https://www.taxtmi.com/caselaws?id=460551 ITAT Delhi allowed the assessee's appeal against PCIT's revision order u/s 263. The assessee had invested in equity shares but didn't deduct expenses related to exempt income, and AO didn't disallow such expenses u/s 14A. ITAT held that PCIT's order was arbitrary as AO had already examined the issue during assessment proceedings. The tribunal relied on Era Infrastructure case, noting that Finance Act 2022 amendments to Section 14A take effect from 01.04.2022 without retrospective application. Since AO had discharged statutory duty by making proper inquiry, PCIT's revision branding the assessment as erroneous was unsustainable. en-us Wed, 14 Aug 2024 00:00:00 +0530 Fri, 31 Jan 2025 13:30:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460551 ITAT Delhi allowed the assessee's appeal against PCIT's revision order u/s 263. The assessee had invested in equity shares but didn't deduct expenses related to exempt income, and AO didn't disallow such expenses u/s 14A. ITAT held that PCIT's order was arbitrary as AO had already examined the issue during assessment proceedings. The tribunal relied on Era Infrastructure case, noting that Finance Act 2022 amendments to Section 14A take effect from 01.04.2022 without retrospective application. Since AO had discharged statutory duty by making proper inquiry, PCIT's revision branding the assessment as erroneous was unsustainable. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460551