Dismissing the appeal of the revenue the Court held that section 14A could only be invoked if the assessee had earned exempted income during the relevant assessment year, that the disallowance could be only to the extent of expenses in relation to earn exempted income and in interpreting Circular No. 5 of 2014 ([2014] 361 ITR (St.) 94) of the Central Board of Direct Taxes which clarified the true scope and meaning of section 14A.(AY.2010-11)