#Section 14A
Log in to FollowDisallowance under Section 14A of Income TAx Act, 1961
Income Tax

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Disallowance u/s 14A, suo moto or otherwise, not sustainable if interest free funds exceeds tax free investments
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If there is no loss to revenue then there would be no Disallowance and Rule 8D is not applicable for A.Y. 2007-08
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Discount on issue of ESOP is allowable expenditure u/s 37: ITAT
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AO has to record his satisfaction before proceeding to make addition u/s 14A
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Disallowance u/s 14A cannot be made on ad-hoc basis
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Addition for low GP ratio cannot be made if it is consistent with previous Years without any change in factual position
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No disallowance u/s 14A if no exempt income earned or received
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Only Investments in respect of which income is exempt to be considered in working of disallowance U/s. 14A
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Expenditure incurred in relation to income not includible in total income
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AO cannot go beyond the directions/ orders of CIT (A) while working under the order
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Provisions of Rule 8D applicable from A.Y. 2008-09 and is not retrospective
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If provisions of section 14A is to be invoked, disallowance is to be computed as per rule 8D
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Invocation of rule 8D without recording objective satisfaction by the Assessing Officer is not proper
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