Unless and until there is receipt of exempted income for concerned assessment year, section 14A is not attracted. Circular No.5/2014, dt. 11-2-2014 is considered.
PCIT v. Vardhman Chemtech (P.) Ltd. (2019) 261 Taxman 233/ 179 DTR 35/(2020)423 ITR 241 (P&H)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Unless and until there is receipt of exempted income for concerned assessment year, section 14A is not attracted.[R. 8D]