Shanti Prime Publication Pvt. Ltd.
Sec. 14A of Income Tax Act, 1961 — Disallowance — Disallowance under Section 14A read with Rule 8D cannot exceed the Assessee's exempt income— When the Assessee has not earned any income which was exempt from tax, disallowance of the expenditure under Section 14A read with 8D would not be permissible. Where the assessee's income exempt from tax is not NIL but has earned exempt income which is larger than the expenditure incurred by the assessee in order to earn such income, in such a situation that disallowance cannot exceed the exempt income so earned by the assessee during the year under consideration— Nirved Traders Pvt. Ltd. vs. Deputy CIT [2020] 421 Itr 142 (BOM)