https://www.taxtmi.com/caselaws?id=796402 Section 14A disallowance cannot be made where no exempt income was earned during the relevant year; the Finance Act, 2022 amendment applies prospectively from 1 April 2022 and does not alter that position for earlier years. Independently, where interest-free own funds exceed investments in wholly owned subsidiaries, the investments are presumed to be funded from own funds, so proportionate interest expenditure cannot be disallowed. On both grounds, the section 14A disallowance was deleted in full. en-us Wed, 29 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796402 Section 14A disallowance cannot be made where no exempt income was earned during the relevant year; the Finance Act, 2022 amendment applies prospectively from 1 April 2022 and does not alter that position for earlier years. Independently, where interest-free own funds exceed investments in wholly owned subsidiaries, the investments are presumed to be funded from own funds, so proportionate interest expenditure cannot be disallowed. On both grounds, the section 14A disallowance was deleted in full. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796402