https://www.taxtmi.com/caselaws?id=424896 ITAT GAUHATI - AT allowed the Revenue appeal, holding the Finance Act 2022 explanation to section 14A is clarificatory and operates retrospectively. The Tribunal found expenses are allowable only to the extent they relate to taxable income; apportionment is required where expenses serve exempt income, and disallowance under s.14A may be made even if no exempt income was actually earned. The CIT(A)'s reliance that disallowance cannot exceed exempt income was set aside, the AO's Rule 8D computation was restored, and the taxpayer's suo motu, unsubstantiated methodology for disallowance was rejected. en-us Wed, 06 Jul 2022 00:00:00 +0530 Wed, 08 Oct 2025 11:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424896 ITAT GAUHATI - AT allowed the Revenue appeal, holding the Finance Act 2022 explanation to section 14A is clarificatory and operates retrospectively. The Tribunal found expenses are allowable only to the extent they relate to taxable income; apportionment is required where expenses serve exempt income, and disallowance under s.14A may be made even if no exempt income was actually earned. The CIT(A)'s reliance that disallowance cannot exceed exempt income was set aside, the AO's Rule 8D computation was restored, and the taxpayer's suo motu, unsubstantiated methodology for disallowance was rejected. Case-Laws Income Tax Wed, 06 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424896