https://www.taxtmi.com/caselaws?id=464394 Disallowance under Section 14A read with Rule 8D was held impermissible where no exempt income was received or receivable during the relevant year. The governing principle applied was that Section 14A operates only when income not forming part of total income actually arises in the previous year, so a nil exempt-income year cannot attract the disallowance machinery. CBDT Circular No. 5/2014 could not override the statute, and the later explanatory amendment to Section 14A was treated as non-retrospective. On that basis, the tax disallowance failed. en-us Thu, 24 Nov 2022 00:00:00 +0530 Mon, 27 Oct 2025 20:01:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464394 Disallowance under Section 14A read with Rule 8D was held impermissible where no exempt income was received or receivable during the relevant year. The governing principle applied was that Section 14A operates only when income not forming part of total income actually arises in the previous year, so a nil exempt-income year cannot attract the disallowance machinery. CBDT Circular No. 5/2014 could not override the statute, and the later explanatory amendment to Section 14A was treated as non-retrospective. On that basis, the tax disallowance failed. Case-Laws Income Tax Thu, 24 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464394