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Pr. Commissioner Of Income Tax-04 v. Il & Fs Energy Development Company Ltd.
Judgment Summary — S. Muralidhar, J.
Factual and Procedural Background
The Revenue filed an appeal under Section 260A of the Income Tax Act, 1961 against the Income Tax Appellate Tribunal (ITAT) order dated 7 November 2016 in ITA No. 2895/Del/2015 for Assessment Year (AY) 2011-12. The revenue challenged the ITAT's deletion of a disallowance made by the Assessing Officer (AO) of Rs. 4,00,78,074/- under Section 14A read with Rule 8D of the Income Tax Rules, 1962.
The Respondent-Assessee, a company providing consultancy services, filed its return on 26 September 2011 declaring a loss of Rs. 2,42,63,176/-. The AO questioned why disallowance under Section 14A read with Rule 8D should not be made for computing book profit for Minimum Alternate Tax (MAT) under Section 115JB. The Assessee contended that it had invested in mutual funds and not in interest-bearing funds to earn tax-free income, and therefore no disallowance was called for.
The AO rejected the plea, relying on the Special Bench ITAT decision in Cheminvest Ltd. v. ITO (2009) 121 ITD 318 (Del) (SB) and made additions by the assessment order dated 20 February 2014 (including a large addition of interest/related amounts). The CIT(A) reduced the disallowance to Rs. 4,00,78,074/- and reduced the interest disallowance to Rs. 6,11,80,756/-. The ITAT, by its order dated 7 November 2016, allowed the Assessee's appeal and deleted the disallowance, relying on the view that Section 14A would not apply where no exempt income was earned in the year under consideration. The Revenue appealed to the High Court, which is the subject of this opinion. The appeal was dismissed by the High Court, which concluded that no substantial question of law arises from the ITAT order.
Legal Issues Presented
- Whether the ITAT erred in deleting the AO's disallowance of Rs. 4,00,78,074/- made under Section 14A read with Rule 8D of the Rules for AY 2011-12.
- Whether disallowance under Section 14A read with Rule 8D can be made in an assessment year in which the Assessee has not actually earned any exempt income from investments, but there exists the potential for exempt income to be earned in later years.
Arguments of the Parties
Appellant (Revenue) — Principal Contentions
- The CBDT Circular No. 5/2014 dated 11 February 2014 clarifies that Section 14A applies even where exempt income was not earned in the particular assessment year; Cheminvest (2015) did not consider that Circular.
- There is nothing in Section 14A that requires exempt income to have been earned in the same AY for disallowance to be attracted; otherwise the purpose of Section 14A would be frustrated.
- Precedents and ITAT decisions (e.g., ACIT v. Ratan Housing Development Ltd.; Relaxo Footwear Ltd. v. Addl. CIT) support the view that disallowance can be made even where exempt income has not actually been earned in the year under consideration.
- Certain decisions of this Court (Taikisha Engineering India Pvt. Ltd.; Holcim India P. Ltd.) do not address the CBDT Circular and are therefore distinguishable.
Respondent (Assessee) — Principal Contentions
- The Assessee's investments (including significant investments in equity and fully-convertible debentures) did not yield any exempt income in the AY in question; hence no disallowance under Section 14A arises for that year.
- Some investments were made for commercial/business purposes (subsidiary/joint venture shares) and not for earning exempt dividend income.
- The Assessee also relied on the decision of this Court in Cheminvest Limited v. Commissioner of Income Tax-VI (2015) 378 ITR 33 (Del) and the Gujarat High Court in CIT v. Corrtech Energy Pvt. Ltd. [2015] 372 ITR 97 (Guj), which held that Section 14A does not apply where no exempt income was earned in the year in question.
- Audit report suggestions as to disallowance are not determinative of the legal position; factual openings and balances indicated availability of interest-free funds exceeding investments for the year in question.
