ACIT v. Progressive Constructions Ltd ( 2018) 161 DTR 289 /63 ITR 516/ 191 TTJ 549( SB) ( Hyd) (Trib)

S. 14A : Disallowance of expenditure – Exempt income – When there is no exempt income during the relevant year no disallowance can be made .[ R.8D ]

Tribunal held that , when there is no exempt income during the relevant assessment year , no disallowance can be made , even otherwise the assessee had sufficient surplus interest -free funds to make in vestment in exempt yielding assets . ( AY.2011-12)