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 : Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: stat...
Income Tax : The case examined whether interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). The Tribunal he...
Income Tax : Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical ...
Income Tax : A taxpayer could submit a revised return u/s 139(5) only when it discovered a bona fide omission or incorrect statement in the ori...
Income Tax : The Tribunal set aside additions to book profit after ruling that MAT provisions do not apply to banks established under a special...
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...
The PCIT held the AO’s assessment under section 143(3) as erroneous and prejudicial to Revenue, directing fresh verification of various deductions. The assessee argued all claims were correctly examined, questioning the jurisdiction of section 263.
ITAT Delhi held that Section 14A cannot be applied when no exempt income is earned, deleting a ₹1.24 crore disallowance. The Tribunal also condoned a 99-day filing delay due to reasonable cause.
ITAT Pune held that late filing of audit report cannot disentitle trust from availing benefit of section 11 of the Income Tax Act. Accordingly, order of CIT(A) allowing claim of exemption u/s. 11 upheld and appeal of revenue dismissed.
The Court held that no disallowance under Section 14A can be made when exempt income is not earned in the relevant year. It upheld the Tribunal’s decision and dismissed the revenue’s appeal.
ITAT Mumbai held that section 50 does not convert a long-term capital asset to a short-term capital asset, then the rate of tax is applicable for the transfer of a long-term capital asset has to be in accordance with section 112. The deeming fiction of section 50 cannot be imported under section 112.
ITAT Ahmedabad held that addition on account of section 14A of the Income Tax Act while computing books profit under section 115JB of the Income Tax Act is not justifiable. Accordingly, addition u/s. 14A deleted and appeal of assessee allowed.
ITAT Delhi upholds capital receipt status of E-tax subsidies and deletes disallowances on leasehold expenses, Section 14A, bank charges, and MAT additions for PVR Ltd.
ITAT Mumbai upheld relief granted by CIT(A) to Aishwarya Rai Bachchan, holding that the AO failed to record satisfaction before rejecting the assessee’s suo-moto disallowance under Section 14A. The Tribunal found the additional disallowance of ₹4.11 crore excessive and unsupported by evidence.
ITAT Mumbai held that in absence of recording of non-satisfaction in terms of section 14A(2) of the Income Tax Act, invocation of Rule 8D is not permissible. Accordingly, disallowance u/s. 14A read with Rule 8D cannot be sustained.
Delhi ITAT held that disallowance under Section 14A cannot be made without Assessing Officer recording satisfaction about correctness of assessee’s claim. Since no such satisfaction was recorded, ₹25.06 lakh disallowance was deleted.
