Dismissing the appeal of the revenue the Tribunal held that; No disallowance can be made in the absence of any exempt income earned during the year. (AY. 2012-13)
DCIT v. Piramal Realty (P.) Ltd. (2019) 174 ITD 633/ 198 TTJ 999 / 176 DTR 242 (Mum.) (Trib.)
S. 14A : Disallowance of expenditure – Exempt income – No disallowance can be made in the absence of any exempt income earned during the year . [R. 8D]