https://www.taxtmi.com/caselaws?id=470893 Section 14A read with rule 8D does not permit disallowance of expenditure where no exempt income was earned during the relevant assessment year. Since the investments did not generate exempt income, no expenditure could be regarded as incurred in relation to income excluded from total income. A CBDT circular supporting disallowance despite the absence of exempt income cannot override the statutory provision or its judicial interpretation. Accordingly, the section 14A disallowance computed under rule 8D was unsustainable and deleted. en-us Thu, 27 Mar 2025 00:00:00 +0530 Wed, 12 Aug 2026 21:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470893 Section 14A read with rule 8D does not permit disallowance of expenditure where no exempt income was earned during the relevant assessment year. Since the investments did not generate exempt income, no expenditure could be regarded as incurred in relation to income excluded from total income. A CBDT circular supporting disallowance despite the absence of exempt income cannot override the statutory provision or its judicial interpretation. Accordingly, the section 14A disallowance computed under rule 8D was unsustainable and deleted. Case-Laws Income Tax Thu, 27 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470893