Assessee had not derived any exempt income during year. Hence, provisions of S.14A cannot be made applicable. This issue is now very well settled by the decision of Supreme Court in case of Maxopp Investments Ltd. v. CIT (2018) 402 ITR 640 (SC). (AY. 2010-11, 2011-12, 2012-13)
Dy. CIT v. BMI Whole sale Trading (P) Ltd. (2020) 203 TTJ 797 (Mum.)(Trib.) Dy.CIT v. Brand Marketing (India) (P.) Ltd. (2020) 203 TTJ 797 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-No exempt income-No disallowance can be made. [R. 8D]