https://www.taxtmi.com/caselaws?id=774240 ITAT Delhi quashed CIT's revision order u/s 263 regarding disallowance u/s 14A and TDS mismatch. Tribunal held that no disallowance can be made when assessee received no exempt income during the year, citing settled law by various HCs and coordinate benches. CBDT circular has no application without exempt income. Regarding TDS mismatch, assessee consistently followed POCM method for housing projects, causing natural variance between TDS deducted and declared income. CIT failed to examine reconciliation and merely remanded matter without clear findings on revenue prejudice. Since AO took possible view, CIT cannot substitute another possible view. Appeal allowed. en-us Mon, 30 Jun 2025 00:00:00 +0530 Sat, 05 Jul 2025 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774240 ITAT Delhi quashed CIT's revision order u/s 263 regarding disallowance u/s 14A and TDS mismatch. Tribunal held that no disallowance can be made when assessee received no exempt income during the year, citing settled law by various HCs and coordinate benches. CBDT circular has no application without exempt income. Regarding TDS mismatch, assessee consistently followed POCM method for housing projects, causing natural variance between TDS deducted and declared income. CIT failed to examine reconciliation and merely remanded matter without clear findings on revenue prejudice. Since AO took possible view, CIT cannot substitute another possible view. Appeal allowed. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774240