https://www.taxtmi.com/caselaws?id=759327 The Explanation inserted into Section 14A by the Finance Act, 2022 is held to operate prospectively because the legislative Memorandum to the Finance Bill, 2022 evidences an intent against retrospective operation; consequently, characterising the Explanation as merely clarificatory and applying it retrospectively is incorrect. Prior tribunal findings treating the insertion as clarificatory and retrospective are therefore legally unsound, and reliance on earlier decisions that concluded retrospective effect does not override the legislative intent expressed in the Memorandum, resulting in prospective application of the amendment. en-us Tue, 24 Sep 2024 00:00:00 +0530 Wed, 14 Jan 2026 18:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759327 The Explanation inserted into Section 14A by the Finance Act, 2022 is held to operate prospectively because the legislative Memorandum to the Finance Bill, 2022 evidences an intent against retrospective operation; consequently, characterising the Explanation as merely clarificatory and applying it retrospectively is incorrect. Prior tribunal findings treating the insertion as clarificatory and retrospective are therefore legally unsound, and reliance on earlier decisions that concluded retrospective effect does not override the legislative intent expressed in the Memorandum, resulting in prospective application of the amendment. Case-Laws Income Tax Tue, 24 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759327