2019 (2) TMI 1332

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....Agarwal a/w Mr. Atul Jasani for the respondent P.C. 1. The appeal is admitted for consideration on following question of law : (i) On the facts and in the circumstance of the case and in law, the Tribunal is not justified in holding that the distribution network, material supply contract and brand use are eligible for depreciation, it has failed to specify any reason as to how it falls wi....

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.... 5. This question relates to disallowance made by the Assessing Officer under Section 14A of the Income Tax Act, 1961 r/w Rule 8D of the Rules of the expenditure incurred by the assessee for earning exempt income. The Tribunal by the judgment which is impugned in this appeal held that the assessee had not earned any exempt income during the year under consideration. The Tribunal, therefore, fol....

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..... On fact, there is no dispute that the assessee has not earned any exempt income during the year under consideration. After consideration of Section 14A, the Delhi High Court followed decisions of certain other High Courts. Section 14A of the said Act provides that for the purpose of computing the total income, no deduction shall be allowed in respect of expenditure incurred by the assessee in re....