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TMI Blog2024 (8) TMI 550X X X X Extracts X X X X X X X X Extracts X X X X ..... osh, CIT-DR ORDER PER B.R. BASKARAN, A.M : The Revenue has filed this appeal challenging the order passed by the learned Commissioner of Income Tax (Appeals)-NFAC, Delhi (in short "Ld.CIT(A)") and it relates to AY. 2020-21. The only issue urged by the Revenue in this appeal relates to the relief granted by the Ld.CIT(A) in respect of addition made by the AO u/s. 14A of the Income Tax Act, 1961 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Hon'ble Madras High Court in the case of Chettinad Logistics (P) Ltd., 80 taxmann.com 221 (Madras)/95 taxmann.com 250 (SC), wherein it was held that the disallowance u/s. 14A of the Act is not required to be made when the assessee has not earned any exempt income. The Ld CIT(A) noticed that an amendment has been brought by the Statute in Section 14A of the Act w.e.f. 01-04-2022, making the di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 14A of the Act w.e.f. 01-04-2022 making it mandatory to make disallowance u/s. 14A of the Act even if the exempt income is not earned, the same has been held to be prospective in nature as per the decision of the Hon'ble Delhi High Court in the case of Era Infrastructure (India) Ltd., (supra). In view of the above, we do not find any infirmity in the order passed by the Ld.CIT(A) and accor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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