2022 (11) TMI 882 - AT - Income Tax
Disallowance u/s 14A read with rule 8D - HELD THAT:- We find that during the year the assessee has not earned any exempt income. As it is held in Era Infrastructure India Limited [2022 (7) TMI 1093 - DELHI HIGH COURT] that there cannot be disallowance in the hands of the assessee as the amendment made by the Finance Act, 2022 to section 14A by inserting a non obstante clause and explanation will take effect from 01.04.2022 and cannot be presumed to have retrospective effect. Therefore, in A.Y. 2014-15 no disallowance could be made under section 14A if no exempt income was earned by the assessee. Appeal of assessee allowed.