Section 14A Disallowance Must Target Only Income-Yielding Investments

Gateway Distriparks Ltd. Vs DCIT (ITAT Mumbai) The appeal was filed by Gateway Distriparks Ltd. against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] for Assessment Year (AY) 2018-19. The assessee, an Indo-Singaporean Joint-Venture operating a Containers Freight Station, challenged the CIT(A)’s decision to dismiss its appeal in limine (at the threshold) due to a delay of 1297 days, and consequently, the confirmation of the Assessing Officer’s (AO) disallowance under Section 14A of the Income Tax Act, 1961, and the resulting adjustment to book profit under Section 115JB...