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Section 14A

Disallowance under Section 14A of Income TAx Act, 1961

Latest Articles


Amendment in Section 14A ‘Retrospective or Prospective’

Income Tax : Understanding the retrospective and prospective application of amendment in Section 14A of the Income-tax Act....

August 6, 2022 5838 Views 4 comments Print

Disallowance of Expenditure incurred in relation to income exempt from tax

Income Tax : Section 14A, which pertaining to Expenditure incurred in relation to income not includible in total income, was introduced with ef...

March 16, 2022 7629 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 35394 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 7488 Views 1 comment Print

Land Mark Judgement: No section 14A disallowance if assessee had sufficient interest free own fund

Income Tax : In the landmark judgement the Hon’ble Supreme Court of India allowed the appeal of the South Indian Bank by settling the long dr...

September 13, 2021 11592 Views 0 comment Print


Latest News


6 Suggestions for Amendments in Income Tax Act by BCAS

Income Tax : Bombay Chartered Accountants' Society has made a Representation on 'Suggestions for Amendments in the Income Tax Act', on 24th May...

May 28, 2019 8040 Views 2 comments Print

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 840 Views 0 comment Print

Easwar Committee Recommendations For Income Tax Reforms Through Administrative Instructions

Income Tax : 1. IMPLEMENTATION OF IND-AS AND THEIR IMPACT ON TAXABLE INCOME IND-AS (Indian version of IFRS) accounting standards are being impl...

January 21, 2016 959 Views 0 comment Print

Simplify Section 14A to remove ambiguity

Income Tax : Amendments to Section 14A to provide that (i) dividend received after suffering dividend-distribution tax and share income from fi...

January 19, 2016 662 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 480 Views 0 comment Print


Latest Judiciary


Mere inadequate enquiry alone not justify Commissioner’s revisional jurisdiction

Income Tax : Assessing Officer is not required to detail reasoning for each deduction in the assessment order and that inadequate enquiry alone...

July 12, 2024 345 Views 0 comment Print

Gujarat HC allows Section 80IA(4) deduction to Captive Power Plant of Alembic Ltd

Income Tax : Gujarat High Court grants Alembic Ltd Rs. 4 crore income tax deduction under Section 80IA for their captive power plant. Read the ...

July 10, 2024 600 Views 0 comment Print

ITAT allows foreign travel expenses for board meetings in Singapore

Income Tax : ITAT Cuttack rules replacement of gear boxes in Surface Furnace Kiln as current repairs under Section 31(1) for Sponge Tata Iron L...

July 8, 2024 282 Views 0 comment Print

Assessment not erroneous if AO adopts plausible view despite PCIT’s different opinion

Income Tax : If AO adopts a plausible view, even if two views are possible, the assessment cannot be deemed erroneous merely because the PCIT h...

June 27, 2024 198 Views 0 comment Print

Section 14A disallowance based on presumptions of earning dividend income in future is unsustainable 

Income Tax : Read the detailed analysis of Zodiac Ventures Ltd. vs. ITO case by Mumbai ITAT regarding income tax disallowance based on presumpt...

June 25, 2024 261 Views 0 comment Print


Latest Notifications


Section 14A disallowance cannot exceed total expense: CBDT

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,...

June 2, 2016 6085 Views 0 comment Print

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 51704 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 3584 Views 0 comment Print

Proceedings U/s. 144A & 144B of Income Tax Act, 1961- Procedural Instructions

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...

December 31, 1977 11213 Views 0 comment Print


Section 14A gets applicable when shares are held as stock-in-trade and dividend income is exempt u/s. 10(34)

October 9, 2023 888 Views 0 comment Print

ITAT Ahmedabad held that the applicability of Section 14A is triggered when the shares are held as ‘stock-in-trade’ and by virtue of section 10(34) dividend income is not to be included in total income and is exempt from tax.

Disallowance under rule 8D(2)(ii) unjustified as interest bearing funds not applied for making investments

October 7, 2023 468 Views 0 comment Print

ITAT Kolkata held that there is no finding that interest bearing funds have been applied for purpose of making investment. Further, on account of sufficient availability of interest free funds, interest disallowance under rule 8D(2)(ii) unjustified.

Mere non-attendance of summons cannot be reason to disbelieve genuineness of transaction

October 7, 2023 1098 Views 0 comment Print

ITAT Mumbai held that the assessee had furnished sufficient evidences to justify the genuineness of the payments and therefore their mere non-attendance of summons, cannot be reason enough to disbelieve the genuineness of the transactions with them. Accordingly, addition u/s. 69C deleted.

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

October 6, 2023 486 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 under Section 14A Not Applicable for Stock in Trade Securities

October 5, 2023 852 Views 0 comment Print

Explore Delhi High Court’s judgment on disallowance under Section 14A of Income Tax Act, 1961, in case of Punjab National Bank (Erstwhile United Bank of India)

Disallowance u/s 14A without scrutinizing books of accounts is unwarranted

October 5, 2023 789 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 768 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 restricted to 0.5% of guarantee value in corporate guarantee to AE

October 4, 2023 1257 Views 0 comment Print

ITAT Chennai held that the corporate guarantee to Associated Enterprise (AE) is an international transaction and it has to be assessed at 0.5% of the corporate commission. Hence, directed AO to restrict the disallowance at 0.5% of the guarantee value.

Interest on TDS being compensatory in nature is allowable u/s 37(1)

October 3, 2023 3732 Views 0 comment Print

ITAT Jaipur held that interest paid on TDS is compensatory in nature and is a business expenditure allowable u/s 37(1) of the Income Tax Act

No section 271(1)(c) penalty on non-existing or deleted disallowances

October 3, 2023 1113 Views 0 comment Print

ITAT Delhi rules that penalties under section 271(1)(c) of the Income Tax Act cannot be imposed based on non-existing or deleted disallowances.

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