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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


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

September 1, 2023 1374 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 999 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 2829 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 915 Views 0 comment Print

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

Capital Expenditure Incurred Only When Whole Machine is Replaced, Not for Parts

August 1, 2023 2649 Views 0 comment Print

In present facts of the case, the Hon’ble Tribunal while deducting the additions made by Ld. AO for repair and maintenance, it was observed that if the replacement is of a baby part only, then the same cannot be considered to be a capital expenditure.

Corporate Guarantee facility provided to overseas AE is international transaction

July 31, 2023 1146 Views 0 comment Print

ITAT Mumbai held that Corporate Guarantee facility provided to overseas AE by the assessee is an international transaction and hence addition towards Arm’s Length Guarantee Fee confirmed.

Disallowance u/s 14A against Expenses for Exempt Income, Not Taxable Income

July 17, 2023 1155 Views 0 comment Print

ITAT Delhi held that disallowance u/s 14A of the Act is made in respect of expenses attributable to exempt income and not the taxable income. Further, the disallowance u/s 14A of the Income Tax Act should not exceed the exempt income of that year.

No Disallowance under section 14A if assessee not earned any exempt income

July 16, 2023 3711 Views 0 comment Print

The ITAT Hyderabad recently ruled in favor of NCC Infrastructure Holdings Limited, declaring no disallowance of deduction under section 14A of the Income Tax Act can be made if the assessee hasn’t earned any exempt income.

CESTAT Orders Reconsideration Amidst Rule 8(3A) Controversy

July 15, 2023 690 Views 0 comment Print

In a tax dispute with Baroda Rayon Corporation, the CESTAT Ahmedabad has ordered a fresh review due to the legal status of Rule 8(3A) of the Central Excise Rules, 2002. This case raises critical questions regarding the interpretation and application of taxation laws.

Provisions of section 14A r.w.r. 8D cannot be invoked in absence of any exempt income

July 13, 2023 762 Views 0 comment Print

ITAT Mumbai held that provisions of section 14A r.w.s. 8D of the Income Tax Rules not invocable as assessee has not earned any exempt income during the year. Accordingly, disallowance duly deleted by CIT(A).

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