Disallowance under Section 14A of Income TAx Act, 1961
Income Tax : Understanding the retrospective and prospective application of amendment in Section 14A of the Income-tax Act....
Income Tax : Section 14A, which pertaining to Expenditure incurred in relation to income not includible in total income, was introduced with ef...
Income Tax : Clarification in respect of disallowance under section 14A in absence of any exempt income during an assessment year Section 14A o...
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...
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...
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 : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...
Income Tax : The assessee had filed return of income of Rs.92,06,590 which was selected for complete scrutiny and during the course of assessme...
Income Tax : ITAT Ahmedabad held that disallowance of interest under section 14A unjustified as assessee’s own funds are far in excess of the...
Income Tax : ITAT Hyderabad held that as per the provisions of section 115VG of the Income Tax Act, once the assessee opts for the Tonnage Tax ...
Income Tax : ITAT Delhi held that disallowance u/s. 14A of the Income Tax Act unjustified as sufficient interest free funds were available for ...
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...
HCL Comnet Ltd. Vs DCIT (ITAT Delhi) It is settled principle of law that generic dissatisfaction as to the correctness of the claim of the assessee without assigning any reason is not a valid satisfaction which is mandatory under section 14A(2) of the Act, as has been held by Hon’ble Supreme Court in case of […]
Union Bank of India Vs DCIT (ITAT Mumbai) We find that AO has withdrawn, the relief granted u/s. 14A in the assessment order by mentioning that subsequently order of Hon’ble Supreme Court in Maxopp Investment Ltd. 402 ITR 640 has come. Accordingly, he has effectively made the disallowance us/.14A u/s 154 of the Act. We […]
Infosys BPM Limited Vs DCIT (ITAT Bangalore) Perusal of the assessment order would show that the AO did not examine the above said computation of the assessee and did not find any fault or error in the above said computation. The AO simply observes that section 14A provides that the expenditure has to be computed […]
CIT Vs HTC Global Services India Pvt. Ltd. (Madras High Court) Appellate Tribunal was not correct in confirming to reduce the expenses relating to telecommunication and travel expenses in foreign currency from the total turnover for computing deduction under Section 10B of the Income Tax Act. Further Appellate Tribunal was not right in excluding the […]
DLF Universal Ltd Vs DCIT (ITAT Delhi) Ld AO has applied 0.5% of investment of Rs. 53.51 crores whereas the ld CIT(A) restricting 0.5% only Rs. 30.84 holding that balance investment of approximately Rs. 22 crores was made in the subsidiary companies and there was no intention of earning any dividend income. The ld CIT(A) […]
The ever debatable ‘Disallowance under section 14A’ (read with Rule 8D (2) now has again found a different horizon wherein the disallowance is not attracted (partially). The below mentioned case depicts a situation where interest free funds obtained by the assessee, a real estate developer, far exceeds the investments made by him, presumption was that […]
Unifi Capital Pvt. Ltd. Vs Income Tax Officer (ITAT Chennai) Admittedly, membership fee paid to any stock exchange including MCX Exchange Ltd., is for acquiring a right in membership of exchanges for trading in shares and securities. Further membership rights in any stock exchange including MCX Exchange Ltd., is a transferable right. Therefore, said right […]
Greatship (India) Ltd. Vs DCIT (ITAT Mumbai) The assessee has further assailed the disallowance worked out by the A.O under Sec. 1 4A r.w Rule 8D, on the ground that there was no recording of an objective satisfaction by the A.O that the suo-motto disallowance offered by the assessee under Sec. 14A was not correct. […]
Disallowance made under section 14A was not to be added for computing the book profit, therefore, AO had not erred in directing to exclude difference under section 14A for computing the big profit under section 115JB.
No disallowance u/s 14A was called for in case of no exempt income earned by assessee in the relevant assessment years
