Triveni Engineering & Industries Ltd. v. ACI (2020) 118 taxmann.com 301/ (2021) 186 ITD 353 (Delhi (Delhi)(Trib.)

S. 14A : Disallowance of expenditure – Exempt income – Ad-hoc disallowance – Deleted.[R.8D ]

The Tribunal noted that the Assessing Officer accepted that no expenditure has been incurred for earning the dividend income and therefore no disallowance under section 14A was called for. Without appreciating this aspect, the Assessing Officer disallowed Rs. 3 lacs under section 14A of the Act on an ad-hoc basis, and while doing so the Assessing Officer had not established any nexus between the expenditure and earning of dividend income. The Tribunal deleted the disallowance. (ITA Nos. 1955 to 1959/Del/2016; dt. 06-08-2020) (AY. 2001-02 to  2005-06)