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Section 14A

Disallowance under Section 14A of Income TAx Act, 1961

Latest Articles


ITAT Deletes Section 14A Disallowance Because No Exempt Income Was Earned

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...

June 15, 2026 189 Views 0 comment Print

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 546 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 585 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 756 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 1683 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 8409 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 1053 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 1442 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 1097 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 912 Views 0 comment Print


Latest Judiciary


Section 10AA Deduction Allowed as AO Failed to Prove Business Splitting: ITAT Pune

Income Tax : The ITAT Pune upheld the deduction under Section 10AA after finding that the Assessing Officer had not established that the SEZ un...

June 23, 2026 87 Views 0 comment Print

ITAT Deletes Section 37(1) Disallowance as No Penal Action Was Taken by IRDA Against Insurance Company

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 ...

June 23, 2026 150 Views 0 comment Print

Pune ITAT Deletes ₹44.80 Crore Angel Tax Addition; AO Cannot Replace Assessee’s DCF Valuation with NAV Method

Income Tax : The Tribunal held that Rule 11UA gives the assessee the exclusive option to choose the valuation method for unquoted shares. While...

June 22, 2026 378 Views 0 comment Print

ESOP Discount Is Allowable Business Expenditure Despite Pending SLP: ITAT Mumbai

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...

June 22, 2026 186 Views 0 comment Print

Periodic dredging to maintain existing jetty was revenue expense, not capital outlay: ITAT granted ₹4.49 Crore Relief

Income Tax : Expenditure of ₹4.49 crore incurred on maintenance dredging for removal of natural siltation and restoration of the existing ope...

June 20, 2026 183 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 6313 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 57458 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 4424 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 12272 Views 0 comment Print


PCIT Cannot Order Roving Enquiries Without Proving AO’s View Was Erroneous: ITAT Quashes 263 Order

November 18, 2025 594 Views 0 comment Print

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.

No Exempt Income, No 14A: ITAT Delhi Deletes ₹1.24 Cr Disallowance 

November 16, 2025 618 Views 0 comment Print

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.

Late filing of audit report doesn’t disentitle trust from benefit of exemption u/s. 11

November 15, 2025 1992 Views 0 comment Print

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.

HC Rejects Section 14A Disallowance Due to Absence of Exempt Income

November 15, 2025 843 Views 0 comment Print

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.

Deeming fiction of section 50 cannot change long term assets to short term capital assets

November 13, 2025 702 Views 0 comment Print

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.

Disallowance u/s. 14A while computing book profit u/s. 115JB is not tenable

November 10, 2025 513 Views 0 comment Print

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 Rules Entertainment Tax Subsidy as Capital Receipt in PVR Ltd. Case

November 9, 2025 513 Views 0 comment Print

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 Deletes ₹4.11 Crore Section 14A Disallowance Against Aishwarya Rai

November 8, 2025 5229 Views 0 comment Print

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.

Invocation of rule 8D impermissible without recording non-satisfaction in terms of section 14A(2)

November 7, 2025 828 Views 0 comment Print

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.

ITAT Delhi Deletes Section 14A Disallowance for Lack of AO’s Satisfaction

November 7, 2025 396 Views 0 comment Print

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.

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