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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


CPC had jurisdiction for audit-based adjustments, but double disallowance u/s 14A without hearing assessee was legally impermissible

June 5, 2026 114 Views 0 comment Print

Adjustment under section 143(1)(a)(iv) based on disallowance reported in Form 3CD was held to be within CPC’s jurisdiction. However, rectification under section 154 enhancing income without complying with section 154(3) was quashed.

No 14A Disallowance Without Satisfaction, No Penalty on Debatable Issues

June 4, 2026 246 Views 0 comment Print

The Bangalore ITAT held that a disallowance under Section 14A read with Rule 8D cannot survive without the Assessing Officer recording satisfaction regarding the incorrectness of the assessee’s claim. The Tribunal deleted the disallowance after finding non-compliance with Section 14A(2).

No Specific Charge, No Penalty: Mumbai ITAT Cancels Section 270A Levy for Defective Notice

June 2, 2026 978 Views 0 comment Print

The Tribunal held that a penalty notice must clearly state the specific limb of Section 270A being invoked. Absence of such specification was held fatal to the penalty proceedings.

ITAT Mumbai in AY 2010-11: Extensive Ruling on Banking Taxation Issues

May 31, 2026 1071 Views 0 comment Print

State Bank of India Vs ACIT (ITAT Mumbai) The Mumbai Bench of the Income Tax Appellate Tribunal decided cross-appeals filed by a public sector bank and the Revenue for Assessment Year 2010-11. The case involved a large number of recurring banking-taxation issues including pension provisions, depreciation on securities, bad debts, section 14A disallowance, taxation of […]

ITAT Mumbai Sets Aside Assessment as Adequate Hearing Opportunity Was Not Granted

May 31, 2026 516 Views 0 comment Print

The Mumbai ITAT found that the assessment order was passed without granting a reasonable opportunity to the assessee to furnish complete details or avail a hearing. The matter was remanded for fresh adjudication.

ITAT Quashes Section 263 Revision Because PCIT Raised New Issues Beyond SCN

May 30, 2026 204 Views 0 comment Print

ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The revision order was quashed for travelling beyond the scope of the proceedings.

ITAT Mumbai Allows Gift Card Discount Claim as Liability Crystallised at Time of Sale

May 27, 2026 168 Views 0 comment Print

Mumbai ITAT held that discounts offered on gift cards and gift vouchers became an actual expenditure when the instruments were sold and could not be treated as contingent liability. The Tribunal allowed the deduction after noting that unutilised amounts were later offered to tax.

ITAT Allows 80-IA Relief on Carbon Credits & Deletes Creditor Write-Back Addition

May 27, 2026 180 Views 0 comment Print

For deduction on carbon credits, Section 80-IA deduction on the sale of CERs must be allowed; gains from the prepayment of deferred sales tax constituted capital receipts, meaning Commissioner’s relief required no interference.

80IA Deduction on ‘Other Sources’ Income Only if Nexus With Industrial Undertaking Proven: ITAT Bangalore

May 27, 2026 195 Views 0 comment Print

The Bangalore ITAT held that deduction under Section 80IA can be granted only if the income is genuinely derived from the eligible industrial undertaking. Mere classification of income under other sources does not automatically entitle an assessee to deduction.

ITAT Delhi Deletes Notional Interest Addition as No Real Income Had Accrued

May 26, 2026 651 Views 0 comment Print

ITAT Delhi held that notional interest on business advances cannot be taxed without actual accrual or receipt of income. The Tribunal deleted the addition after finding that the advances were made during the ordinary course of business.

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