Dismissing the appeal of the revenue the Tribunal held that; provision would not apply where no exempt income was received or receivable during relevant previous year by assessee. Followed Cheminvest Ltd. v CIT(2015) 378 ITR 33 (Delhi)(HC)(AY.2010-11)
ACIT v. Dish TV India Ltd. (2018) 194 TTJ 897/ 169 DTR 253 (Mum)(Trib.)
S. 14A : Disallowance of expenditure – Exempt income –Provision would not apply where no exempt income was received or receivable during relevant previous year by assessee. [R. 8D ]