On appeal, the Tribunal held that, provisions of S. 14A of the Act cannot be attracted if there is no exempt income earned during the year and hence disallowance of interest is not allowable when there is no exempt income earned. (AY.2010-11, 2014-15)
ACIT v. Amartara P. Ltd. (2020) 78 ITR 46 (SN) (Mum)(Trib)
S. 14A : Disallowance of expenditure – Exempt income – Investments Not generating any exempt income – Disallowance of interest on borrowed funds utilized for making investments cannot be made [R.8D ]