2023 (9) TMI 1551

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..... LHI HIGH COURT] has held that no disallowance u/s 14A of the Act can be made if the assessee had not earned any exempt income during the year under consideration. Thus, respectfully following the same, we find that there is no exempt income earned by the assessee during the year and therefore, disallowance u/s 14A of the Act is uncalled for and accordingly, we set aside the finding of CIT(A) and d .....

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..... For that on the facts and in the circumstances of the case, the Ld. CIT(A) erred in confirming the order of the AO making disallowance of Rs. 13,28,529/- u/s 14A read with Rule 8D. 2. For that on the facts and circumstances of the case, the interest levied u/s 234B and 234C deserves to be reduced and/or deleted. 3. For that the appellant craves leave to submit additional grounds and/or amend or al .....

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..... ng expenses incurred in relation to earning of income not includable in its total income ld. AO applied Rule 8D of the Income Tax Rules, 1962 and computed disallowance u/s 14A of the Act at Rs. 13,28,529/-. Before us ld. Counsel for the assessee, as an officer of Court stated that the assessee company has not earned any exempt income during the year. We observe that Hon'ble Delhi High Court in .....

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