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    <title>2023 (12) TMI 641 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that disallowance under Section 14A read with Rule 8D cannot exceed exempt income earned by the assessee. For AY 2016-17, interest disallowance of Rs.21,92,534 was deleted as assessee had sufficient interest-free funds (Rs.81 crores) exceeding mutual fund investments (Rs.15.60 crores). Administrative expenditure disallowance was restricted to exempt income of Rs.53,873. For AY 2017-18, AO was directed to recompute disallowance considering only investments yielding exempt income, ensuring total disallowance doesn&#039;t exceed exempt income earned. Finance Act 2022 amendments to Section 14A held prospective from April 1, 2022, following Delhi HC precedent. Appeals allowed with directions for recomputation.</description>
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      <title>2023 (12) TMI 641 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=446957</link>
      <description>ITAT Mumbai held that disallowance under Section 14A read with Rule 8D cannot exceed exempt income earned by the assessee. For AY 2016-17, interest disallowance of Rs.21,92,534 was deleted as assessee had sufficient interest-free funds (Rs.81 crores) exceeding mutual fund investments (Rs.15.60 crores). Administrative expenditure disallowance was restricted to exempt income of Rs.53,873. For AY 2017-18, AO was directed to recompute disallowance considering only investments yielding exempt income, ensuring total disallowance doesn&#039;t exceed exempt income earned. Finance Act 2022 amendments to Section 14A held prospective from April 1, 2022, following Delhi HC precedent. Appeals allowed with directions for recomputation.</description>
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