2024 (11) TMI 1317

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....sed the following grounds of appeal: 1. That on the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre ['Ld. CIT(A)'] was not justified in confirming addition of a sum of INR 215,773 under section 14A of the Income-tax Act, 1961 ('the Act') read with Rule 8D(2)(ii) of the Income-tax Rules, 1962 ('the Rules') without appreciating the fact that during the year, the Appellant has neither earned any exempt income nor incurred any expenditure in relation to earning any exempt income. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not justified in not appreciating the fact that t....

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....sment order. 5. The ld. CIT(A) vide order dated 28.06.2024, partly upheld the order of the ld. A.O. and confirmed the disallowance made u/s. 14A of the Act. 6. The assessee is in appeal before us, challenging the impugned order of the ld. CIT(A). 7. The learned Authorised Representative ('ld. AR' for short) for the assessee contended that the assessee has not earned any exempt income and has also not incurred any expenditure as there was no such exempt income for the year under consideration. The ld. AR further contended that the amendment to Section 14A of the Act introduced by Finance Act, 2022 is prospective in nature and the same is applicable only to the subsequent years. The ld. AR relied on the following decisions in....