ITAT says on Section 14A No Exempt Income, No Disallowance

Blacksoil Capital Private Limited challenged a Section 14A disallowance sustained despite the absence of exempt income. The ITAT held that the 2022 amendment could not retrospectively alter the legal position for AY 2017–18 and, following judicial precedents, directed deletion of the entire disallowance. The appeal was allowed, subject to the condition imposed for condoning the filing delay.