Vatika Bank - Disallowance under Section 14A
Facts
Section 14A disallowance where no exempt income was earned.
Issue
Whether disallowance applies in nil-exempt-income years.
Held
No - Section 14A is contingent on existence of exempt income. Mere potential or future exempt income is insufficient.
Ratio
Section 14A requires actual exempt income; theoretical applicability does not trigger disallowance.
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