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2022 (11) TMI 422 - AT - Income TaxDisallowance u/s. 14A r.w.r 8D - assessee has made investment in shares and claimed expenditure on account of interest payment on loans - Book Profit u/s. 115JB estimation - HELD THAT:- Explanation to Section 14A by the Finance Act, 2022 is operative only from the Assessment Year 2022-23 onwards and not applicable for the earlier Assessment Years and therefore the argument of the Ld. D.R. is hereby rejected. The decision relied by Ld. A.R. in assessee’s own case in [2022 (6) TMI 1325 - ITAT AHMEDABAD] for the Assessment Year 2014-15 is clearly distinguishable, wherein dividend income has been earned by the assessee during the financial year and the disallowance is restricted to that amount. Therefore the decision is not applicable to the present case, since there is no dividend income earned during this financial year. We have no hesitation in confirming the order passed by the CIT(A) and deleting the addition made u/s. 14A of the Act both on normal computation as well as in the book profits u/s. 115JB of the Act. Thus the Grounds raised by the Revenue has no merits and the same are dismissed. Appeal filed by the Revenue is dismissed.
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