Explanation to section 14A inserted vide Finance Act, 2022 is prospective in nature

JCIT Vs Gateway Distriparks Ltd (ITAT Mumbai) ITAT Mumbai held that the Explanation to section 14A of the Income Tax Act inserted by the Finance Act, 2022 is prospective in nature and cannot be applied to assessment years preceding the amendment. Accordingly, appeal of revenue dismissed. Facts- The case was selected for scrutiny, and assessment was completed u/s. 143(3) of the Act. During the course of assessment proceedings, AO observed that the assessee had earned dividend income amounting to Rs.18,36,27,060/-. The total investment in shares during the relevant assessment year stood at Rs.50...