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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


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

September 30, 2023 864 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 3900 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.

No Disallowance under Section 14A/Rule 8D without Exempt Income

September 24, 2023 1233 Views 0 comment Print

In a significant ruling, ITAT Delhi states that no disallowance under Section 14A read with Rule 8D can be made if no exempt income was earned in previous year.

Disallowance of expenditure u/s 14A unjustified without any dividend income from equity investment

September 22, 2023 549 Views 0 comment Print

ITAT Mumbai held that since the assessee has not earned any dividend income from its equity investment during the year disallowance of expenditure under section 14A of the Income Tax Act read with Rule 8D of the Income Tax Rules is not sustainable.

Interest paid on delayed deposit of income tax not allowable as expenditure

September 16, 2023 1872 Views 0 comment Print

ITAT Kolkata held that interest payment on delayed deposit of income tax, whether TDS or otherwise is not an allowable expenditure.

Payment of guarantee fee to Gujarat Government is revenue expenditure

September 15, 2023 531 Views 0 comment Print

ITAT Ahmedabad held that payment of guarantee fee to the Govt. of Gujarat in consideration of guarantee issued by it for repayment of unsecured loan is revenue expenditure.

No Section 14A Disallowance if No Expenditure Claimed in P&L accounts

September 1, 2023 1287 Views 0 comment Print

Delhi’s ITAT rules on disallowance under section 14A of the Income Tax Act. The verdict clarifies treatment of revenue expenses not claimed in P&L accounts.

Late TDS Deposit Interest not deductible as Business Expenditure

August 30, 2023 975 Views 0 comment Print

Analysis of Shiva Pharmachem Ltd vs. DCIT case where ITAT Ahmedabad rules no disallowance under section 14A of Income Tax Act without any exempt income. Full text of ITAT order included.

Disallowance of staff welfare expenditure resorting to adhoc base unsustainable

August 29, 2023 2760 Views 0 comment Print

ITAT Delhi held that disallowance of staff welfare expenditure on the adhoc basis unsustainable as AO failed to establish as to who the expenses are not incurred for business purpose.

ITAT allows Electricity expenses which were disallowed on mere presumptions

August 28, 2023 858 Views 0 comment Print

Detailed analysis of ITAT’s decision in Uma Rajendra Agarwal Vs ACIT regarding deletion of adhoc disallowance on electricity expenses.

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