2024 (2) TMI 1436

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..... onger res integra and there are several decisions to the effect that amendment made u/s 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee during the year. The PCIT has also noted the decision of Chettinad Logistics Pvt. Ltd. [ 2018 (7) TMI 567 - SC ORDER] and Oil Industries Development Board[ 2019 (3) TM .....

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..... a Infrastructure India Ltd. [ITA/204/2022], wherein the Hon ble High Court, was pleased to clarify that the order passed in said case, shall abide by the final decision of the Hon ble Supreme Court, in the SLP filed, in the case of IL FS Energy Development Co. Ltd. [399 ITR 483], which is still pending as on date ? B. Whether on the facts and in the circumstances of the case the order of the Learn .....

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..... ed in the case is that whether disallowance under section 14A of the Act can be made even if the assessee has not earned any exempt income, the issue is no longer res integra and there are several decisions to the effect that amendment made under section 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee .....

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