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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 189 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 87 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 378 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 186 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


Without receipt of exempted income, Section 14A cannot be invoked

December 14, 2014 1458 Views 0 comment Print

Assessee engaged in the business of real estate and construction had filed its return for AY; 2009-10 declaring an income of Rs.55,45,092/-and for AY: 2010-11 and an income of Rs.8,07,253/-. During the course of assessment proceedings

No disallowance u/s 14A, where assessee have sufficient own funds for making investment

October 24, 2014 1973 Views 0 comment Print

We could notice from the record that the assessee was having share holding funds to the extent of 2607.18 crores and the investment made by it was to the extent of Rs. 195.10 crores. In other words, the assessee had sufficient funds for making the investments and it has not used the borrowed

If AO not satisfied with correctness of expenditure claimed, he has to proceed in manner prescribed in Rule 8D(2)

September 28, 2014 2212 Views 0 comment Print

In the present case, the Assessing Officer has noted that the assessee had invested a certain amount of its funds in shares and that the dividend which has been received or receivable did not form part of the total income.

Disallowance U/s. 14A cannot exceed expenditure claimed as a deduction

August 23, 2014 5169 Views 0 comment Print

We find from the audit report that the expenses in respect of exempt income was shown at Rs. Nil,that the assessee had debited direct expenses on account of dematerialisation and STT in the capital account and in the profit and loss account,that AO had presumed that the assessee had must

No Disallowance under section 14A If Own Funds Exceed Borrowed Funds

August 2, 2014 9221 Views 0 comment Print

Issue – Whether on the facts and in law, the Hon’ble Tribunal was correct in holding that the investment in tax free securities/investments are represented by assessee’s own funds in the shape of share capital and reserves, ignoring the fact that the assessee is a bank involved in transactions

No disallowance U/s 14A if there is no exempt income

July 31, 2014 3832 Views 0 comment Print

Counsel for the assessee submits that assessee has not received any exempt income and in the absence of the assessee receiving any exempt income, there is no justification in deriving expenses attributable for earning income which is not received by the assessee.

Sec 14A – Disallow only directly related Expense; Disallowance should not exceed tax on Exempt Income – ICAI

June 27, 2014 33812 Views 0 comment Print

ICAI Suggestion on Disallowance of expenditure incurred in relation to income not includible  in total income under section 14A  of the Act: As per the existing provisions of section 14A of the Act, no deduction shall be allowed in respect of expenditure incurred by a taxpayer in relation to income which does not form part […]

Section 14A – Investment not resulting in any exempt income cannot be considered for of disallowance under Rule 8D(2)(i)

June 27, 2014 6868 Views 0 comment Print

Definition of ‘total income u/s 2(45) refers to section 5 which envisages ‘scope of total income’. On a reading of section 5 of the IT Act, it would be evident that as per this section ‘total income’ is of any previous year and which includes income from

No disallowance U/s. 14A relating to expenditure attributable to dividend and tax-free interest, etc.

May 28, 2014 1457 Views 0 comment Print

As regards disallowance under section 14A of the Income-Tax Act, 1961 (the Act), it is well-known that in respect of correct interpretation of the same, divergent views have been expressed by various judicial fora. In this context, please refer to the Article authored by me under the title “Disallowance under section 14A, in the light of the case of Deepak Mittal”, which has been published in 361 ITR (Journ.) P.1 (Part.1)

Section 14A have no application if Assessee not made any claim for exemption

May 25, 2014 4012 Views 0 comment Print

Sub­section(1) of section 14A provides that for the purpose of computing total income under chapter IV of the Act, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the total income under the Act.

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