https://www.taxtmi.com/caselaws?id=468852 No disallowance under section 14A read with Rule 8D is sustainable where no exempt income was earned during the relevant previous year, and the Explanation inserted by the Finance Act, 2022 to section 14A operates prospectively, not retrospectively. Applying the binding jurisdictional High Court rulings, the ITAT held that the section 14A adjustment could not be maintained on these facts and deleted the disallowance in favour of the assessee. en-us Wed, 11 Mar 2026 00:00:00 +0530 Fri, 22 May 2026 19:11:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468852 No disallowance under section 14A read with Rule 8D is sustainable where no exempt income was earned during the relevant previous year, and the Explanation inserted by the Finance Act, 2022 to section 14A operates prospectively, not retrospectively. Applying the binding jurisdictional High Court rulings, the ITAT held that the section 14A adjustment could not be maintained on these facts and deleted the disallowance in favour of the assessee. Case-Laws Income Tax Wed, 11 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468852