Consistency Rule Ignored, but Cap on 14A Disallowance Reaffirmed by ITAT Mumbai

Motilal Oswal Financial Services Limited Vs DCIT (ITAT Mumbai)

Assessee,Motilal Oswal Financial Services Ltd. (successor of Mope Investment Advisors Pvt. Ltd.),filed return for AY 2016-17 declaring income of ₹10.27 crore. AO completed scrutiny assessment u/s 143(3) on 28.12.2019, making: Disallowance u/s 14A: ₹33.92 lakh.& Disallowance u/s 80G: ₹20.60 lakh.

On appeal, CIT(A) partly confirmed the disallowance u/s 14A.

Assessee’s Grounds

• Rule of consistency violated – In earlier years (including AY 2012-13), suo motu disallowance was ac

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