No Retrospective Application of 2022 Amendment to Section 14A

PCIT Vs Alchemist Ltd. (Delhi High Court)

Conclusion: Assessee claimed that in section 14A, the disallowance of expenditure even if computed in accordance with Rule 8D could not exceed the exempt income earned in that year. Amendment by inserting Explanation to section 14A would take effect from 1st April, 2022 and accordingly would apply in relation to the assessment year 2022-23 and subsequent assessment years. Therefore, the appeal of Revenue was dismissed for retrospective application of amendment to the relevant assessment year.

Held: 

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