Lakozy Motors P. Ltd. v. Dy. CIT (2024)110 ITR 19 (SN) (Mum)(Trib) Xchanging Technology Services India P. Ltd. v.ACIT (2024)110 ITR 52 (SN)(Delhi)(Trib)

S.14A : Disallowance of expenditure-Exempt income-No dividend income earned from investments-No disallowance can be made-The amendment by the Finance Act, 2022 is prospective in nature. [R.8D]

Held that the amendment by the Finance Act, 2022, by which a non obstante clause and Explanation were inserted in section 14A of the Act to the effect that the section shall apply even if no exempt income has accrued or arisen or has been received during the year, was prospective and will apply in relation to the assessment year 2022-23 and subsequent assessment years. When  no dividend income is earned  from investments, no disallowance can be made.(AY.2013-14)

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