Executive Summary

This Article, authored by our Founder Director Sh. Mayank Mohanka, captures the entire journey and life-cycle of Section 14A and Rule 8D, the Legislative Intent of its introduction, and how that is being disregarded, the practical hardships being faced by the assessees, all significant legal precedents on section 14A and Rule 8D, the recent amendment brought in Section 14A by the Finance Act, 2022, its applicability i.e., prospective or retrospective, in the light of real-life assessment scenarios.

The equituous and meritorious objective, purpose and the legislative intent of bringing in the expenditure disallowance section 14A, in respect of exempt income, has somehow, been turned down into an unfettered, u.