Disallowance under Section 14A of Income TAx Act, 1961
Income Tax : The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section...
Income Tax : The Tribunal clarified that disallowance under Section 14A is not warranted when sufficient interest-free own funds are available,...
Income Tax : The ruling confirms that notional disallowances under Section 14A cannot be added while computing book profits under the MAT regim...
Income Tax : Section 14A disallows expenses related to tax-exempt income. Rule 8D provides the formula, ensuring only taxable-income-related ex...
Income Tax : Tribunal confirms that detailed AO dissatisfaction justifies invoking Rule 8D, ensuring proper disallowance of expenses related to...
Income Tax : Bombay Chartered Accountants' Society has made a Representation on 'Suggestions for Amendments in the Income Tax Act', on 24th May...
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...
Income Tax : 1. IMPLEMENTATION OF IND-AS AND THEIR IMPACT ON TAXABLE INCOME IND-AS (Indian version of IFRS) accounting standards are being impl...
Income Tax : Amendments to Section 14A to provide that (i) dividend received after suffering dividend-distribution tax and share income from fi...
Income Tax : As earlier intimated to you, Writ Petition bearing No. 50 of 2010 (Indian Exporters Grievances Forum & Other vs. CIT) challenging ...
Income Tax : Court held that penalty under Section 270A cannot apply where assessed income does not exceed processed income. Key takeaway: stat...
Income Tax : The case examined whether interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). The Tribunal he...
Income Tax : Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical ...
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...
Income Tax : The Tribunal set aside additions to book profit after ruling that MAT provisions do not apply to banks established under a special...
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,...
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...
Income Tax : INCOME TAX NOTIFICATION NO-45/2008, DT: March 24, 2008 Method for determining amount of expenditure in relation to income not incl...
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...
The issue was whether long-term financing income qualified for deduction despite reclassification of receipts. The Tribunal held the entity eligible, citing statutory changes, past approvals, and consistency across years.
The Tribunal held that when interest-free own funds exceed investments, no interest disallowance under section 14A can be made. The ruling reinforces that presumption favours the taxpayer in such cases.
ITAT held that invoking Rule 8D without recording dissatisfaction with the assessee’s own disallowance violates section 14A(2). Mechanical application of Rule 8D renders the disallowance legally unsustainable.
The Tribunal dismissed the Revenue’s appeal, holding that JDA-related income issues had already attained finality. Any attempt to reassess the same income in an earlier year would result in impermissible double taxation.
The ruling confirms that notional disallowances under Section 14A cannot be added while computing book profits under the MAT regime.
The dispute centered on unexplained investment taxed in an incorrect year. The Tribunal ruled that such an addition is legally unsustainable and must be deleted.
The ITAT held that earning significant exempt dividend income necessarily involves indirect administrative expenses. In the absence of separate books, the AO rightly applied Rule 8D to compute disallowance.
The Tribunal held that no disallowance under Section 14A is warranted when exempt dividend arises incidentally from shares held as stock-in-trade in banking business. Applying Supreme Court precedents, it deleted the entire sustained disallowance, reaffirming that such income does not trigger Section 14A.
ITAT Delhi ruled that disallowance under Section 14A cannot be made without AO recording satisfaction under Section 14A(2), fully deleting ₹23.38 lakh claimed from exempt dividend income.
The Tribunal ruled that AMP expenses incurred by a brand-owning trader cannot be allocated to contract manufacturers without proof of obligation or agreement. Tax incentives enjoyed by related entities alone were held insufficient.
