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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.
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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