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 : ITAT Pune ruled that investments in mutual funds and tax-free bonds should not form part of the investment pool for Rule 8D(2)(ii)...
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 : 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 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.
ITAT Mumbai rules on Radiant Life Care’s appeal against disallowance under Section 14A of the Income Tax Act. Key interpretation of Rule 8D(2)(ii) discussed.
ITAT Jaipur held that the assessee has sufficient amount of interest free fund to make investment yielding exempt income, therefore, disallowance under section 14A of the Income Tax Act not justified. Accordingly, appeal of assessee allowed.
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.
