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...
Tribunal directed allocation of common head-office expenses (and common income) to eligible industrial undertakings when computing deductions under sections 10B and 80-IB, following prior coordinate-bench rulings; AO must apply the earlier directions on remand. Key takeaway: common corporate overheads and income were to be apportioned to units for deduction-computation as previously directed.
The Supreme Court upheld the deletion of Section 14A disallowance after finding that the Assessing Officer did not record dissatisfaction with the assessee’s computation before invoking Rule 8D.
ITAT Delhi held that while selecting the comparables transactions or entities, in case of international transactions, the basis should be one of similarity with the control transactions/entities and mere broad similarity is not sufficient.
ITAT Mumbai held that marketing and advertisement expenses incurred to promote products on an online retail platform are revenue in nature since they relate to expansion of an existing business.
The Tribunal ruled that both conditions for Section 263 revision must exist simultaneously. Since no exempt income was earned, the assessment order was neither erroneous nor prejudicial.
ITAT Ahmedabad held that upward adjustment on account of notional interest on outstanding receivables rightly deleted since TNMM has been applied and working capital adjustment has been given while benchmarking the main international transaction.
The tribunal held that disallowance under Section 14A cannot be made when the assessee has not earned any exempt income during the relevant year. The ruling reaffirmed that the provision applies only when exempt income actually arises.
The Tribunal upheld deletion of a Section 14A disallowance after noting that the taxpayer did not earn any exempt income in the relevant assessment year. The ruling reiterates that Section 14A cannot be invoked in the absence of exempt income.
ITAT Delhi held that initiation of re-assessment proceedings under section 148 of the Income Tax Act is liable to be quashed as without jurisdiction since revisionary proceedings under section 263 on the same issue was already dropped.
ITAT Ahmedabad allowed three appeals for statistical purposes by setting aside CIT(A) orders and directing fresh adjudication, subject to deposit of ₹5,000 per case in the PM National Relief Fund.
