It was held that no disallowance under section 14A was to be made where assessee has not earned any income during the relevant period. (AY. 2009-10, 2010-11)
Tata Sky Ltd. v. ACIT (2020) 195 DTR 177 / 208 TTJ 194 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-No income earned by assessee during the relevant AY-No disallowance can be made. [R. 8D].