Prospective 2022 Amendment Saves Assessee – 14A Knocked Out No Exempt Income, No 14A

DCIT Vs HDB Financial Services Limited (ITAT Ahmedabad)

Revenue appealed against CIT(A)’s deletion of disallowance of ₹17,93,76,718 u/s 14A r.w. Rule 8D(2)(ii). AO had applied 1% of annual average investments towards administrative expenses, holding that Assessee had substantial investments yielding exempt income. CIT(A) deleted the disallowance on the ground that no exempt income was earned during the year.

Before Tribunal, Revenue argued that Rule 8D was correctly invoked. Assessee submitted that the issue was already

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