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Exempt Dividend Income Cannot Be Taxed Beyond Rule 8D: ITAT Delhi

Income Tax : The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section...

January 10, 2026 504 Views 0 comment Print

ITAT Upholds Rule 8D for Sec. 14A Disallowance Due to Unsatisfactory Explanation

Income Tax : Tribunal confirms that detailed AO dissatisfaction justifies invoking Rule 8D, ensuring proper disallowance of expenses related to...

December 2, 2025 546 Views 0 comment Print

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 37911 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 8763 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 4569 Views 0 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 1029 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 867 Views 0 comment Print


Latest Judiciary


SC Dismisses Revenue Appeal as AO Failed to Record Dissatisfaction Before Applying Rule 8D

Income Tax : The Supreme Court upheld the deletion of Section 14A disallowance after finding that the Assessing Officer did not record dissatis...

March 16, 2026 294 Views 0 comment Print

No Section 14A Disallowance Without Exempt Income: ITAT Deletes Addition in Investment Case

Income Tax : The tribunal held that disallowance under Section 14A cannot be made when the assessee has not earned any exempt income during the...

March 6, 2026 480 Views 0 comment Print

No Satisfaction Under Section 14A, Rule 8D Disallowance Fails

Income Tax : ITAT Delhi ruled that disallowance under Section 14A cannot be made without AO recording satisfaction under Section 14A(2), fully ...

December 27, 2025 351 Views 0 comment Print

Tribunal Flags Error in Applying Section 14A to Non-Yielding Investments

Income Tax : The ITAT found that Rule 8D cannot be applied blindly without examining the nature of investments and income earned. The matter wa...

December 18, 2025 405 Views 0 comment Print

Section 14A Disallowance Deleted for Mechanical Application & Lack of AO Satisfaction

Income Tax : he ITAT ruled that an automatic ₹56 lakh 14A disallowance was invalid as the AO failed to record specific satisfaction regarding...

November 23, 2025 351 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 57173 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 4370 Views 0 comment Print


Section 14A disallowance applies only to investments yielding exempt income

June 9, 2024 1734 Views 0 comment Print

ITAT Mumbai rules no disallowance under Section 14A for investments not yielding tax-free income. Detailed analysis of DCIT vs Paranjapee Schemes case.

Section 14A disallowance not warranted for investments not yielding tax-free income

June 4, 2024 846 Views 0 comment Print

In the case of DCIT vs. Paranjapee Schemes Construction Ltd., ITAT Mumbai rules no disallowance under Section 14A of the Income Tax Act is warranted for investments not yielding tax-free income.

Intas Pharmaceuticals Wins Dispute Over Profitability Calculations

June 4, 2024 552 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 819 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 801 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 1605 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 987 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 1269 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 918 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 816 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.

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