https://www.taxtmi.com/caselaws?id=758288 ITAT Ahmedabad quashed PCIT's revision order u/s 263 regarding disallowance u/s 14A. The tribunal held that when no exempt income is earned, no disallowance u/s 14A can be made, following SC precedent in Chettinad Logistics. AO had properly examined the issue during original assessment by issuing notice u/s 142(1) and considering assessee's response before passing order u/s 143(3) r.w.s. 144B. Twin conditions for invoking Section 263 were not satisfied as AO had made adequate inquiries and followed established judicial interpretation. PCIT's different view alone does not render the order erroneous. Finance Act 2022 amendments to Section 14A cannot be applied retrospectively. Appeal allowed. en-us Mon, 09 Sep 2024 00:00:00 +0530 Wed, 11 Sep 2024 09:08:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758288 ITAT Ahmedabad quashed PCIT's revision order u/s 263 regarding disallowance u/s 14A. The tribunal held that when no exempt income is earned, no disallowance u/s 14A can be made, following SC precedent in Chettinad Logistics. AO had properly examined the issue during original assessment by issuing notice u/s 142(1) and considering assessee's response before passing order u/s 143(3) r.w.s. 144B. Twin conditions for invoking Section 263 were not satisfied as AO had made adequate inquiries and followed established judicial interpretation. PCIT's different view alone does not render the order erroneous. Finance Act 2022 amendments to Section 14A cannot be applied retrospectively. Appeal allowed. Case-Laws Income Tax Mon, 09 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758288