9911796707
TMI Blog2023 (6) TMI 214X X X X Extracts X X X X X X X X Extracts X X X X ..... idend income earned by the assessee is NIL. Thus, it is clear that the assessee has not earned any exempt income in the relevant assessment year under appeal against the investments. As relying on M/S CHETTINAD LOGISTICS PVT. LTD. [ 2018 (7) TMI 567 - SC ORDER] held that when there was no dividend income earned in the relevant assessment year, the disallowance made by the Assessing Officer in v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant to the assessment year 2018-19. The only issue involved in this appeal is relating to deletion of disallowance made under section 14A of the Income Tax Act, 1961 [ Act in short] amounting to ₹. 2,36,66,025/-. 2. Brief facts of the case are that the assessee filed its return of income for the assessment year 2018-19 on 30.10.2018 admitting loss of ₹. 3,55,08,850/-. The return wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as submitted that when there is no express provisions in section 14A and Rule 8D, the ld. CIT(A) has erroneously restricted the disallowance. 4. On the other hand, the ld. Counsel for the assessee has relied on the decision in the case of CIT v. Chettinad Logistics Pvt. Ltd. (supra) and strongly supported the order passed by the ld. CIT(A). 5. We have heard both the sides, perused the materi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ected the Assessing Officer to delete the addition towards disallowance made under section 14A of the Act. 6. In this case, the ld. CIT(A) has observed that in his assessment order itself, the Assessing Officer has clearly stated that the assessee has not earned from equity investments which would yield exempt dividend income and the dividend income earned by the assessee is NIL. Thus, it is cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issed by the Hon ble Supreme Court [2018] 95 taxmann.com 250 (SC). In view of the above decision in the case of CIT v. Chettinad Logistics (P) Ltd. (supra), we find no infirmity in the order passed by the ld. CIT(A) in directing the Assessing Officer to delete the addition made towards disallowance of ₹. 2,36,66,025/- under section 14A of the Act. Thus, the ground raised by the Revenue is di ..... X X X X Extracts X X X X X X X X Extracts X X X X
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