DCIT v. SNJ Distillers Pvt. Ltd. (2020) 208 TTJ 968 / (2021) 87 ITR 540 (Chennai)(Trib.)

S. 14A : Disallowance of expenditure-Exempt income-No exempt income-No disallowance can be made. [R. 8D]

The facts born out from record clearly indicate that the assessee has not earned any dividend income which does not form part of total income for the year under consideration. In fact, the Ld. AO has categorically admitted that for the impugned assessment years, the assessee has not earned any dividend income from investments. No disallowance can be made. (AY. 2014-15 to 2016-17)