Muthoot Vehicle and Asset Finance Ltd. v. ACIT (2022)100 ITR 185 (Cochin)(Trib)

S. 14A : Disallowance of expenditure-Exempt income-No exempt income received during the year-Disallowance cannot be made-Amendment is from AY. 2022-23, prospective in nature.[R.8D]

Held, that the assessee was not in receipt of any exempt income on the investments made by it. The Finance Act, 2022 had amended section 14A wherein it was stated that irrespective of whether the assessee is not in receipt of exempt income, disallowance under section 14A can be made. However, the amendment was prospective and applied for and from the assessment year 2022-23 onwards. Therefore, no disallowance under section 14A was called for. (AY.2013-14)