The Tribunal held that when there is no tax free income earned during the year, no disallowance u/s. 14A could be made. (AY. 2009-10 to 2014-15)
ACIT v. Orissa Manganese & Minerals Ltd. (2019) 69 ITR 1 (SN) (Kol.) (Trib.)
S. 14A : Disallowance of expenditure-Exempt income–Disallowance cannot be made if there is no tax free income. [R. 8D]