2019 (6) TMI 599

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....ICIAL MEMBER: The present appeal has been preferred by the Revenue against the order dated 31/07/2018 of the Commissioner of Income Tax (Appeals) I, Ludhiana [hereinafter referred to as CIT(A)] agitating the action of the Ld. CIT(A) in deleting the addition made by the Assessing officer on account of disallowance of Rs. 2,14,68,549/- u/s 14A of the Income Tax Act read with Rule 8D of the Income T....

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....IT Vs. Hero Cycles Ltd.' [2010] 323 ITR 518 and 'CIT Vs. Winsome Industries Ltd.' [2009] 319 ITR 203, categorically held that unless and until there is a receipt of exempt income for the concerned assessment year, provisions of section 14A cannot be invoked. 3. The Ld. DR, though supported the order of the Assessing officer but could not rebut the factual findings given by the Ld. CIT(A). 4. We ....