Income Tax : Clarification in respect of disallowance under section 14A in absence of any exempt income during an assessment year Section 14A o...
Income Tax : The issue before the Hon’ble Supreme Court (SC) was whether section 14A of the Income-tax Act, 1961 (the Act) enables the Depart...
Income Tax : The ever debatable ‘Disallowance under section 14A’ (read with Rule 8D (2) now has again found a different horizon whe...
Income Tax : No applicability of section 14A on exemption of Rs.1,00,000/- (One Lakh) Long Term Capital Gain (LTCG) under Section 112A of Incom...
Income Tax : Section 14A of the Income Tax Act, 1961 (‘the Act’) provides that no deduction shall be allowed of any expenditure incurred in...
Income Tax : The mechanical disallowance u/s 14A r.w. Rule 8D is also being added to the book profit by the AO irrespective of the fact whethe...
Income Tax : As earlier intimated to you, Writ Petition bearing No. 50 of 2010 (Indian Exporters Grievances Forum & Other vs. CIT) challenging ...
Income Tax : Explanation to Section 14A has only a prospective effect from April 1, 2022, and cannot be retrospectively applied to earlier asse...
Income Tax : ITAT Mumbai rules 14A amendment is prospective. No disallowance if no exempt income earned, upholding Delhi HC's Era Infrastructur...
Income Tax : ITAT Delhi remanded the issue back to file of AO to re-compute disallowance under rule 8D(2)(ii) of the Income Tax Act by taking t...
Income Tax : ITAT Mumbai held that disallowance under rule 8D(2)(ii) r.w.s. 14A of the Income Tax Rules should be made on average value of inve...
Income Tax : The ITAT Mumbai dismissed the Revenue’s plea on Section 14A disallowance, ruling that the amendment introduced in Finance Act 20...
Income Tax : Circular No. 5/2014-Income Tax Central Board of Direct Taxes, in exercise of its powers under section 119 of the Act hereby clari...
Income Tax : INCOME TAX NOTIFICATION NO-45/2008, DT: March 24, 2008 Method for determining amount of expenditure in relation to income not incl...
Explanation to Section 14A has only a prospective effect from April 1, 2022, and cannot be retrospectively applied to earlier assessment years.
ITAT Mumbai rules 14A amendment is prospective. No disallowance if no exempt income earned, upholding Delhi HC’s Era Infrastructure view.
ITAT Delhi remanded the issue back to file of AO to re-compute disallowance under rule 8D(2)(ii) of the Income Tax Act by taking those investment which give rise to exempt income @1% of average value of investment.
ITAT Mumbai held that disallowance under rule 8D(2)(ii) r.w.s. 14A of the Income Tax Rules should be made on average value of investment yielding exempt income and not on the basis of quantum of investment based on market value.
The ITAT Mumbai dismissed the Revenue’s plea on Section 14A disallowance, ruling that the amendment introduced in Finance Act 2022 is not retrospective.
Delhi High Court held that recourse to Rule 8D of Income Tax Rules for computing disallowance u/s. 14A not allowable since assessee’s computation of expense attributable to earning exempt income not found inadequate.
The ITAT Mumbai ruled on Prakash Udyog Ltd. vs ITO, addressing errors in income computation, disallowance under section 14A, and overdraft interest disallowance.
The fiction created by Section 11 of the Acquisition Act, does not imply that the assessee bank would also become a company for the purpose of the Companies Act for which Clause (b) of Sub-Section 2 of Section 115JB is applicable.
Assessee claimed that in section 14A, the disallowance of expenditure even if computed in accordance with Rule 8D could not exceed the exempt income earned in that year.
ITAT Ahmedabad held that no disallowance under Section 14A of the Income Tax Act warranted as interest-free funds exceed the investments made, and there is no evidence to suggest that borrowed funds were used for such investments.