Table of Precedents Cited
| Precedent | Rule or Principle Cited For | Application by the Court |
|---|---|---|
| Cheminvest Ltd. v. ITO [2009] 121 ITD 318 (Del) (Special Bench) | Held that Section 14A would apply even if during the AY the investments had not actually yielded any exempt income. | The AO relied on this Special Bench decision to justify making disallowance; the Court noted the Special Bench view but observed that this Court's later decision in Cheminvest (2015) had reversed that Special Bench. |
| Cheminvest Limited v. Commissioner Of Income Tax-VI (2015) 378 ITR 33 (Del) | Held that Section 14A would not apply if the Assessee had not received any exempt income in the year in question. | The ITAT relied on this decision to allow the Assessee's appeal; the High Court considered this decision persuasive and declined to reconsider it in light of the CBDT Circular. |
| CIT v. Corrtech Energy Pvt. Ltd. [2015] 372 ITR 97 (Guj) | Held in line with Cheminvest (2015) that Section 14A does not apply where no exempt income was earned in the year. | Cited by the ITAT in support of deleting disallowance; the High Court noted this decision as consistent with its reasoning. |
| ACIT v. Ratan Housing Development Ltd. (ITAT Lucknow, order dated 23 May 2008) | ITAT decision suggesting applicability of disallowance even where exempt income not actually earned (as relied upon by Revenue). | The High Court stated that such ITAT decisions, to the extent inconsistent with the present holding, do not merit acceptance. |
| Relaxo Footwear Ltd. v. Addl. CIT [2012] 50 SOT 102 (Del) | Decision relied upon by Revenue supporting broader application of Section 14A. | The High Court noted this decision but rejected its applicability where inconsistent with the interpretation of Section 14A read with Rule 8D adopted in the present judgment. |
| Commissioner of Income Tax v. Walfort Share and Stock Brokers Pvt. Ltd. [2010] 326 ITR 1 (SC) | Explains the mandate of Section 14A: to prevent claiming deductions in relation to exempt income while availing the exemption without apportionment of expenses. | The High Court relied on this Supreme Court statement to emphasize the object of Section 14A and to support its view that Section 14A targets actual exempt income and related expenses. |
| Redington (India) Ltd. v. Additional Commissioner of Income Tax (Madras HC, order dated 23 Dec 2016, TCA No. 520 of 2016) | Held that Section 14A relates to earning of actual income and not notional or anticipated income; declined to apply CBDT Circular to expand applicability to notional income. | The High Court cited this decision as a similar authority negating the Revenue's contention and supporting the focus on actual exempt income in the assessment year. |
| CIT v. Lakhani Marketing Inc. (2014 SCC OnLine P&H 20357) | Taken as authority aligning with the view that Section 14A relates to actual exempt income. | Cited as one of several authorities adopting a like view; the High Court referenced it as part of a consistent line of decisions. |
| CIT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204 (P&H) | Decision following a view consistent with limiting disallowance to situations involving actual exempt income. | Used as supporting authority for the Court's interpretation that Section 14A is tied to actual exempt income. |
| CIT v. Shivam Motors (P) Ltd. (2014) 272 CTR (All) 277 | Another decision that has taken a similar view regarding Section 14A. | Referred to by the Court as part of consistent judicial views limiting Section 14A disallowance to cases involving actual exempt income. |
| Commissioner of Income Tax, West v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC) | Interpreted Section 57(iii): deduction allowable even where income was not actually earned in the AY; focuses on purpose of expenditure. | The High Court distinguished this Supreme Court decision, holding it is inapposite to Section 14A because Section 57(iii) uses different language (purpose-focused) than Section 14A (which speaks of expenditure "in relation to income which does not form part of the total income"). |
| Taikisha Engineering India Pvt. Ltd. [2015] 370 ITR 338 (Del) | Decision of this Court mentioned in submissions; not held to have specifically dealt with CBDT Circular or the precise issue here. | The Court noted that Taikisha does not specifically deal with the CBDT Circular issue and therefore is distinguishable on that basis. |
| Commissioner Of Income Tax-IV v. Holcim India P. Ltd. (2014) 272 CTR (Del) 282 | Mentioned by Revenue in support of its stance; the High Court noted it did not discuss the CBDT Circular. | The Court observed that Holcim did not address the CBDT Circular and therefore could be distinguished on that basis. |
Court's Reasoning and Analysis
The Court's analysis proceeded from statutory text, legislative history and the concept of “real income.” Key aspects of the Court's reasoning, as stated in the opinion, are summarized below.
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Statutory framework and timeline:
The Court reviewed the history: Section 14A was inserted (with retrospective effect to 1 April 1962) to disallow expenditure incurred in relation to exempt income. A proviso (from 11 May 2001) prevents reopening of completed assessments. Sub-sections (2) and (3) (from 1 April 2007) provided for methodology, but Rule 8D furnished the actual methodology only from 24 March 2008. A later amendment (2 June 2016) changed computation limits. For AY 2011-12, Rule 8D was applicable.
