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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 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 96 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


Nothing indicated knowingly participation in sham transaction: Reopening quashed

February 23, 2026 381 Views 0 comment Print

Gujarat High Court held that the respondent officer could not have assumed jurisdiction for reopening the assessment since there was nothing which indicate that petitioner has participated knowingly in the sham transaction. Accordingly, order is quashed and set aside.

ITAT Delhi Quashed Section 263 Revision as AO Took a Possible View

February 19, 2026 720 Views 0 comment Print

The Tribunal held that revision under Section 263 is invalid where the Assessing Officer examined records and adopted a plausible view. Mere disagreement or desire for further enquiry is insufficient.

Sec 147 Reopening After 4 Years Invalid; Audit Objection Not Tangible; Bad Debt MAT Issue Fails: ITAT Mumbai

February 17, 2026 396 Views 0 comment Print

The Tribunal ruled that reopening based merely on audit objection without independent application of mind is unsustainable. An audit note cannot replace the Assessing Officers reasoned belief.

Disallowance u/s. 14A limited to extent of investment which yielded exempt income

February 14, 2026 477 Views 0 comment Print

ITAT Chennai held that disallowance in terms of section 14A of the Income Tax Act read with rule 8D restricted to the extent of investment which yielded exempt income. Accordingly, disallowance restricted and appeal partly allowed.

No Disallowance u/s 14A Without Exempt Income – ₹43.23 Cr Addition Deleted: ITAT Mumbai

February 14, 2026 297 Views 0 comment Print

The Tribunal held that Section 14A cannot be invoked when no exempt income is earned during the year. It deleted both the additional disallowance and the assessee’s own mistaken disallowance.

Disallowance U/s 14A while computing book profit U/s 115JB deserved to be deleted

February 13, 2026 381 Views 0 comment Print

ITAT Mumbai held that disallowance made under section 14A of the Income Tax Act added to Book Profits for computing taxes under section 115JB Income Tax Act deserved to be deleted.

Loan Repayment Not Taxable U/s 68 & 14A Disallowance Restricted to Actual Expenditure

February 13, 2026 747 Views 0 comment Print

The Tribunal ruled that amounts received were repayments of past advances and could not be taxed as unexplained cash credits in the current year. Additions were deleted as they did not pertain to fresh transactions.

Deemed Dividend U/s 2(22)(e) Largely Deleted & Sec.54 Deduction Allowed

February 13, 2026 801 Views 0 comment Print

ITAT Delhi held that Section 2(22)(e) cannot apply where the assessee held less than 10% shareholding in the lending company. As statutory thresholds were not met, the deemed dividend addition was largely deleted.

Disallowance u/s. 14A read with rule 8D cannot exceed exempt income

February 12, 2026 483 Views 0 comment Print

ITAT Mumbai held that the disallowance under section 14A of the Income Tax Act read with rule 8D cannot exceed the exempt income earned by the assessee during the relevant previous year. Accordingly, no further disallowance u/s. 14A is called for.

Revision order was upheld as it flagged unverified INSIGHT Portal inputs on alleged accommodation entries

February 11, 2026 423 Views 0 comment Print

PCIT s revision under section 263 against assessee was upheld holding that AO did not properly verify the very low Section 14A disallowance despite huge exempt income and also ignored INSIGHT portal inputs about alleged accommodation entries.

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