https://www.taxtmi.com/caselaws?id=446042 The ITAT Ahmedabad allowed the assessee's appeal against revision u/s 263. The CIT sought to revise the assessment for non-disallowance u/s 14A when the assessee had investments in shares and securities capable of generating exempted income u/s 10(34), despite no actual exempted income being earned. The tribunal held that both conditions for revision u/s 263 must be satisfied - the order must be erroneous and prejudicial to revenue interests. Since no exempted income was earned, no disallowance u/s 14A r.w. Rule 8D was required, following established SC precedent. The amendment requiring disallowance even without exempted income was not applicable for the assessment year in question. en-us Fri, 20 Oct 2023 00:00:00 +0530 Fri, 24 Nov 2023 07:42:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446042 The ITAT Ahmedabad allowed the assessee's appeal against revision u/s 263. The CIT sought to revise the assessment for non-disallowance u/s 14A when the assessee had investments in shares and securities capable of generating exempted income u/s 10(34), despite no actual exempted income being earned. The tribunal held that both conditions for revision u/s 263 must be satisfied - the order must be erroneous and prejudicial to revenue interests. Since no exempted income was earned, no disallowance u/s 14A r.w. Rule 8D was required, following established SC precedent. The amendment requiring disallowance even without exempted income was not applicable for the assessment year in question. Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446042