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    <title>2026 (5) TMI 1393 - ITAT DELHI</title>
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    <description>No disallowance under section 14A read with Rule 8D was sustainable where the assessee earned no exempt income during the relevant year. The Explanation to section 14A was treated as prospective and could not be applied retrospectively to enlarge the disallowance for that assessment year. The Revenue&#039;s cited authorities were found distinguishable on facts, and the view taken in identical matters was followed for consistency. The deletion of the disallowance by the appellate authority was therefore upheld.</description>
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    <pubDate>Wed, 22 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=792191</link>
      <description>No disallowance under section 14A read with Rule 8D was sustainable where the assessee earned no exempt income during the relevant year. The Explanation to section 14A was treated as prospective and could not be applied retrospectively to enlarge the disallowance for that assessment year. The Revenue&#039;s cited authorities were found distinguishable on facts, and the view taken in identical matters was followed for consistency. The deletion of the disallowance by the appellate authority was therefore upheld.</description>
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      <pubDate>Wed, 22 Apr 2026 00:00:00 +0530</pubDate>
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