Disallowance under Section 14A of Income TAx Act, 1961
Income Tax : The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section...
Income Tax : The Tribunal clarified that disallowance under Section 14A is not warranted when sufficient interest-free own funds are available,...
Income Tax : The ruling confirms that notional disallowances under Section 14A cannot be added while computing book profits under the MAT regim...
Income Tax : Section 14A disallows expenses related to tax-exempt income. Rule 8D provides the formula, ensuring only taxable-income-related ex...
Income Tax : Tribunal confirms that detailed AO dissatisfaction justifies invoking Rule 8D, ensuring proper disallowance of expenses related to...
Income Tax : Bombay Chartered Accountants' Society has made a Representation on 'Suggestions for Amendments in the Income Tax Act', on 24th May...
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 : 1. IMPLEMENTATION OF IND-AS AND THEIR IMPACT ON TAXABLE INCOME IND-AS (Indian version of IFRS) accounting standards are being impl...
Income Tax : Amendments to Section 14A to provide that (i) dividend received after suffering dividend-distribution tax and share income from fi...
Income Tax : As earlier intimated to you, Writ Petition bearing No. 50 of 2010 (Indian Exporters Grievances Forum & Other vs. CIT) challenging ...
Income Tax : ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional in...
Income Tax : The ITAT Agra upheld deletion of a Section 14A disallowance after finding that the Assessing Officer mechanically applied Rule 8D ...
Income Tax : Mumbai ITAT upheld ₹10.76 crore addition after rejecting selective identification of physical shares for capital gains computati...
Income Tax : The Tribunal found that the transfer pricing adjustment was incorrectly computed using SEB sale rates. It allowed deduction based ...
Income Tax : Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: stat...
Income Tax : 2) The expenditure in relation to income which does not form part of the total income shall be the aggregate of following amounts,...
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...
Income Tax : The provisions of Sections 144-A and 144-B of the Income-tax Act have come into force with effect from 1st January 1976. Instructi...
ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional income cannot be brought to tax. The ruling relied on the principle that only real income is taxable.
The ITAT Agra upheld deletion of a Section 14A disallowance after finding that the Assessing Officer mechanically applied Rule 8D without recording reasons for dissatisfaction. The Tribunal reiterated that such satisfaction is mandatory before invoking Rule 8D.
Mumbai ITAT upheld ₹10.76 crore addition after rejecting selective identification of physical shares for capital gains computation. The Tribunal termed the arrangement a “colourable device” to suppress taxable gains.
The Tribunal found that the transfer pricing adjustment was incorrectly computed using SEB sale rates. It allowed deduction based on consumer tariff rates. The decision clarifies benchmarking for captive consumption.
Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: statutory conditions must be strictly met.
The case examined whether interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). The Tribunal held that co-operative banks are also co-operative societies, making such income eligible.
Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical disallowances, and held CBDT instructions cannot override the Income-tax Act.
A taxpayer could submit a revised return u/s 139(5) only when it discovered a bona fide omission or incorrect statement in the original return submitted u/s 139(1).
The Tribunal set aside additions to book profit after ruling that MAT provisions do not apply to banks established under a special statute. It emphasized that such entities are not companies under the Companies Act.
The Tribunal held that delay alone cannot justify rejection of a statutory deduction claim raised in appeal. It directed fresh verification to determine eligibility on merits.
