Dy. CIT v. Futurz Next Services P. Ltd. (2020) 80 ITR 58( Delhi ) (Trib)

S. 14A : Disallowance of expenditure – Exempt income – Not earning any exempt income during relevant period — No disallowance can be made .[ R.8D ]

Tribunal held that S. 14A envisages that there has to be actual receipt of exempt income during the relevant previous year for purpose of making any disallowance.. The Assessing Officer having categorically held that no exempt income was earned by the assessee during the year 2013-14 there could be no disallowance. Followed  Cheminvest Ltd. v. CIT ( 2015) 378 ITR 33 ( Delhi) (HC)  ( AY.2013-14)