Disallowance under Section 14A of Income TAx Act, 1961
Income Tax : The ITAT Bangalore held that no disallowance under section 14A read with Rule 8D can be made where the assessee did not earn exemp...
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 : 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 : The ITAT Pune upheld the deduction under Section 10AA after finding that the Assessing Officer had not established that the SEZ un...
Income Tax : The ITAT Mumbai held that Explanation 1 to Section 37(1) could not apply in the absence of any finding by the competent authority ...
Income Tax : The Tribunal held that Rule 11UA gives the assessee the exclusive option to choose the valuation method for unquoted shares. While...
Income Tax : The ITAT Mumbai held that ESOP discount is an allowable deduction under Section 37(1), observing that the pendency of an SLP again...
Income Tax : Expenditure of ₹4.49 crore incurred on maintenance dredging for removal of natural siltation and restoration of the existing ope...
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...
Tribunal highlighted that short-term and long-term capital gains from share sales, under sections 111A and 10(38), were properly taxed, reflecting assessee’s investment intent.
he ITAT ruled that an automatic ₹56 lakh 14A disallowance was invalid as the AO failed to record specific satisfaction regarding the assessee’s claim. The Tribunal emphasized that generic reasoning cannot replace case-specific analysis.
The Tribunal directed AO to compute Section 14A disallowance only for investments generating exempt income, following Rule 8D. The decision reinforces the need for precise calculation of disallowances against exempt income.
ITAT Kolkata struck down AO’s whimsical treatment of LTCG as bogus while simultaneously accepting STCG from the same shares. The Tribunal deleted the entire ₹53.24 lakh addition, noting both gains arose from identical transactions and evidence.
The Court held that interest and related receipts must be treated as business income, not income from other sources. The Tribunal’s order was upheld as no substantial question of law arose.
Tribunal held that Rule 8D disallowance cannot exceed the assessee’s total claimed expenditure and directed restriction of the 14A addition. The ruling clarifies limits on 14A disallowances where expenses are minimal.
The Tribunal removed the interest disallowance after holding that the assessee’s earlier favourable ruling covered the issue. Key takeaway: once a factual issue is already adjudicated in the assessee’s own case, consistency must be maintained.
The ITAT sent back the issue of carry-forward business losses for re-examination because assessment records did not clarify earlier allowances. Key takeaway: loss set-off must be verified year-by-year before denial.
The tribunal held that the State Electricity Board consumer tariff of ₹6.62/unit was the valid internal CUP for captive power transfer. Rejecting comparisons with generating companies, it ruled that no downward adjustment was required. The key takeaway is that actual SEB purchase rates can reliably determine market value for 80IA claims.
Tribunal held that the AO had validly recorded dissatisfaction with the assessee’s 14A working and rightly invoked Rule 8D, confirming interest disallowance while remanding only the investment-averaging computation for Vireet-based recalculation.
