Section 14A Disallowance Allowed from AY 2022-23; GST Input Credit Deductible Based on Cost Inclusion. Limited Remand Ordered.

No exempt income earned, hence no disallowance u/s 14A permissible up to AY 2021-22; however, from AY 2022-23 onwards, disallowance relating to exempt income allowable even if no exempt income earned due to inserted Explanation. GST input credit allowable as deduction if not embedded in cost of goods/services; else revenue neutral. AO directed to allow GST deduction after verifying not claimed in P&L with corresponding cost entries, subject to Wipro and Shri Ram Investments decisions of SC. Assessee's appeal allowed for limited remand to AO on GST issue. .....

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