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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 204 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 1445 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 111 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 156 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 384 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 189 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


Letters of Comfort will construe as an International Transaction u/s 92B

May 13, 2024 1461 Views 0 comment Print

Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued by assessee could not be compared with the letters of comfort and therefore agreed with the computation of arm’s length rate of 0.04%.

ITAT Upholds AO’s Decision to Treat Rental Income as House Property Income & Disallow Depreciation

May 12, 2024 1218 Views 0 comment Print

ITAT noted that company’s primary objective was providing IT services, not letting out properties. Therefore, it upheld Assessing Officer’s decision to treat rental income as income from house property and disallow depreciation claimed by company.

Expenditure u/s 37(1) should be disallowed to the extent not in line with existing business

May 11, 2024 2598 Views 0 comment Print

Expenditure incurred by assessee should be disallowed to the extent that expenditure which had been incurred for evaluation of business opportunities that could not be said to be in line with the existing business or an extension of the existing business of assessee of manufacturing of paints and enamels.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 855 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 1650 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

AO’s Failure in Recording Dissatisfaction Invalidates Section 14A Disallowance

April 21, 2024 1023 Views 0 comment Print

In the case of Krishnamurthy Thiagarajan vs ACIT (ITAT Mumbai), AO’s failure to record dissatisfaction u/s 14A led to ITAT allowing expenditure claim under Section 14A related to earning exempt income.

ITAT allows deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD)

April 21, 2024 1320 Views 0 comment Print

ITAT Mumbai grants relief to Tata Steel Limited, allowing deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD) under section 36(1)(iii) of the Act. 

Final Assessment Order Invalid without Draft Section u/s 144C(1) Order: ITAT Mumbai

April 12, 2024 2007 Views 0 comment Print

ITAT Mumbai quashes assessment order in Welspun Global Brands Ltd Vs DCIT case. AO failed to follow Sec 144C(1) of Income Tax Act, rendering order invalid.

After initiation of resolution process appeal not maintainable if not filed by IRP

April 11, 2024 528 Views 0 comment Print

Since the appellant hadn’t filed the appeal through the Interim Resolution Professional as required under the resolution process, the ITAT deemed the appeal not maintainable and dismissed it.

Section 14A: AO Must records Discontent with Assessee’s Expenditure Claim with Cogent Reasons

April 11, 2024 963 Views 0 comment Print

Bombay High Court ruling: Assessing Officer (AO) must record dissatisfaction with Assessee’s claim regarding expenditure. Detailed analysis of PCIT-2 Vs Tata Capital Ltd case.

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