https://www.taxtmi.com/caselaws?id=759327 The Explanation inserted to Section 14A by the Finance Act, 2022 applies prospectively from assessment year 2022-23. Although described as clarificatory and intended to remove doubts, the amendment altered the earlier legal position and could not be treated as retrospective without express or necessary legislative intent. Tax liability remains governed by the law applicable to the relevant assessment year. The stated effective date of 1 April 2022 therefore prevents retrospective application, and the contrary view that the Explanation was retrospective was erroneous. en-us Tue, 24 Sep 2024 00:00:00 +0530 Sat, 01 Aug 2026 10:56:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759327 The Explanation inserted to Section 14A by the Finance Act, 2022 applies prospectively from assessment year 2022-23. Although described as clarificatory and intended to remove doubts, the amendment altered the earlier legal position and could not be treated as retrospective without express or necessary legislative intent. Tax liability remains governed by the law applicable to the relevant assessment year. The stated effective date of 1 April 2022 therefore prevents retrospective application, and the contrary view that the Explanation was retrospective was erroneous. Case-Laws Income Tax Tue, 24 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759327