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 : No applicability of section 14A on exemption of Rs.1,00,000/- (One Lakh) Long Term Capital Gain (LTCG) under Section 112A of Incom...
Income Tax : Section 14A of the Income Tax Act, 1961 (‘the Act’) provides that no deduction shall be allowed of any expenditure incurred in...
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 : Gujarat High Court grants Alembic Ltd Rs. 4 crore income tax deduction under Section 80IA for their captive power plant. Read the ...
Income Tax : ITAT Cuttack rules replacement of gear boxes in Surface Furnace Kiln as current repairs under Section 31(1) for Sponge Tata Iron L...
Income Tax : Read the detailed analysis of Zodiac Ventures Ltd. vs. ITO case by Mumbai ITAT regarding income tax disallowance based on presumpt...
Income Tax : ITAT Mumbai rules no disallowance under Section 14A for investments not yielding tax-free income. Detailed analysis of DCIT vs Par...
Income Tax : In the case of DCIT vs. Paranjapee Schemes Construction Ltd., ITAT Mumbai rules no disallowance under Section 14A of the Income Ta...
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...
Calcutta High Court held that invocation of provisions of rule 8D(2)(ii) of the Income Tax Rules by AO without examining the accounts of the assessee and without examining the claim made by the assessee is unjustified.
n this case addition was made u/s.14A r.w. Rule 8D by AO and confirmed by CIT (A) holding that Amendment in Finance Act, 2022 in relation to disallowance u/s.14A r.w. Rule 8D is applicable retrospectively even if no exempted income was earned by assessee.
It is to be presumed that the assessee made investments from its own funds but not from borrowed funds. If that is the case the disallowance under interest is not warranted. Therefore, disallowance under Rule 8D(ii) to an extent of Rs. 1,78,490/- is not maintainable.
HC held that amendment of Section 14A, which is for removal of doubts cannot be presumed to be retrospective even where such language is used, if it alters or changes the law as it earlier stood.
Geetanjali Hotels & Promoters Pvt. Ltd. Vs ACIT/DCIT (ITAT Jaipur) It is noted from the record that the assessee company is engaged in the business of Hotel Industries and Toll Tax Collection. During the course of assessment proceedings, the AO noted that the assessee company had debited the interest expenses amounting to Rs. 4,23,15,400/-. During the […]
PCIT Vs IFFCO LTD (Delhi High Court) In view of Section 14A(1), no deduction is to be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total income under the As per Section 2(45) of the Act, ‘total income’ means the total amount of […]
Addl. CIT Vs TV Today Network Ltd. (ITAT Delhi) The Ground in respect of deleting disallowance of Rs. 56,20,737/- u/s 14A of the Act on the ground that disallowance u/s 14A cannot exceed exempt income. The issue involved in Ground No. 2 is also decided in favour of the assessee in ITA No. 7277/Del/2018 for […]
ITAT held that no disallowance of expenses can be made in respect of exempt income by invoking the provisions of s. 14A of the Act r/w Rule 8D of the Rules while computing book profit u/s. 115JB of the Act.
Delhi high court negating dept stand about retrospective amendment plea for sec 14A explanation added by finance act 2022 in authors opinion it should ably address the much created confusion from revenue side.
Explore the impact of Maxopp Investment Ltd. vs CIT on Section 14A disallowance. ITAT Kolkata sets aside Ld. CIT(A) order, directing re-computation in light of strategic investments.
