CIT v. Continuum Wind Energy (India) Pvt. Ltd. (2021) 430 ITR 52 / 276 Taxman 286 (Mad.)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Investment in subsidiary companies-When there is no exempt income-No disallowance can be made. [R. 8D]

Dismissing the appeal of the revenue the Court held that the investments were made in subsidiary companies. When the investments were made in wholly owned subsidiary companies, it could not be construed that investment was made for earning exempt income. Investment made in the wholly owned company was only for the purpose of business. The Tribunal rightly held that the provisions of section 14A would not stand attracted. (AY.2013-14)