Investments on which no dividend income is earned should be excluded for calculation of disallowance u/s 14A-Living Media India Ltd [2015] 61 taxmann.com 206 (Delhi - Trib.)

Battery of Cases u/s 14A relied upon by assessee:
Delhi High Court in the case of CIT v. Holcim India (P.) Ltd. [2015] 57 taxmann.com 28 and

Para 63 of Karanatka High Court in Manju Nath Cotton & Ginning factory 359 ITR 565 on Penalty followed by Banglore Tribunal in H.LakshmiNarayan [2015] 61 taxmann.com 373 (Bangalore - Trib.)

63. In the light of what is stated above, what emerges is as under :

(a)		Penalty under section 271(1)(c) is a civil liability.
(b)		Mens rea is not an essential element for imposing penalty for breach of civil obligations or liabilities.
(c)		Willful concealment is not an essential ingredient for attracting civil liability.