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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 186 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 270 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


Suo-motto disallowance by Assessee cannot be disregarded by AO without recording his Satisfaction

April 11, 2021 1869 Views 0 comment Print

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. […]

Section 14A disallowance not to be added for computation of section 115JB Book Profit

April 8, 2021 2331 Views 0 comment Print

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.

Disallowance u/s 14A cannot be made in absence of exempt income

March 27, 2021 4818 Views 0 comment Print

No disallowance u/s 14A was called for in case of no exempt income earned by assessee in the relevant assessment years

Investments yielding dividend to be considered to compute Section 14A disallowance

March 11, 2021 1242 Views 0 comment Print

Only those investments which had yielded dividend income for computing the average value of investments would be considered for the purpose of computing the amount of disallowance u/s 14A.

ITAT deletes Section 14A disallowance made without recording Satisfaction

February 3, 2021 1296 Views 0 comment Print

Asian Paints Ltd Vs ACIT (ITAT Mumbai) We have considered rival submissions in the light of decisions relied upon and perused material on record. Undisputedly, the assessee in its computation of income has computed disallowance under section 14A of the Act at Rs.23,98,769 by applying certain principles of apportionment. Therefore, it is not a case […]

ITAT restricts Section 14A Disallowance to the extent of exempt income

January 28, 2021 1368 Views 0 comment Print

Disallowance u/s 14A got restricted to the extent of exempt income, even if the provisions of the section 14A were attracted.

No applicability of section 14A on LTCG exemption of Rs.1 Lakh

January 14, 2021 65337 Views 2 comments Print

No applicability of section 14A on exemption of Rs.1,00,000/- (One Lakh) Long Term Capital Gain (LTCG) under Section 112A of Income Tax Act, 1961. Section 14A shall not be applicable on LTCG income earned u/s 112A. The answer to the questions of applicability of section 14A for LTCG u/s 112A, as income covered under section […]

Rule 8D is not retrospective & applicable from AY 2008-09 onwards

January 13, 2021 1659 Views 0 comment Print

Hero Motocorp Ltd. Vs ACIT (ITAT Delhi) In the present year, the Assessing Officer has made disallowance under section 14A by invoking provisions of Rule 8D of the Income Tax Rules, 1962. Since Rule 8D is not retrospective, the same is not applicable in the present assessment year and accordingly, we hold that the assessing […]

ITAT deletes Section 14A disallowance as AO not recorded Satisfaction

January 4, 2021 2421 Views 0 comment Print

Prism Cement Ltd. Vs DCIT (ITAT Mumbai) We observed that assessee has earned exempt income of Rs. 12,62,95,486/- and made a suo moto disallowance of Rs. 29,87,943/-. After careful consideration of the assessment order passed by the AO and the order passed by Ld. CIT(A), it is fact on record that AO has not recorded […]

Section 14A provisions cannot be imported into MAT provisions

January 4, 2021 3399 Views 0 comment Print

Sobha Developers Ltd. Vs DCIT (Karnataka High Court) From perusal of the relevant extract of Section 115JB, it is evident that Sub-Section (1) of Section 115JB provides the mode of computation of the total income of the assessee and tax payable on the assessee under Section 115JB of the Act. Sub-Section (5) of Section 115JB […]

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