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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


No section 14A disallowance if no income exempt during relevant period

November 23, 2023 453 Views 0 comment Print

Explore the Delhi High Court judgment in PCIT vs. Bhilwara Energy Ltd, covering condonation of delay, key issues, and disallowance under Section 14A of the Income Tax Act.

No Section 14A Disallowance without Exempt Income: Delhi HC

November 21, 2023 672 Views 0 comment Print

Delhi High Court ruling in PCIT Vs Techno Trexim (India) Pvt. Ltd. Understand the implications of the judgment on Section 14A disallowance without exempt income.

No tax is payable on interest accrued as fixed deposit is under prohibitory order

October 13, 2023 5331 Views 0 comment Print

ITAT Bangalore held that as assessee has no right to receive the interest accrued on Fixed Deposits due to prohibitory order, the same is not taxable.

Disallowance under rule 8D(2)(ii) unjustified as interest bearing funds not applied for making investments

October 7, 2023 576 Views 0 comment Print

ITAT Kolkata held that there is no finding that interest bearing funds have been applied for purpose of making investment. Further, on account of sufficient availability of interest free funds, interest disallowance under rule 8D(2)(ii) unjustified.

Determination of ALP without applying methods prescribed u/s 92C is untenable

October 6, 2023 576 Views 0 comment Print

ITAT Mumbai held that the determination of Arm’s Length Price (ALP) without applying any methods as prescribed under section 92C(1) of the Income Tax Act by the TPO is not tenable in law.

Disallowance u/s 14A without scrutinizing books of accounts is unwarranted

October 5, 2023 873 Views 0 comment Print

Delhi High Court held that disallowance under section 14A of the Income Tax Act without scrutinizing the accounts of the respondent/assessee unjustified in law and hence liable to be set aside.

Expense incurred for earning income chargeable under income from other source allowable as deduction u/s 57(iii)

October 4, 2023 939 Views 0 comment Print

ITAT Mumbai held that any expenditure incurred for purpose of earning income chargeable under the head ‘income from other sources’ is allowable as deduction u/s. 57(iii) of the Income Tax Act.

Disallowance of interest u/s 36(1)(iii) unjustified as interest bearing funds not used for purchase of land

September 30, 2023 1338 Views 0 comment Print

ITAT Bangalore held that disallowance of interest u/s. 36(1)(iii) of the Income Tax Act unjustified as interest bearing funds not utilized towards purchase of capital assets (i.e. land).

No Section 14A Disallowance of Expenditure for Stock-in-Trade Securities

September 30, 2023 633 Views 0 comment Print

ITAT Mumbai grants relief to Central Bank of India, disallowing expenditure under Section 14A for securities held as stock-in-trade, citing the Maxopp Investment Ltd case.

Forfeiture of share application money being capital receipt is not taxable

September 28, 2023 2631 Views 0 comment Print

ITAT Delhi held that forfeiture of share application money being forfeiture of a kind of deposits cannot be treated as revenue receipt. The same is capital in nature and hence not taxable.

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