On appeal by the Department, the Tribunal affirmed the order of the Ld. CIT(A) and held that no disallowance u/s. 14A of the Act could be made where no exempt income is actually earned by the Assessee during the year. (AY. 2011-12)
ACIT v. Sodexo Food Solutions India P. Ltd. (2019) 69 ITR 119 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income–No disallowance could be made where no exempt income was actually earned by the Assessee during the year. [R. 8D]