https://www.taxtmi.com/caselaws?id=444839 ITAT Delhi dismissed revenue's appeal regarding Section 14A disallowance, following Delhi HC precedent in Era Infrastructure that Finance Act 2022 amendment is prospective, not retrospective, and no disallowance applies without exempt income. Tribunal upheld CIT(A)'s decision allowing deferred revenue expenditure deduction, ruling entire upfront loan fee allowable in incurrence year regardless of accounting treatment. For TDS under Section 195, Tribunal deleted disallowance following Welspring Universal precedent, holding commission paid to foreign agent for services rendered outside India not chargeable to tax in India under Sections 5(2) or 9(1). en-us Fri, 20 Oct 2023 00:00:00 +0530 Mon, 23 Oct 2023 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444839 ITAT Delhi dismissed revenue's appeal regarding Section 14A disallowance, following Delhi HC precedent in Era Infrastructure that Finance Act 2022 amendment is prospective, not retrospective, and no disallowance applies without exempt income. Tribunal upheld CIT(A)'s decision allowing deferred revenue expenditure deduction, ruling entire upfront loan fee allowable in incurrence year regardless of accounting treatment. For TDS under Section 195, Tribunal deleted disallowance following Welspring Universal precedent, holding commission paid to foreign agent for services rendered outside India not chargeable to tax in India under Sections 5(2) or 9(1). Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444839