DABWALI TRANSPORT COMPANY LIMITED,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH

िनधा�रती क� ओर से/Assessee by : Shri Ashwani Kumar, C.A राज�व क� ओर से/ Revenue by : Shri Vivek Vardhan, JCIT, Sr. DR सुनवाई क� तारीख/Date of Hearing : 18/12/2024 उदघोषणा क� तारीख/Date of Pronouncement : 30/12/2024 आदेश/Order PER VIKRAM SINGH YADAV, A.M. : This is an appeal filed by the Assessee against the order of the Ld. CIT (A)/NFAC, Delhi dt. 28/12/2023 pertaining to Assessment Year 2017-18 wherein the sole ground of appeal relates to sustenance of disallowance of Rs. 33,56,578/- under Section 14A of the Act.

2. During the course of hearing, the Ld. AR submitted that it is an undisputed fact that the assessee has not earned any exempt income during the year under consideration and in such a situation, where no exempt income has been earned, the question of disallowance of any expenditure in relation to earning of the exempt income does not arise for consideration. It was submitted that it is now a settled position as supported by the decision of various authorities and in this regard, our reference was drawn to the decision of Hon’ble Punjab & Haryana High Court in case of CIT Vs. Lakhani Marketing (2014) 49 taxmann.com 257 (P& H) and Pr. CIT-1, Vs M/s Vardhman Chemtech (P) Ltd. (2020) 423 ITR 241 (P&H). It was further submitted that the Hon’ble