https://www.taxtmi.com/caselaws?id=449066 ITAT Delhi held that no disallowance under section 14A read with Rule 8D could be made where the assessee had not incurred any actual expenditure for earning exempt income. The AO's finding that expenditure must have been incurred for mutual fund investments was based on conjecture without identifying actual expenditure. Following Supreme Court precedent in Maxopp Investment Ltd., the Tribunal ruled that section 14A requires actual expenditure, not imagined expenditure. The CIT(A)'s deletion of the disallowance was upheld. Appeal decided against revenue. en-us Thu, 21 Dec 2023 00:00:00 +0530 Mon, 05 Feb 2024 08:44:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449066 ITAT Delhi held that no disallowance under section 14A read with Rule 8D could be made where the assessee had not incurred any actual expenditure for earning exempt income. The AO's finding that expenditure must have been incurred for mutual fund investments was based on conjecture without identifying actual expenditure. Following Supreme Court precedent in Maxopp Investment Ltd., the Tribunal ruled that section 14A requires actual expenditure, not imagined expenditure. The CIT(A)'s deletion of the disallowance was upheld. Appeal decided against revenue. Case-Laws Income Tax Thu, 21 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449066