https://www.taxtmi.com/caselaws?id=464832 ITAT PUNE - AT held that the assessee was not obliged to charge guarantee commission because an independent bank expressly prohibited the guarantor from receiving any commission; the addition was deleted. The bench further held the Finance Act 2022 amendment is prospective and not applicable to AY 2020-21, and affirmed that disallowance under s.14A cannot exceed exempt income for the year. The AO was directed to restrict s.14A disallowance to the exempt income of Rs. 4,50,000 and delete the balance disallowance. en-us Thu, 10 Jul 2025 00:00:00 +0530 Mon, 17 Nov 2025 20:07:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464832 ITAT PUNE - AT held that the assessee was not obliged to charge guarantee commission because an independent bank expressly prohibited the guarantor from receiving any commission; the addition was deleted. The bench further held the Finance Act 2022 amendment is prospective and not applicable to AY 2020-21, and affirmed that disallowance under s.14A cannot exceed exempt income for the year. The AO was directed to restrict s.14A disallowance to the exempt income of Rs. 4,50,000 and delete the balance disallowance. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464832