Held, that since during the year, no dividend income was received from the investments made by the assessee and thus, no exemption was claimed under section 10(34) of the Act while filing the return of income, disallowance of expenditure under section 14A read with rule 8D was not sustainable. The amendment by the Finance Act, 2022 , in section 14A was prospective and would apply in relation to the assessment year 2022-23 and subsequent assessment years.(AY.2012-13 to 2015-16)