https://www.taxtmi.com/caselaws?id=772584 The ITAT Delhi dismissed the Revenue's appeal on two grounds. First, regarding Section 14A disallowance for expenditure on exempt income, the tribunal held that disallowance applies only when exempt income is actually declared by the assessee, citing SC and HC precedents. The tribunal noted that the 2022 Finance Act amendment requiring actual exempt income as a precondition has only prospective effect. Second, concerning interest disallowance under Section 36(1)(iii), the tribunal upheld CIT(A)'s finding that the assessee had sufficient interest-free funds and commercial expediency existed for interest-free loans to subsidiaries, rejecting Revenue's contentions. en-us Tue, 31 Dec 2024 00:00:00 +0530 Tue, 10 Jun 2025 12:50:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772584 The ITAT Delhi dismissed the Revenue's appeal on two grounds. First, regarding Section 14A disallowance for expenditure on exempt income, the tribunal held that disallowance applies only when exempt income is actually declared by the assessee, citing SC and HC precedents. The tribunal noted that the 2022 Finance Act amendment requiring actual exempt income as a precondition has only prospective effect. Second, concerning interest disallowance under Section 36(1)(iii), the tribunal upheld CIT(A)'s finding that the assessee had sufficient interest-free funds and commercial expediency existed for interest-free loans to subsidiaries, rejecting Revenue's contentions. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772584