https://www.taxtmi.com/caselaws?id=251408 Section 14A disallowance cannot be sustained where the assessee has not earned any dividend or other exempt income in the relevant assessment years, because the provision applies only to expenditure incurred in relation to income not forming part of total income. The Court rejected a hypothetical disallowance based merely on the assessee's status as an investment company and future of exempt income, and also noted that genuine business expenditure incurred to carry on activities and protect investments could not be completely disallowed on that basis. The additions were deleted, and the issue was decided in favour of the assessee. en-us Fri, 05 Sep 2014 00:00:00 +0530 Fri, 01 Aug 2025 15:38:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251408 Section 14A disallowance cannot be sustained where the assessee has not earned any dividend or other exempt income in the relevant assessment years, because the provision applies only to expenditure incurred in relation to income not forming part of total income. The Court rejected a hypothetical disallowance based merely on the assessee's status as an investment company and future of exempt income, and also noted that genuine business expenditure incurred to carry on activities and protect investments could not be completely disallowed on that basis. The additions were deleted, and the issue was decided in favour of the assessee. Case-Laws Income Tax Fri, 05 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251408