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Core interpretive question:
The Court reformulated the key question as whether disallowance under Section 14A and Rule 8D can be applied where the investment did not yield exempt income in that AY but might yield exempt income in later years.
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Textual reading of Rule 8D(1):
Rule 8D(1) uses the phrase “in relation to income which does not form part of the total income under the Act for such previous year.” The Court read the phrase “such previous year” to indicate a nexus between the exempt income earned in that specific year and the expenditure disallowable for that year. Thus, if no exempt income was earned in the AY in question, the rule's language suggests the question of disallowance does not arise for that year.
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Concept of "real income" and Section 5:
The Court emphasized that taxable income under Section 5 must be real income (not notional or speculative). The Court declined an interpretation that would produce an artificial disallowance based on anticipated or notional exempt income in a year when no exempt income actually arose.
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Critique of the CBDT Circular (11 Feb 2014 / 11 May 2014 references in the text):
The Revenue relied heavily on the CBDT Circular which stated disallowance could be triggered even if exempt income was not included in a particular year. The Court viewed this as a truncated reading because the Circular did not consider the Rule 8D(1) textual phrase “such previous year” nor the concept of real income under Section 5. Accordingly, the Court found the Circular could not override the statutory text.
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Reliance on precedent and distinction from other provisions:
The Court relied on the Supreme Court's explanation in Commissioner of Income Tax v. Walfort Share and Stock Brokers Pvt. Ltd. to illuminate Section 14A's object — to prevent mismatch of claiming deductions for expenses relating to exempt income while enjoying exemption without apportionment. The Court distinguished Rajendra Prasad Moody (s.57(iii) context) on the ground that the statutory language and object are different; Rajendra Prasad Moody cannot be inverted to support extending Section 14A to cases of notional or future exempt income.
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Support from other high court decisions and final view:
The Court noted consistent decisions (e.g., Redington (Madras), Corrtech (Guj), several P&H / All decisions) that limit Section 14A to situations involving actual exempt income for the year. On that basis the Court held that the ITAT's deletion of disallowance was justified and that the CBDT Circular did not displace the statutory text and Rule 8D(1)'s wording.
Holding and Implications
HOLDING: The appeal by the Revenue is dismissed and no substantial question of law arises from the impugned ITAT order. The ITAT order deleting the disallowance under Section 14A read with Rule 8D for AY 2011-12 is therefore sustained.
Implications:
- Direct effect on parties: The ITAT's decision in favour of the Assessee (deleting the disallowance of Rs. 4,00,78,074/- and related adjustments as recorded in the orders below) stands; the Revenue's challenge is dismissed.
- Statutory interpretation: The Court held that Section 14A read with Rule 8D(1) must be read to require a link to exempt income "for such previous year"; accordingly, where no exempt income is earned in the assessment year, disallowance under Section 14A/R.8D will not arise for that year on the basis of notional or anticipated exempt income for future years.
- On administrative guidance: The Court concluded that the CBDT Circular relied on by the Revenue does not override the expressed provisions of Section 14A read with Rule 8D, given the statutory language and the concept of real income.
- Scope of further challenge: The Court expressly recorded that no substantial question of law arises from the ITAT order, which circumscribes the scope for further challenge under Section 260A in this matter.
Note: This summary is strictly confined to the statements, reasoning, and conclusions contained in the provided opinion and does not add information beyond the text of the judgment.
S. Muralidhar, J.:— The matter is taken up for hearing today as 14th August 2017 was declared a holiday on account of Janmashtami.
2. This appeal by the Revenue under Section 260 A of the Income Tax Act, 1961 (‘Act’) is directed against the order dated 7 November 2016 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 2895.Del/2015 for the Assessment Year (‘AY’) 2011 - 2012.
3. The question of law sought to be urged by the Revenue is whether the ITAT erred in deleting the disallowance made by the Assessing Officer (‘AO’) of the sum of Rs. 4,00,78,074/- from the returned income of the Assessee under Section 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 (‘Rules’).
