Held that on the facts the Tribunal was correct in deleting the disallowances made under section 14A since no exempt income was earned by the assessee in the assessment years 2012-13 and 2013-14. The contention of the Department that the Tribunal had failed to consider the Central Board of Direct Taxes Circular No. 5 of 2014 dated February 11, 2014 ([2014] 361 ITR (St.) 94) was also untenable. (AY. 2012-13, 2013-14)
PCIT v Amadeus India Pvt. Ltd. (No. 2) (2023) 452 ITR 206 / 290 Taxman 201 (Delhi)(HC)
S. 14A : Disallowance of expenditure-Exempt income-No exempt income during the year-Deletion of addition is justified. [R. 8D]