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2023 (10) TMI 513 - ITAT HYDERABADDisallowance u/s 14A r.w.r. 8D - assessee did not earn any exempt income during the year - Scope of amendment of section 14A - HELD THAT:- Respectfully following the decision of Era Infrastructure (India) Ltd. [2022 (7) TMI 1093 - DELHI HIGH COURT] we hold that the operation of explanation to provisions u/s 14A by way of Finance Act, 2022 is only prospective in nature and cannot be made applicable to the year under consideration. Since it is an undisputed fact that there is no dividend income earned in the relevant previous year, by respectfully following case of Cheminvest Ltd [2015 (9) TMI 238 - DELHI HIGH COURT] we hold that Section 14A read with Rule 8D applies only in relation to an assessee’s exempt income and not otherwise. Decided against revenue.
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