4. The facts are that the Respondent-Assessee is a company engaged in provision of consultancy services. On 26 September 2011, the Assessee filed its return at a loss of Rs. 2,42,63,176/-. The Assessee was asked to explain why disallowance should not be made under Section 14A of the Act read with Rule 8D of the Rules for the purpose of normal computation of book profit for the purpose of Minimum Alternative Tax (‘MAT’) under Section 115JB of the Act.
5. The response of the Assessee was that it had made investment in mutual funds and that no interest bearing funds were invested to earn tax free income. It accordingly pleaded that no disallowance under Section 14A of the Act was called for.
6. However, this plea was rejected by the AO who relied on the decision of the Special Bench of the ITAT Delhi in Cheminvest Ltd. v. ITO [2009] 121 ITD 318 (Del) (SB) wherein it was held that Section 14A would apply even if during the AY in question, the investment has not actually yielded any exempt income. The AO, by the assessment order dated 20 February 2014, made an addition of Rs. 15,44,43,369/- to the income of the Assessee. The AO held that the Assessee had made investments in shares to the tune of Rs. 5,29,38,26,780/- for the purposes of earning dividend income not chargeable to the tax. The AO noted that, even in the tax audit report, the auditors had calculated disallowance under section 14a read with rule 8d in the sum of Rs. 5,89,22,873/-, which included direct expenses of Rs. 1,12,025/-.
7. The appeal filed by the Assessee was disposed of by the Commissioner of Income (Appeal) [‘CIT (A)’] by an order dated 20 March 2015 observing as under:
(i) The opening balance in the investment of the appellant company, as on 31st March 2010 was Rs. 44.98 lakh. The bulk of the investment was made during the year in the equity shares of ONGC Tripura Power Company Limited in the sum of Rs. 402,32,17,980/-, Himachal Sorang Power Limited in the sum of Rs. 35,70,40,000/- and, SE Power Private Ltd. in the sum of Rs. 28,99,60,000/-.
(ii) In terms of the decision of ITAT Delhi (Special Bench) in Cheminvest Ltd. (supra), Section 14A would apply even where the investments do not give rise to exempt income pertaining to the AY in question. Further, the Central Board of Direct Taxes (‘CBDT’) by Circular No. 5/2014 dated 11 February 2014 clarified the above position.
(iii) On facts, it could not be held categorically that the Assessee used significant amount of its own funds only towards investments while the borrowed funds were used only towards fixed assets and loans and advances given by the Assessee. Some amount of the borrowed funds would have gone towards making investments. Even the Assessee admitted that the balance amount of loans of Rs. 175 crores could have been utilized for making investments. Consequently, the application of Rule 8D(2)(ii) of the Rules by the AO could not be said to be erroneous.
(iv) The CIT (A) reduced the disallowance to Rs. 4,00,78,074/-. The CIT (A) also reduced the interest disallowed from Rs. 29,03,54,953/- to Rs. 6,11,80,756/-.
8. The ITAT, by the impugned order dated 7 November 2016, allowed the Assessee's appeal and held as under:
(i) The Assessee had made investments in various companies amounting to Rs. 5,29,38,26,780/-. Out of said investments, an amount of Rs. 35,70,40,000/- was invested in fully convertible debentures which could yield no tax-free income.
(ii) When the Assessee did not earn any exempt income, there could not be any disallowance. Further, when the Assessee had made investments in shares of subsidiary companies and joint ventures for the purposes of business and not for earning exempted dividend income, there could not be any disallowance. This Court, in Cheminvest Limited v. Commissioner Of Income Tax-Vi (2015) 378 ITR 33 (Del), reversed the decision of the Special Bench of the ITAT and held that Section 14A of the Income Tax Act would not apply if the Assessee had not received any exempt income in the year in question. The Gujarat High Court had, in CIT v. Corrtech Energy Pvt. Ltd. [2015] 372 ITR 97 (Guj) held likewise. The Assessee held interest free funds in the form of share capital, share application money and reserve paid surplus, which exceeded the amount invested by the Assessee. Consequently, the question of disallowance of any expenditure incurred to earn exempt income during the AY in question did not arise.
