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TMI Blog2022 (12) TMI 651X X X X Extracts X X X X X X X X Extracts X X X X ..... DELHI HIGH COURT] which has ruled on the amendment which was brought about in Section 14A of the Act via Finance Act 2022. The coordinate bench has ruled that the amendment will not operate retrospectively. It appears that the coordinate bench in judgment has referred to judgments passed by other coordinate benches rendered in PCIT v. IL FS Energy Development Company Ltd. [ 2017 (8) TMI 7 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Physical Hearing/Hybrid Hearing (as per request)] RAJIV SHAKDHER, J. (ORAL): CM No.52418/2022 [Application filed on behalf of the appellant seeking condonation of delay of 80 days in re-filing the appeal] 1. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in re-filing the instant appeal. 1.1 According to the appellant/revenue, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isallowance could be effected under Section 14A of the Income Tax Act, 1961 [in short, Act ] if the respondent/assessee had not earned income which was exempt from imposition of tax. 7.1. The Tribunal has taken a view in favour of the respondent/assessee. 8. Mr Ajit Sharma, who appears on behalf of the appellant/revenue, has fairly placed before us a judgment dated 20.07.2022, rendered by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IL FS Energy Development Company Ltd. has been assailed by the appellant/revenue by instituting a special leave petition (SLP), which is pending adjudication. 9. Given these circumstances, since no substantial question of law arises in the present case, at this juncture, the appeal is, accordingly, disposed of. 9.1. Needless to state, if the appellant/revenue were to succeed in the SLP r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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