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TMI Blog2017 (3) TMI 1763X X X X Extracts X X X X X X X X Extracts X X X X ..... also carefully examined the computation of income and the Balance Sheets and find that the assessee has not earned any exempted income. We have also examined the judgments referred to by the assessee in which a similar proposition has been laid down. Therefore, we are of the view that when the assessee has not received any exempted income, no disallowance under section 14A can be made. We accordin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isallowance to the extent of ₹ 68,40,793/- under the provisions of section 14A of the act r.w. Rule 8D(2)(iii) of the Rules ignoring the fact that, for the facts of the appellant case the provisions of section 14A of the act, does not apply. 3. The learned Commissioner of Income Tax (Appeals) erred in confirming the disallowance U/s.14A of the act, ignoring the fact that, the appel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ose of earning exempt income. 6. The appellant craves permission to add, delete or alter any of the grounds at the time of hearing. 2. During the course of hearing, the learned counsel for the assessee has contended that the assessee has not received any exempted income therefore no disallowance under section 14A can be made. In support of his contention, he has invited our att ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the lower authorities in the light of the rival submissions, we find that the assessee has not received any exempted income, therefore no disallowance under section 14A is to be made. We have also carefully examined the computation of income and the Balance Sheets and find that the assessee has not earned any exempted income. We have also examined the judgments referred to by the assessee in whic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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