9. Mr. Zoheb Hossain, learned Senior Standing Counsel for the Revenue, submitted that, in Cheminvest Ltd. (supra), this Court had no occasion to consider the CBDT Circular No. 5/2014 dated 11 February 2014 which clarified that Section 14A would apply even when exempt income was not earned in a particular AY. According to him, the other decisions of this Court in CIT-IV v. Taikisha Engineering India Pvt. Ltd. [2015] 370 ITR 338 (Del) and Commissioner Of Income Tax-Iv v. Holcim India P. Ltd…. (2014) 272 CTR (Del) 282 did not actually discuss the above Circular of the CBDT and, therefore, would be distinguishable.
10. Mr. Hossain further submitted that there was nothing in Section 14A of the Act which suggested that exempt income had to necessarily be earned in the AY in question for the applicability of the said provision. He submitted that if the interpretation placed on Section 14 A of the Act by the above CBDT Circular was not accepted, the very purpose of Section 14A would be defeated. He referred to the decisions of the ITAT in ACIT v. Ratan Housing Development Ltd. (order dated 23rd May 2008 of ITAT Lucknow) Relaxo Footwear Ltd. v. Addl. CIT [2012] 50 SOT 102 (Del).
11. At the outset, it requires to be noticed that we are concerned with the AY 2011-12 and, therefore, the question of the applicability of Rule 8D, which was inserted with effect from 24 March 2008, is not in doubt.
12. Section 14A of the Act, which was inserted with retrospective effect from 1 April 1962, provides for disallowance of the expenditure incurred in relation to income exempted from tax. From 11 May 2001, a proviso was inserted in Section 14A to clarify that it could not be used to reopen or rectify a completed assessment. sub-sections (2) and (3) of section 14a were inserted with effect from 1 April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in terms of Rule 8D only from 24 March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance the aggregate of the amount of expenditure directly relating to income which does not form part of total income and an amount equal to one per cent of the annual average of the monthly average of the opening and closing balances of the value of investment, income from which does not form part of the total income. It is also provided that the amount shall not exceed the total expenditure claimed by the Assessee.
13. In the above background, the key question in the present case is whether the disallowance of the expenditure will be made even where the investment has not resulted in any exempt income during the AY in question but where potential exists for exempt income being earned in later AYs.
14. In the Explanatory Memorandum to the Finance Act 2001, by which Section 14A was inserted with effect from 1 April 1962, it was clarified that “expenses incurred can be allowed only to the extent they are relatable to the earned income of taxable income”. The object behind Section 14A was to provide that “no deduction shall be made in respect of any expenditure incurred by the Assessee in relation to income which does not form part of the total income under the Income Tax Act”.
15. What is taxable under Section 5 of the Act is the “total income” which is neither notional nor speculative. It has to be ‘real income’. The subsequent amendment to Section 14A does not particularly clarify whether the disallowance of the expenditure would apply even where no exempt income is earned in the AY in question from investments made, not in that AY, but earlier AYs.
16. Rule 8D (1) of the Rules is helpful, to some extent, in understanding the above issue. It reads as under:
“8D. (1) Where the Assessing Officer, having regard to the accounts of the assessee of a previous year, is not satisfied with—
(a) the correctness of the claim of expenditure made by the assessee;
(b) the claim made by the assessee that no expenditure has been incurred, in relation to income which does not form part of the total income under the Act for such previous year, he shall determine the amount of expenditure in relation to such income in accordance with the provisions of sub-rule (2).”
17. The words “in relation to income which does not form part of the total income under the Act for such previous year” in the above Rule 8D(1) indicates a correlation between the exempt income earned in the AY and the expenditure incurred to earn it. In other words, the expenditure as claimed by the Assessee has to be in relation to the income earned in ‘such previous year’. This implies that if there is no exempt income earned in the AY in question, the question of disallowance of the expenditure incurred to earn exempt income in terms of section 14a read with rule 8d would not arise.
18. The CBDT Circular upon which extensive reliance is placed by Mr. Hossain does not refer to rule 8d(1) of the rules at all but only refers to the word “includible” occurring in the title to Rule 8D as well as the title to Section 14A. The Circular concludes that it is not necessary that exempt income should necessarily be included in a particular year's income for the disallowance to be triggered.
19. In the considered view of the Court, this will be a truncated reading of Section 14 A and Rule 8D particularly when Rule 8D(1) uses the expression ‘such previous year’. Further, it does not account for the concept of ‘real income’. It does not note that under Section 5 of the Act, the question of taxation of ‘notional income’ does not arise. As explained in Commissioner of Income Tax v. Walfort Share and Stock Brokers Pvt. Ltd. [2010] 326 ITR 1 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Consequently, the Court is not persuaded that in view of the Circular of the CBDT dated 11 May 2014, the decision of this Court in Cheminvest Ltd.(supra) requires reconsideration.
