Radison Projects Pvt. Ltd v ITO (2023) 103 ITR 17 (SN)(Kol) (Trib)

S. 14A : Disallowance of expenditure-Exempt income-Disallowance cannot exceed exempt income-Amendment introduced by Finance Act, 2022, is prospective.[R.8D]

Held that the disallowance under section 14A cannot exceed exempt income earned by noting that amendment introduced by the Finance Act, 2022, is prospective. Accordingly, no disallowance can be made in absence of exempt income earned.(AY. 2012-13)