Challenge to Disallowance u/s 14A for Mutual Fund Consolidation with No Exempt Income Trigger.

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....Disallowance u/s 14A - expenditure incurred on earning exempt income - In the given case the transaction of the consolidation of mutual funds is not considered as a transfer under section 47(xviii) and therefore it does not result in any income within the definition of section 2(24). Therefore we see merit in the contention that the assessee has not earned any income that is exempt under the Act in order invoke section 14A. - AT....