https://www.taxtmi.com/caselaws?id=775508 The ITAT Hyderabad set aside the disallowance under pre-amended Section 14A, directing the AO to verify whether the assessee received exempt income during the year; if not, the disallowance must be deleted. The tribunal held that the 2022 amendment to Section 14A is prospective, not retrospective. Regarding Section 56(2)(viia), the allotment of shares was held to be creation, not receipt or transfer, thus not attracting the provision. The AO's disallowance under this section was partly set aside. On interest under Sections 234B and 234C, the tribunal referred to Supreme Court precedent, rejecting the assessee's claim but directed redetermination of interest liability consistent with the appellate findings. Grounds of appeal were allowed partly or for statistical purposes accordingly. en-us Thu, 03 Jul 2025 00:00:00 +0530 Sat, 26 Jul 2025 08:39:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775508 The ITAT Hyderabad set aside the disallowance under pre-amended Section 14A, directing the AO to verify whether the assessee received exempt income during the year; if not, the disallowance must be deleted. The tribunal held that the 2022 amendment to Section 14A is prospective, not retrospective. Regarding Section 56(2)(viia), the allotment of shares was held to be creation, not receipt or transfer, thus not attracting the provision. The AO's disallowance under this section was partly set aside. On interest under Sections 234B and 234C, the tribunal referred to Supreme Court precedent, rejecting the assessee's claim but directed redetermination of interest liability consistent with the appellate findings. Grounds of appeal were allowed partly or for statistical purposes accordingly. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775508