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Section 14A

Disallowance under Section 14A of Income TAx Act, 1961

Latest Articles


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 489 Views 0 comment Print

ITAT Orders Fresh Section 14A Disallowance computation for Lack of AO Satisfaction

Income Tax : The Tribunal clarified that disallowance under Section 14A is not warranted when sufficient interest-free own funds are available,...

January 8, 2026 537 Views 0 comment Print

Section 14A Disallowance Not Addable to MAT Book Profits: Analysis by ITAT

Income Tax : The ruling confirms that notional disallowances under Section 14A cannot be added while computing book profits under the MAT regim...

December 31, 2025 555 Views 0 comment Print

Disallowance of expenditure u/s 14A of Income Tax Act against Exempt Income

Income Tax : Section 14A disallows expenses related to tax-exempt income. Rule 8D provides the formula, ensuring only taxable-income-related ex...

December 21, 2025 1359 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 510 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 8364 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 1008 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 1385 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 1046 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 846 Views 0 comment Print


Latest Judiciary


Bombay HC Quashes Section 270A Penalty Due to Absence of Under-Reported Income

Income Tax : Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: stat...

May 1, 2026 162 Views 0 comment Print

Interest from co-op banks qualifies for Section 80P(2)(d) deduction: ITAT Indore

Income Tax : The case examined whether interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). The Tribunal he...

April 28, 2026 264 Views 0 comment Print

Consistency Over Technicalities – ITAT Allows Actuarial Pension Provision & Rejects Mechanical Disallowances

Income Tax : Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical ...

April 24, 2026 201 Views 0 comment Print

Revised ITR u/s 139(5) was allowed only for errors in the original return

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...

April 24, 2026 252 Views 0 comment Print

MAT Not Applicable as Bank Not Formed Under Companies Act: ITAT Kolkata

Income Tax : The Tribunal set aside additions to book profit after ruling that MAT provisions do not apply to banks established under a special...

April 21, 2026 357 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 6295 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 57032 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 4307 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 12155 Views 0 comment Print


ITAT Mumbai: Depreciation on Trademark Allowed-AO Cannot Revisit Claim in Subsequent Years

April 13, 2026 117 Views 0 comment Print

ITAT held that once depreciation is allowed after scrutiny in the first year, it cannot be disallowed subsequently without fresh facts. The AO cannot revisit the same issue repeatedly. The key takeaway is that consistency must be maintained in tax assessments.

Choosing AE as tested party justifiable since AE possess least complex functional analysis

April 9, 2026 282 Views 0 comment Print

ITAT Mumbai held that with respect to benchmarking of export transaction, foreign Associated Enterprise [AE] can be chosen as tested party since AE possess the least complex functional analysis. Accordingly, transfer pricing adjustment not justifiable.

ITAT Exceeded Jurisdiction by Admitting Additional Evidence Filed by Revenue: Telangana HC

April 3, 2026 333 Views 0 comment Print

The court held that parties cannot introduce additional evidence as a matter of right under Rule 29. The ITAT’s acceptance of Revenue-filed evidence and remand order was set aside as beyond jurisdiction.

Section 14A Cannot Apply When No Exempt Income Exists: ITAT Delhi

April 1, 2026 351 Views 0 comment Print

The Tribunal held that Section 14A cannot be invoked in absence of exempt income. It clarified that taxable dividend income eliminates the basis for disallowance.

Section 148 Notice Invalid When Issued After Limitation Deadline: ITAT Mumbai

April 1, 2026 1365 Views 0 comment Print

Zee Entertainment Enterprises Limited Vs DCIT (ITAT Mumbai) The matter concerns two appeals filed by the assessee against orders of the Commissioner of Income Tax (Appeals)-48, Mumbai, for Assessment Years (AY) 2015–16 and 2019–20. Both appeals arise from assessment orders passed under Section 143(3) read with Section 147 of the Income Tax Act, 1961. Since […]

Penny Stock Share Transactions: Reassessment Quashed for Change of Opinion

March 31, 2026 519 Views 0 comment Print

The ITAT held that reopening was invalid as it was based on the same material already examined during the original assessment. It ruled that reassessment cannot be used to review a concluded issue.

Development fee collected for funding capital expenditure for airport development not taxable as revenue income

March 30, 2026 210 Views 0 comment Print

ITAT Mumbai held that development fees collected from passengers was earmarked for capital expenditure towards modernisation and development of airport infrastructure and therefore the same could not be treated as revenue income of the assessee.

Deduction u/s. 80G not deniable merely because payment forms part of CSR expenditure

March 21, 2026 951 Views 0 comment Print

ITAT Mumbai held that deduction claimed by the assessee under section 80G of the Income Tax Act cannot be denied merely on the ground that the payment also formed part of CSR expenditure under the Companies Act.

Recourse to residuary provision 37(1) not justified as provision u/s. 35D for amortization of preliminary expense exists

March 18, 2026 201 Views 0 comment Print

ITAT Kolkata held that professional fees for works related to acquisition of new unit or expansion of existing undertaking is governed by provisions of section 35D of the Income Tax Act. Thus, since there is a specific provision u/s. 35D for amortization of certain preliminary expenses, the recourse could not have been had to the residuary provision of section 37(1) of the Act.

Excess payment over net book value in amalgamation is goodwill hence eligible for depreciation u/s. 32(1)(ii)

March 18, 2026 183 Views 0 comment Print

ITAT Chennai held that the excess payment over the net book value of assets and liabilities acquired on account of amalgamation is in the nature of ‘goodwill’ and is eligible for depreciation u/s.32(1)(ii) of the Income Tax Act.

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