2021 (9) TMI 214

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....ue: Shri Gurmel Singh, Sr. D.R. ORDER PER BHAVNESH SAINI, J.M. This appeal by Assessee has been directed against the common Order of the Ld. CIT(A), Ghaziabad, Dated 28.12.2017, for the A.Y. 2014-2015, challenging the addition of Rs. 24,27,800/- under section 14A of the I.T. Act, 1961 read with Rule 8D of the I.T. Rules, 1962. 2. We have heard the Learned Representatives of both the pa....

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....d any exempt income in assessment year under appeal, therefore, the issue is covered by Judgment of the Hon'ble Delhi High Court in the case of Cheminvest vs., CIT [2015] 378 ITR 33 (Del.). The Ld. CIT(A) following his Order for the A.Y. 2012-2013 confirmed the addition and dismissed the appeal of assessee. 4. After considering the rival submissions, we are of the view that the addition is whol....

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....Ltd. vs. CIT (Supra) that if the assessee has not earned any exempt income or when there is no actual receipt of any income which does not form part of the total income, no disallowance u/s 14A can be made, is clearly applicable here. We therefore, respectfully following the said principle laid down by the Honhle Jurisdictional High Court, hold no disallowance u/s 14A can made in this year, becaus....