Dismissing the appeal of the Revenue the Court held that amendment brought in section 14A of the Act, inserted by Finance Act, 2022  vide explanation is  clarificatory in nature has prospective effect. The said amendment  clarified and brought the exempt income, even when not earned during the year, under the ambit of section 14A effective from 1-4 2022. Accordingly the amendment will apply in relation to AY. 2022-23 and subsequent assessment years. (AY. 2013-14)