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rule 8D

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Section 14A disallowance even in absence of any exempt income

Income Tax : Clarification in respect of disallowance under section 14A in absence of any exempt income during an assessment year Section 14A o...

February 1, 2022 36651 Views 3 comments Print

Section 14A disallowance- South Indian Bank Ltd Vs. CIT (Supreme Court)

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...

September 21, 2021 7806 Views 1 comment Print

Disallowance under section 14A: Another instance where section is not invoked

Income Tax : The ever debatable ‘Disallowance under section 14A’ (read with Rule 8D (2) now has again found a different horizon whe...

May 19, 2021 4284 Views 0 comment Print

No applicability of section 14A on LTCG exemption of Rs.1 Lakh

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...

January 14, 2021 64377 Views 2 comments Print

Analysis of Section 14A read with Rule 8D

Income Tax : Section 14A of the Income Tax Act, 1961 (‘the Act’) provides that no deduction shall be allowed of any expenditure incurred in...

October 16, 2020 79032 Views 1 comment Print


Latest News


Stop Mechanical disallowance of expenditure u/s 14A r.w. Rule 8D: ICAI

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...

January 24, 2018 843 Views 0 comment Print

Bombay high court to hear petition challenging Constitutional validity of Rule 8D

Income Tax : As earlier intimated to you, Writ Petition bearing No. 50 of 2010 (Indian Exporters Grievances Forum & Other vs. CIT) challenging ...

February 17, 2010 522 Views 0 comment Print


Latest Judiciary


Section 14A Explanation Applies Prospectively from 01/04/2022, Not Retrospectively

Income Tax : Explanation to Section 14A has only a prospective effect from April 1, 2022, and cannot be retrospectively applied to earlier asse...

March 8, 2025 99 Views 0 comment Print

2022 Section 14A Amendment: Prospective, No Disallowance Without Exempt Income

Income Tax : ITAT Mumbai rules 14A amendment is prospective. No disallowance if no exempt income earned, upholding Delhi HC's Era Infrastructur...

February 23, 2025 360 Views 0 comment Print

Consider Investments Yielding Exempt for Rule 8D Disallowance: ITAT Delhi

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...

February 6, 2025 243 Views 0 comment Print

Rule 8D Disallowance should be Based on Average Investment Value: ITAT Mumbai

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...

February 6, 2025 201 Views 0 comment Print

No Retrospective Amendment to Section 14A vide Finance Act 2022: ITAT Mumbai

Income Tax : The ITAT Mumbai dismissed the Revenue’s plea on Section 14A disallowance, ruling that the amendment introduced in Finance Act 20...

January 27, 2025 915 Views 0 comment Print


Latest Notifications


CBDT Circular No. 5/2014 Dated: 11.02.2014

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...

February 11, 2014 53492 Views 0 comment Print

Notification No. 45/2008-Income Tax Dated: March 24, 2008 on Section 14A

Income Tax : INCOME TAX NOTIFICATION NO-45/2008, DT: March 24, 2008 Method for determining amount of expenditure in relation to income not incl...

March 31, 2008 3671 Views 0 comment Print


Intas Pharmaceuticals Wins Dispute Over Profitability Calculations

June 4, 2024 282 Views 0 comment Print

Explore the ITAT Ahmedabad ruling on Intas Pharmaceuticals Vs ACIT, focusing on working capital adjustment and notional interest on trade receivables.

Section 41(1) cannot be invoked without liability in books: ITAT Kolkata

May 27, 2024 609 Views 0 comment Print

Dive into the detailed analysis of Syama Prasad Mookerjee Port’s case against DCIT at ITAT Kolkata regarding Section 41(1) of the Income Tax Act. Understand why cessation of trading liability cannot be invoked without liability in books.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 372 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 1071 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

AO’s Failure in Recording Dissatisfaction Invalidates Section 14A Disallowance

April 21, 2024 726 Views 0 comment Print

In the case of Krishnamurthy Thiagarajan vs ACIT (ITAT Mumbai), AO’s failure to record dissatisfaction u/s 14A led to ITAT allowing expenditure claim under Section 14A related to earning exempt income.

ITAT allows deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD)

April 21, 2024 750 Views 0 comment Print

ITAT Mumbai grants relief to Tata Steel Limited, allowing deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD) under section 36(1)(iii) of the Act. 

Section 14A: AO Must records Discontent with Assessee’s Expenditure Claim with Cogent Reasons

April 11, 2024 624 Views 0 comment Print

Bombay High Court ruling: Assessing Officer (AO) must record dissatisfaction with Assessee’s claim regarding expenditure. Detailed analysis of PCIT-2 Vs Tata Capital Ltd case.

Disallowance u/s 14A deleted as interest free own funds exceeded investment: ITAT Mumbai

April 5, 2024 627 Views 0 comment Print

ITAT Mumbai held that disallowance made u/s. 14A of the Income Tax Act read with rule 8D deleted as tax free funds were more than investment made on which exempt income was earned.

Expenditure towards ESOP is allowable u/s 37(1) of Income Tax Act: ITAT Mumbai

April 2, 2024 1881 Views 0 comment Print

ITAT Mumbai held that the ESOP expenses claimed by the assessee is an allowable expenditure under section 37(1) of the Income Tax Act.

Notional interest for delay in realization of export proceeds from AEs unwarranted: ITAT Mumbai

March 26, 2024 573 Views 0 comment Print

ITAT Mumbai held that as there is complete uniformity in not charging interest from AEs and Non-AEs for delay in realization of export proceeds, addition of notional interest in respect of transactions with AEs in the course of transfer pricing proceedings unwarranted.

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