PCIT v. Era Infrastructure (India) Ltd.

141 Taxmann.com 289High Court2022#215 most cited

What is PCIT v. Era Infrastructure (India) Ltd. authority for?

Disallowance under Section 14A is not attracted when no exempt income is earned in the relevant assessment year. The amendment to Section 14A by the Finance Act, 2022, applies prospectively.

354

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2022 to 2026.

Also referred to as

PCIT v. Era Infrastructure (India) Ltd. · Section 14A · Disallowance under Section 14A · No exempt income · Expenditure for exempt income · Finance Act 2022 amendment · Prospective application of Section 14A amendment · Rule 8D · 448 ITR 674 · Delhi High Court 2022 · Disallowance in absence of exempt income

Issues it is cited on

Judgments citing PCIT v. Era Infrastructure (India) Ltd.

Chhattisgarh Gramin Bank, Raipur vs. Deputy Commissioner of Income Tax, Circle-1(1), Raipur

In the result, the appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 170/RPR/2023[2012-13]Status: DisposedITAT Raipur20 Oct 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 170/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Chhattisgarh Gramin Bank C/O. Chhattisgarh Rajya Gramin Bank, Corporate Office, Sector-24, Plot No.47, Atal Nagar, Naya Raipur Raipur (C.G.)-492 018 Pan : Aaajc0574H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur ……""यथ" / Respondent

For Appellant: Shri B. Subramanyam, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(2)Section 143(3)Section 14A

…me being prospective would not be applicable to the case of the assessee company before us for A.Y.2012-13. 11. Our aforesaid view is fortified by the judgment of the Hon’ble High Court of Delhi in the case of Pr. CIT v. Era Infrastructure (India) Ltd. (2022) 448 ITR 674 (Delhi). The Hon’ble High Court, after deliberating at length on the issue under consideration, i.e., as to whether or not the “Explanation” to Section 14A of the Act was retrospective, had held that the same was effective from 1st April 2022 and will apply in relation to A.Y.2022-23 and subsequent assessment years. Albeit, the Hon’ble High Court…