The assessee did not earn any exempt income during the relevant assessment years. The Tribunal held that no disallowance under section 14A read with rule 8D could be made in the absence of exempt income and further held that the amendment made by the Finance Act, 2022 was prospective in operation. (AY. 2015-16 & 2016-17).
Dy. CIT v. Piramal Estates (P.) Ltd. (2025) 123 ITR 488 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-No exempt income earned-No disallowance permissible. [R. 8D]
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