DCIT - 10 (3)(2), MUMBAI vs. PARAJAPE PROPERTIES & INVESTMENT PVT. LTD., MUMBAI

ORDER PER N.K. PRADHAN, A.M. The appellant has filed a written submission stating as under: “In the above referred case appeal was filed before the Hon’ble ITAT although the tax effect involved was before the prescribed monetary limit as specified in CBDT Circular No. 03/2018 dated 11.07.2018. The appeal had been filed considering the circular of CBDT No. 05/2014 dated 11.02.2014, specifically clarifying that disallowance u/s 14A of the Act needs to be done even if no exempt income has been earned by the assessee during the previous year related to the concerned year. In the light of Apex Court recent decision in the case of Chettinad Logistics Pvt. Ltd. [Special Leave Petition (Civil) Diary No. 15631 of 2018] upholding the decision of Hon’ble Madras High Court that no disallowance u/s 14A can be made if there was no exempt income in the relevant AY and also in light