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 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.
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.
