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of <h1>Gauhati High Court Rules Section 14A Explanation of Income Tax Act Applies Prospectively from AY 2022-23.</h1> The article examines a Gauhati High Court ruling on whether the Explanation to Section 14A of the Income Tax Act, introduced by the Finance Act, 2022, should apply retrospectively or prospectively. The Revenue argued for retrospective application, claiming the Explanation was clarificatory, while the Assessee contended it should apply prospectively, as indicated in the Finance Bill's Memorandum. The Court concluded that the Explanation applies prospectively from the Assessment Year 2022-23, aligning with legislative intent and established tax law principles that tax laws cannot be retroactive unless explicitly stated. This decision ensures legal certainty and protects taxpayers' expectations.
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