The Tribunal held that as the assessee had not earned any exempt income during the relevant assessment years, no disallowance under section 14A read with rule 8D could be made. (AY. 2012-13, 2014-15 & 2015-16).
SIEL Ltd. v. Dy. CIT (LTU) (2025) 123 ITR 599 / 173 taxmann.com 278 (Delhi)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-No exempt income earned-Disallowance not sustainable. [R. 8D]
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