Held that the disallowance under section 14A cannot exceed exempt income and the amendment made to provisions of section 14A vide Finance Act, 2022 is prospective in nature and cannot be applied for earlier years. (AY. 2017-18)
G.N. International (P.) Ltd. v. ACIT (2025) 214 ITD 180 (Delhi) (Trib.)
S.14A: Disallowance of expenditure-Exempt income-Disallowance cannot exceed exempt income-Amendment made to provisions of section 14A vide Finance Act, 2022 is prospective in nature and cannot be applied for earlier years.[R.8D]
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