https://www.taxtmi.com/caselaws?id=459715 The ITAT Kolkata dismissed the Revenue's appeal, affirming the CIT(A)'s decision to delete the disallowance under sec. 14A r.w.s. Rule 8D. The CIT(A) had reversed the AO's disallowance of Rs. 1,56,07,230, as the assessee did not earn any exempt income during the year. The ITAT upheld that sec. 14A disallowance is inapplicable without exempt income, aligning with judicial precedents. The ruling emphasizes the necessity of exempt income for sec. 14A and Rule 8D application, requiring a factual basis for such disallowances. en-us Mon, 07 Dec 2020 00:00:00 +0530 Tue, 24 Dec 2024 20:36:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459715 The ITAT Kolkata dismissed the Revenue's appeal, affirming the CIT(A)'s decision to delete the disallowance under sec. 14A r.w.s. Rule 8D. The CIT(A) had reversed the AO's disallowance of Rs. 1,56,07,230, as the assessee did not earn any exempt income during the year. The ITAT upheld that sec. 14A disallowance is inapplicable without exempt income, aligning with judicial precedents. The ruling emphasizes the necessity of exempt income for sec. 14A and Rule 8D application, requiring a factual basis for such disallowances. Case-Laws Income Tax Mon, 07 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459715