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    <title>2025 (12) TMI 482 - ITAT CHENNAI</title>
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    <description>Disallowance under Section 14A read with Rule 8D was held unsustainable where the assessee had earned no exempt income during the relevant year. The binding precedent applied was that Section 14A disallowance cannot be made in the absence of exempt income. The Explanation inserted with effect from 01.04.2022 was treated as prospective and therefore did not apply to the assessment year in question. The disallowance was deleted in favour of the assessee.</description>
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      <description>Disallowance under Section 14A read with Rule 8D was held unsustainable where the assessee had earned no exempt income during the relevant year. The binding precedent applied was that Section 14A disallowance cannot be made in the absence of exempt income. The Explanation inserted with effect from 01.04.2022 was treated as prospective and therefore did not apply to the assessment year in question. The disallowance was deleted in favour of the assessee.</description>
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