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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 183 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 267 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


Section 41(1) Addition Not Permissible Solely Due to Lapse of Limitation Period: ITAT Mumbai

March 23, 2024 1776 Views 0 comment Print

ITAT Mumbai rules in favor of Ecokrin Hygiene Pvt. Ltd., deleting additions under section 41(1) of the Income Tax Act solely based on the expiration of the limitation period.

Section 14A was inapplicable in absence of exempt income: ITAT Delhi

March 23, 2024 672 Views 0 comment Print

Assessing Officer computed a disallowance under section 14A concerning non-current investments. However, the assessee had not claimed any exempt income. Citing relevant legal precedents, the Tribunal dismissed the disallowance, affirming that section 14A was inapplicable in the absence of exempt income.

Section 14A Disallowance cannot exceed Exempted Income: ITAT Bangalore

March 21, 2024 858 Views 0 comment Print

Read the full text of the order of ITAT Bangalore in Ambika Ghorpade Vs ACIT case, discussing disallowance u/s 14A of Income Tax Act and expenses under section 37(1).

Receiving funds from a company alone doesn’t imply income evasion

March 21, 2024 747 Views 0 comment Print

The mere receipt of funds from M/s Solvent Real Estate Pvt. Ltd. did not constitute tangible evidence of income escapement by the assessee. Despite efforts by the assessee to provide explanations and evidence, the AO failed to conduct independent inquiries and relied solely on the information received.

TP adjustment towards brand development services deleted as no contract exists between the parties: ITAT Chennai

March 20, 2024 345 Views 0 comment Print

ITAT Chennai held that transfer pricing adjustment towards brand development services unjustified in absence of contract amongst the assessee and its associated enterprises. Accordingly, AO directed to delete addition made towards brand fee adjustment.

Addition u/s. 68 unsustainable as assessee duly discharged initial burden but AO failed to conduct independent inquires: ITAT Kolkata

March 20, 2024 1176 Views 0 comment Print

ITAT Kolkata held that addition u/s. 68 of the Income Tax Act towards unexplained share application money is unsustainable as assessee has successfully discharged the burden of proof primarily casted upon it, however, AO failed to conduct independent inquires.

Section 14A disallowance should be limited to investments generating tax-exempt income

March 19, 2024 1263 Views 0 comment Print

Kolkata ITAT ruling clarifies disallowance under Rule 8D(2)(iii) for investments yielding tax-exempt income. Get insights into the case and its implications.

Failure to substantiate identity & fund source: Kolkata ITAT Remits Matter for Re-adjudication

March 19, 2024 432 Views 0 comment Print

Kolkata ITAT remits case of Dahisar Traders Pvt Ltd vs ITO due to failure in substantiating identity & fund source, demanding re-adjudication. Full order details.

Transfer pricing study selecting AE as tested party duly acceptable: ITAT Mumbai

March 18, 2024 582 Views 0 comment Print

ITAT Mumbai held that assessee selecting Associated Enterprise (AE) as “tested party” justifiable. Accordingly, transfer pricing study conducted by the assessee is duly acceptable.

Issuance of Letter of Comfort to banker of AE doesn’t constitute international transaction u/s. 92B: ITAT Mumbai

March 18, 2024 1080 Views 0 comment Print

ITAT Mumbai held that there is a fundamental gap between guarantee and Letter of Comfort. Guarantee is a legally enforceable; however, Letter of Comfort is not. Thus, issuing Letter of Comfort to the Bankers of AE, the assessee did not incurred any cost and hence it does not constitute international transaction under section 92B of the Act

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