Dy. CIT v. Dee Development Engineers Ltd. (2021) 87 ITR 38 (SN) (Delhi)(Trib.)

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

The AO made an addition under section 14A read with rule 8D of the Income-tax Rules, 1962, although the assessee-company had not earned any exempt income. Tribunal held that there was a clear finding in the assessment order as well as by the CIT(A) that there was no exempt income earned by the assessee during the year. Hence, the disallowance was properly reversed deleted. Cheminvest Ltd. v. CIT [2015] 378 ITR 33 (Delhi) Applied.  (AY.2011-12).