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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


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

October 6, 2023 966 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 1059 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 1281 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 2118 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 912 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 4017 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 1302 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 573 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 1953 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 558 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.

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