9911796707
TMI Blog2024 (8) TMI 550X X X X Extracts X X X X X X X X Extracts X X X X ..... under consideration. Accordingly, CIT(A) has deleted the disallowance, by following the decisions M/S. NIRVED TRADERS PVT. LTD. [ 2019 (4) TMI 1738 - BOMBAY HIGH COURT] AND M/S. CHETTINAD LOGISTICS PVT. LTD. [ 2017 (4) TMI 298 - MADRAS HIGH COURT] Even though the amendment has been made in section 14A of the Act w.e.f. 01-04-2022 making it mandatory to make disallowance u/s. 14A of the Act even if ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ). 2. We heard the parties and perused the record. The AO noticed that the assessee has made investments, but did not make any disallowance u/s. 14A of the Act. The case of the assessee was that it did not earn any exempt income and hence, no disallowance u/s. 14A of the Act is called for. The said contention was rejected by the AO. Accordingly, he worked out the disallowance u/s. 14A r.w. Rule 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s. 14A of the Act mandatory, even if no exempt income is earned. The Ld.CIT(A) held that the said amendment is prospective in nature and in this regard, he relied upon the decision rendered by the Hon ble Delhi High Court in the case of Era Infrastructure (India) Ltd., (2022) 141 taxmann.com 289 (Delhi). Accordingly, Ld.CIT(A) deleted the disallowance made by the AO u/s. 14A of the Act. 4. We he ..... X X X X Extracts X X X X X X X X Extracts X X X X
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