2022 (8) TMI 1486

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....nsel with Ms.Adeeba Mujahid, Jr.Standing Counsel and Mr.Nikhil Jain, Advocate. For the Respondent : Mr.Rahul Yadav, Advocate. JUDGMENT MANMOHAN, J: (ORAL) 1. Present Income Tax Appeal has been filed challenging the Order dated 16th July, 2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No.3609/Del/2017 for the Assessment Year 2011-12. 2. Learned counsel for the Appel....

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....fact that the prior period expenses had to be debited in the profit and loss account of the relevant year. 5. A perusal of the paperbook reveals that the authorities below have given concurrent finding of fact that the assessee did not earn any exempt income during the year under consideration. Consequently, the present case is covered by the judgment of this Court in Cheminvest Ltd. vs. CIT, [....

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....aid judgment is reproduced hereinbelow: "8. Consequently, this Court is of the view that the amendment of Section 14A, which is "for removal of doubts" cannot be presumed to be retrospective even where such language is used, if it alters or changes the law as it earlier stood." 7. This Court also finds that ITAT and CIT(A) have given concurrent finding of fact on the issue relating to ....