With effect from April 1, 2022 the Finance Act, 2022 had introduced an Explanation, which made it clear that the provisions of section 14A with respect to the disallowance shall apply and shall be deemed to have always been applied even in cases where the assessee has not earned any exempt income. Therefore, in view of the amendment the Tribunal remanded the matter to the Assessing Officer (AY. 2007-08, 2010-11 to 2014-15).