Income Tax : The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section...
Income Tax : Tribunal confirms that detailed AO dissatisfaction justifies invoking Rule 8D, ensuring proper disallowance of expenses related to...
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 : 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 : The ITAT Kolkata held that the Assessing Officer could not examine issues beyond the limited scrutiny mandate without following CB...
Income Tax : ITAT Delhi accepted the assessee’s contention that disallowance under Section 14A cannot exceed exempt income. The ruling restri...
Income Tax : The Bangalore ITAT held that a disallowance under Section 14A read with Rule 8D cannot survive without the Assessing Officer recor...
Income Tax : The Supreme Court upheld the deletion of Section 14A disallowance after finding that the Assessing Officer did not record dissatis...
Income Tax : The tribunal held that disallowance under Section 14A cannot be made when the assessee has not earned any exempt income during the...
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...
The ITAT Kolkata held that the Assessing Officer could not examine issues beyond the limited scrutiny mandate without following CBDT-prescribed procedures for conversion into complete scrutiny. As a result, the interest disallowance under Section 36(1)(iii) was deleted.
ITAT Delhi accepted the assessee’s contention that disallowance under Section 14A cannot exceed exempt income. The ruling restricted the addition to the exempt income of ₹2.63 lakh despite a higher Rule 8D computation.
The Bangalore ITAT held that a disallowance under Section 14A read with Rule 8D cannot survive without the Assessing Officer recording satisfaction regarding the incorrectness of the assessee’s claim. The Tribunal deleted the disallowance after finding non-compliance with Section 14A(2).
The Supreme Court upheld the deletion of Section 14A disallowance after finding that the Assessing Officer did not record dissatisfaction with the assessee’s computation before invoking Rule 8D.
The tribunal held that disallowance under Section 14A cannot be made when the assessee has not earned any exempt income during the relevant year. The ruling reaffirmed that the provision applies only when exempt income actually arises.
The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section 14A framework are invalid.
ITAT Delhi ruled that disallowance under Section 14A cannot be made without AO recording satisfaction under Section 14A(2), fully deleting ₹23.38 lakh claimed from exempt dividend income.
The ITAT found that Rule 8D cannot be applied blindly without examining the nature of investments and income earned. The matter was restored to the Assessing Officer to verify whether investments were stock-in-trade and whether they yielded exempt income.
Tribunal confirms that detailed AO dissatisfaction justifies invoking Rule 8D, ensuring proper disallowance of expenses related to exempt dividend and capital gains.
he ITAT ruled that an automatic ₹56 lakh 14A disallowance was invalid as the AO failed to record specific satisfaction regarding the assessee’s claim. The Tribunal emphasized that generic reasoning cannot replace case-specific analysis.
