Held that High where there was no exempt income claimed to be earned by assessee-company during year, there could not be any disallowance of expenditure under section 14A read with rule 8D. Court also held that since disallowance under section 14A itself was deleted, there was no question of adding same back under section 115JB of the Act. (AY. 2015-16)
PCIT v. Adani Wilmar Ltd. (2021) 133 taxmann.com 443 (Guj.)(HC) Editorial : Notice is iisued in SLP filed by the revenue ; PCIT v. Adani Wilmar Ltd. (2022) 285 Taxman 547 (SC)
S.14A : Disallowance of expenditure-Exempt income-No exempt income earned during the year-No disallowance can be made-When no disallowance is made addition cannot be made to book profi.t [S. 115JB, R. 8D]