https://www.taxtmi.com/caselaws?id=397763 The Tribunal upheld the decision of the CIT(A) and dismissed the appeal filed by the Revenue. It was held that disallowance under Section 14A read with Rule 8D is not applicable when no exempt income is earned during the relevant assessment year. The reliance on CBDT Circular No. 05/2014 by the AO was deemed incorrect, as the circular cannot override the explicit provisions of the law. The Tribunal's decision aligns with the consistent judicial view that Section 14A disallowance requires actual receipt of exempt income during the relevant year. en-us Wed, 18 Mar 2020 00:00:00 +0530 Thu, 27 Aug 2020 17:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397763 The Tribunal upheld the decision of the CIT(A) and dismissed the appeal filed by the Revenue. It was held that disallowance under Section 14A read with Rule 8D is not applicable when no exempt income is earned during the relevant assessment year. The reliance on CBDT Circular No. 05/2014 by the AO was deemed incorrect, as the circular cannot override the explicit provisions of the law. The Tribunal's decision aligns with the consistent judicial view that Section 14A disallowance requires actual receipt of exempt income during the relevant year. Case-Laws Income Tax Wed, 18 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397763