ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

ITA 5349/MUM/2025Status: DisposedITAT Mumbai31 October 2025AY 2014-15Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)7 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A is not warranted when the assessee has not earned any exempt income. The amendment to Section 14A by the Finance Act, 2022, is prospective and not applicable to the assessment years under consideration.

What were the facts?

The Assessing Officer disallowed expenses under Section 14A of the Income Tax Act, 1961, amounting to Rs. 3,14,55,653, despite the assessee not earning any exempt income. The CIT(A) deleted this disallowance, holding that no disallowance is warranted without exempt income.

What were the issues?

Whether disallowance under Section 14A is permissible when no exempt income is earned by the assessee. Applicability of the amendment to Section 14A by the Finance Act, 2022.

Which sections of the Income-tax Act were involved?

Section 14A,Section 143(3),Section 115JB,Section 250

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Cases cited in this judgment(25)Show list

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Income Tax Appellate Tribunal, “E” BENCH, MUMBAI

Before: SHRI VIKRAM SINGH YADAV, AM

For Appellant: Shri Madhur Agrawal
For Respondent: Shri Hemanshu Joshi, SR DR
Hearing: 27.10.2025Pronounced: 31.10.2025

Per Kavitha Rajagopal, J M: The captioned appeals have been filed by the revenue, challenging the order of the learned Commissioner of Income Tax (Appeals) 52, Mumbai (‘ld.CIT(A)’ for short), passed u/s.250 of the Income Tax Act, 1961 (‘the Act'), pertaining to the Assessment Year (‘A.Y.’ for short) 2014-15 & 2015-16. 2. As the facts are identical, we hereby pass a consolidated order by taking ITA No. 5349/Mum/2025, relevant to A.Y. 2014-15 as a lead case.

3.

The solitary ground of appeal pertains to the disallowance u/s. 14A of the Act which was deleted by the ld. CIT(A) on the ground that no disallowance u/s. 14A is ITA No. 5349 & 5350/Mum/2025 (Assessment Years: 2014-15

The order continues below.

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