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2022 (7) TMI 1450 - AT - Income TaxAddition u/s 14A - disallowing expenses i.e., interest expenses u/r 8D(2)(ii) and administrative expenses being 0.5% of average value of investment u/r 8D(2)(iii) - assessee stated that the assessee has not earned any exempt income and has not claimed any income in its computation of income - HELD THAT:- As going through the decision of Era Infrastructure (India) Ltd. [2022 (7) TMI 1093 - DELHI HIGH COURT] we are of the view that the explanation inserted in the provisions of section 14A of the Act by the Finance Act, 2022 is prospective and not retrospective. Accordingly, since the assessee has not earned any exempt income, no disallowance can be resorted by invoking the provisions of section 14A of the Act read with Rule 8D(2) of the Rules. The appeal of the assessee is allowed.
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