Court held that I n view of the Memorandum Explaining the Provisions in the Finance Bill, 2022 and various decisions rendered by the different High Courts, it is clear that the Explanation inserted to s. 14A vide Finance Act, 2022 is applicable prospectively. Order passed by the Tribunal holding that insertion of Explanation to s. 14A is clarificatory and thereby retrospective in nature, is erroneous in law.  Tribunal having held in one case that decision of Delhi High Court is binding on it, same Bench of the Tribunal was not justified in holding that the judgment of Delhi High Court is not binding upon it-Said conduct of the members of the Tribunal is liable to be condemned. (AY.2009-10,  2012-13 to 2014-15)