https://www.taxtmi.com/caselaws?id=395326 The ITAT Mumbai held that no disallowance under section 14A could be made where there was no tax exempt income in the relevant previous year. The tribunal deleted the disallowance made by the Assessing Officer, upholding the assessee's plea. Regarding the procedural issue of order pronouncement beyond 90 days, the tribunal ruled that the COVID-19 lockdown period should be excluded from the 90-day time limit prescribed under rule 34(5) of the Appellate Tribunal Rules, 1963. The tribunal rejected a pedantic interpretation of the rule, considering the exceptional circumstances of the nationwide lockdown. The exception inherent in rule 34(5)(c) was deemed applicable, and no refixing of matters for clarifications was required on the case facts. en-us Thu, 14 May 2020 00:00:00 +0530 Thu, 17 Jul 2025 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395326 The ITAT Mumbai held that no disallowance under section 14A could be made where there was no tax exempt income in the relevant previous year. The tribunal deleted the disallowance made by the Assessing Officer, upholding the assessee's plea. Regarding the procedural issue of order pronouncement beyond 90 days, the tribunal ruled that the COVID-19 lockdown period should be excluded from the 90-day time limit prescribed under rule 34(5) of the Appellate Tribunal Rules, 1963. The tribunal rejected a pedantic interpretation of the rule, considering the exceptional circumstances of the nationwide lockdown. The exception inherent in rule 34(5)(c) was deemed applicable, and no refixing of matters for clarifications was required on the case facts. Case-Laws Income Tax Thu, 14 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395326