https://www.taxtmi.com/caselaws?id=760051 The ITAT Chennai ruled on disallowance under Section 14A regarding investments yielding exempt income. The tribunal held that the newly inserted explanation to Section 14A cannot be applied retrospectively despite "deemed to have always applied" language, following Era Infrastructure India Ltd precedent. The AO was directed to verify and adopt correct cost of investments from assessee's books, considering only investments that actually yielded exempt income during the year, not net worth of demerged entities. Revenue's grounds were dismissed while assessee's appeal was partially allowed regarding correct adoption of investment costs. Additionally, the AO was directed to consider TDS credit of Rs. 16.35 lacs upon proper substantiation by the assessee. en-us Wed, 09 Oct 2024 00:00:00 +0530 Tue, 15 Oct 2024 08:39:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760051 The ITAT Chennai ruled on disallowance under Section 14A regarding investments yielding exempt income. The tribunal held that the newly inserted explanation to Section 14A cannot be applied retrospectively despite "deemed to have always applied" language, following Era Infrastructure India Ltd precedent. The AO was directed to verify and adopt correct cost of investments from assessee's books, considering only investments that actually yielded exempt income during the year, not net worth of demerged entities. Revenue's grounds were dismissed while assessee's appeal was partially allowed regarding correct adoption of investment costs. Additionally, the AO was directed to consider TDS credit of Rs. 16.35 lacs upon proper substantiation by the assessee. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760051