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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 555 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 636 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 38040 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 8868 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 4605 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 1065 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 912 Views 0 comment Print


Latest Judiciary


ITAT Pune Directs Exclusion of Mutual Funds & Tax-Free Bonds While Computing Rule 8D Disallowance

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)...

June 13, 2026 195 Views 0 comment Print

ITAT Kolkata Deletes Interest Disallowance as AO Exceeded Scope of Limited Scrutiny

Income Tax : The ITAT Kolkata held that the Assessing Officer could not examine issues beyond the limited scrutiny mandate without following CB...

June 7, 2026 201 Views 0 comment Print

Section 14A Disallowance Cannot Exceed Exempt Income Earned: ITAT Delhi

Income Tax : ITAT Delhi accepted the assessee’s contention that disallowance under Section 14A cannot exceed exempt income. The ruling restri...

June 7, 2026 171 Views 0 comment Print

No 14A Disallowance Without Satisfaction, No Penalty on Debatable Issues

Income Tax : The Bangalore ITAT held that a disallowance under Section 14A read with Rule 8D cannot survive without the Assessing Officer recor...

June 4, 2026 330 Views 0 comment Print

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 327 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 57524 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 4442 Views 0 comment Print


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

April 21, 2024 1041 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 1338 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 972 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 840 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 2805 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 1119 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.

Registrar of Companies Fees for Working Capital Enhancement is Capital Expenditure

March 24, 2024 1020 Views 0 comment Print

Explore the case of Dharani Developers Private Limited Vs ACIT, addressing whether fees paid to Registrar of Companies for enhancing working capital should be treated as revenue or capital expenditure.

Deduction u/s. 80IA accepted in initial AY same cannot be denied in subsequent AY: ITAT Mumbai

March 23, 2024 2538 Views 0 comment Print

ITAT Mumbai held that once assessee’s claim of deduction u/s. 80IA of the Income Tax Act on Supa Wind Power Project 17 MW Unit has been accepted in the initial Assessment Year, the same cannot be denied in the subsequent Assessment Years.

Section 14A Disallowance cannot exceed Exempted Income: ITAT Bangalore

March 21, 2024 912 Views 0 comment Print

Read the full text of the order of ITAT Bangalore in Ambika Ghorpade Vs ACIT case, discussing disallowance u/s 14A of Income Tax Act and expenses under section 37(1).

Delhi HC allows Adjustment of Actual Interest Expenditure Against Interest Income

January 4, 2024 1278 Views 0 comment Print

Explore Delhi High Court’s judgment in CIT Vs RRPR Holding Pvt Ltd for Assessment Year 2009-10. Analysis of interest expenditure adjustment against earned income and key legal questions answered.

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