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 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 : ITAT Delhi ruled that disallowance under Section 14A cannot be made without AO recording satisfaction under Section 14A(2), fully ...
Income Tax : The ITAT found that Rule 8D cannot be applied blindly without examining the nature of investments and income earned. The matter wa...
Income Tax : he ITAT ruled that an automatic ₹56 lakh 14A disallowance was invalid as the AO failed to record specific satisfaction regarding...
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...
ITAT Mumbai allowed Saurashtra Cement’s appeal, ruling that disallowance under Section 14A r/w Rule 8D cannot be made if Assessee did not earn any exempt income during financial year. Ruling deletes an addition of ₹1.15 crore.
The ITAT ruled that the Assessing Officer’s mechanical application of Rule 8D for Section 14A disallowance was invalid without recording proper satisfaction. The Tribunal directed that only net interest (interest paid less interest earned) and only those investments that yielded exempt income should be considered for re-computation, upholding the assessee’s legal objections.
Delhi ITAT rules that disallowance of expenses under Section 14A cannot exceed the actual exempt dividend income, providing relief to KEI Industries.
ITAT Kolkata rules the Finance Act 2022 amendment to Section 14A is prospective. Disallowance for expenses related to exempt income is limited to investments that yield dividends for Assessment Year 2017-18.
The Kolkata ITAT upheld a Section 14A disallowance, stating there was no breach of natural justice when the AO invoked Rule 8D(2)(iii) after the assessee’s reply was considered.
ITAT Bangalore rules that Section 14A/Rule 8D disallowances cannot be made mechanically without the AO recording proper satisfaction regarding the assessee’s claim of expenditure.
ITAT Delhi dismissed revenue appeals against Jindal Pipes Ltd., upholding deletion of disallowances on technical know-how fees and captive power expenses and restricting Section 14A disallowance.
Bombay High Court rules Section 14A disallowance cannot exceed actual exempt income, upholding Tribunal decision against Revenue in HSBC Invest Direct case.
Bombay High Court upholds ITAT ruling, stating Section 14A disallowance and Section 115JB adjustment for exempt income are not applicable if no exempt income is earned.
ITAT Mumbai rules in favor of Piem Hotels, overturning Section 14A disallowance for AY 2014-15 & 2016-17 due to AO’s lack of recorded satisfaction.
