2024 (12) TMI 505

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.... : Sh. Akhilesh Kumar Yadav, Sr. DR ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2019-20 is directed against the Principal Commissioner of Income Tax (Central) [in short, the "PCIT"], Delhi's order dated 13.03.2024 passed in case no. ITBA/REV/F/REV5/2023-24/1062530408(1), involving proceedings under sections 143(3) r.w.s. 263 of the Income-tax Act, 1961 (h....

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....judice. 5. The assessee's case on the other hand is that it has not derived any exempt income in the relevant previous year so as to be exigible to the foregoing disallowance. 6. Faced with this situation, learned departmental representative quotes section 14A's Explanation inserted by the Finance Act, 2022 w.e.f. 01.04.2022 that whether any actual exempt income is derived or not in the rele....