The Tribunal held that while computing disallowance under section 14A read with rule 8D, only investments which actually yielded exempt income during the relevant year could be considered. The amendment made by the Finance Act, 2022 was not retrospective. Consequently, deletion of the additional disallowance under both the normal provisions and section 115JB was upheld. (AY. 2018-19).
Geecee Ventures Ltd. v. Dy. CIT (2025) 127 ITR 371 / 174 taxmann.com 1285 (Mum.)(Trib.)
S.14A: Disallowance of expenditure-Exempt income-Only investments yielding exempt income to be considered-Amendment by Finance Act, 2022 prospective. [R. 8D]
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