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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


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

August 1, 2023 2544 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 1077 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 1113 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 3654 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 639 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 708 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).

Subsidy received for establishing an industrial unit in backward area is capital receipt

July 10, 2023 1119 Views 0 comment Print

Delhi High Court held that subsidy received from Government of Goa for establishing an industrial unit in a backward area is capital receipt. Further, as subsidy was not intended to meet part of cost of assets, no adjustment against cost of asset could be ordered.

Directions issued by superior authorities are binding on Assessing Officer

July 8, 2023 3060 Views 0 comment Print

ITAT Delhi held that directions issued by a superior appellate authorities are binding on the Assessing Officers and Assessing Officer is required to strictly follow the directions of the appellate authorities and decide the issue as per the directions of the appellate authorities.

Strategic investment not part of average value of investment for disallowance u/r 8D(2)(iii) as no exempt income earned

July 5, 2023 1254 Views 0 comment Print

ITAT Delhi held that strategic investments not yielding any exempt income during the year under consideration, the same cannot form part of the average value of investment for computing disallowance under rule 8D(2)(iii) of the Income Tax Rules.

ITAT deletes Penalty on income tax refund Interest & Section 14A Additions

June 27, 2023 1221 Views 0 comment Print

In Sunrise Broking P. Ltd. Vs ITO, ITAT Ahmedabad abolishes penalty over additions made to interest on income tax refund, recognizing no concealment or inaccuracy in the income particulars.

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