PCIT v. Delhi International Airport (P.) Ltd. (2023) 291 Taxman 490 (Delhi)(HC)

S. 14A : Disallowance of expenditure-Exempt income-No exempt income was received or receivable during relevant previous year-Disallowance cannot be made-Amendment to section 14A is prospective.[R.8D]

Held that where the assessee had no dividend income, then no disallowance can be made under section 14A for AY 2010-2011 in the absence of such income. The amendment by the Finance Act, 2022 is only prospective and has no application to the Assessment year in question.  (AY. 2010-11)