20. In Redington (India) Ltd. v. The Additional Commissioner of Income Tax, Company Range - V, Chennai (order dated 23 December, 2016 of the High Court of Madras in TCA No. 520 of 2016), a similar contention of the Revenue was negated. The Court there declined to apply the CBDT Circular by explaining that Section 14A is “clearly relatable to the earning of the actual income and not notional income or anticipated income.” It was further explained that,
“The computation of total income in terms of Rule 8D is by way of a determination involving direct as well as indirect attribution. Thus, accepting the submission of the Revenue would result in the imposition of an artificial method of computation on notional and assumed income. We believe thus would be carrying the artifice too far.”
21. The decisions in CIT v. Lakhani Marketing Inc. 2014 SCC OnLine P&H 20357, CIT v. Winsome Textile Industries Limited [2009] 319 ITR 204 (P&H), CIT v. Shivam Motors (P) Ltd. (2014) 272 CTR (All) 277 have all taken a similar view. The decision in Taikisha Engineering India Pvt. Ltd. (supra) does not specifically deal with this issue.
22. It was suggested by Mr. Hossain that, in the context of Section 57(iii), the Supreme Court in Commissioner of Income Tax, West v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC) explained that deduction is allowable even where income was not actually earned in the AY in question. This aspect of the matter was dealt with by this Court in Cheminvest Ltd. (supra) where it reversed the decision of the Special Bench of the ITAT by observing as under:
“20. Since the Special Bench has relied upon the decision of the Supreme Court in Rajendra Prasad Moody (Supra), it is considered necessary to discuss the true purport of the said decision. It is noticed to begin with that the issue before the Supreme Court in the said case was whether the expenditure under Section 57(iii) of the Act could be allowed as a deduction against dividend income assessable under the head “income from other sources”. Under Section 57(iii) of the Act deduction is allowed in respect of any expenditure laid out or expended wholly or exclusively for the purpose of making or earning such income. The Supreme Court explained that the expression “incurred for making or earning such income’, did not mean that any income should in fact have been earned as a condition precedent for claiming the expenditure. The Court explained:
“What s. 57(iii) requires is that the expenditure must be laid out or expended wholly and exclusively for the purpose of making or earning income. It is the purpose of the expenditure that is relevant in determining the applicability of s. 57(iii) and that purpose must be making or earning of income. s. 57(iii) does not require that this purpose must be fulfilled in order to qualify the expenditure for deduction. It does not say that the expenditure shall be deductible only if any income is made or earned. There is in fact nothing in the language of s. 57(iii) to suggest that the purpose for which the expenditure is made should fructify into any benefit by way of return in the shape of income. The plain natural construction of the language of s. 57(iii) irresistibly leads to the conclusion that to bring a case within the section, it is not necessary that any income should in fact have been earned as a result of the expenditure.”
21. There is merit in the contention of Mr. Vohra that the decision of the Supreme Court in Rajendra Prasad Moody (supra) was rendered in the context of allowability of deduction under Section 57(iii) of the Act, where the expression used is “for the purpose of making or earning such income.” Section 14A of the Act on the other hand contains the expression “in relation to income which does not form part of the total income.” The decision in Rajendra Prasad Moody (supra) cannot be used in the reverse to contend that even if no income has been received, the expenditure incurred can be disallowed under Section 14A of the Act.”
23. The decisions of the ITAT in ACIT v. Ratan Housing Development Ltd. (supra) and Relaxo Footwear Ltd. v. Addl. CIT (supra), to the extent that they are inconsistent with what has been held hereinbefore do not merit acceptance. Further, the mere fact that in the audit report for the AY in question, the auditors may have suggested that there should be a disallowance cannot be determinative of the legal position. That would not preclude the Assessee from taking a stand that no disallowance under Section 14 A of the Act was called for in the AY in question because no exempt income was earned.
24. For all of the aforementioned reasons, this Court is of the view that the CBDT Circular dated 11 May 2014 cannot override the expressed provisions of section 14a read with rule 8d.
25. No substantial question of law arises from the impugned order of the ITAT. The appeal is accordingly dismissed.
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