SESHADRI VISHWANATH,NAVI MUMBAI vs. ACIT CIRCLE 34(3), MUMBAI
What were the facts?
The assessee claimed exemption for dividend income, but the Assessing Officer reopened the assessment due to the introduction of Section 115BBDA, making dividend income above ₹10 lakhs taxable. The assessee also claimed a deduction under Section 80G, which was disallowed for lack of receipts.
What did the Tribunal hold?
The Tribunal held that Section 14A disallowance is applicable as dividend income exceeding ₹10 lakhs is taxable under Section 115BBDA, and the disallowance under Rule 8D(2)(ii) for investment is justified. The disallowance of the Section 80G deduction was also upheld due to the failure to furnish supporting receipts.
What were the issues?
Whether disallowance under Section 14A is warranted when dividend income is taxable under Section 115BBDA, and whether the Section 80G deduction is allowable without proper substantiation.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI
Before: SHRI CHALLA NAGENDRA PRASAD & SHRI MAKARAND VASANT MAHADEOKAR
PER SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER:
This appeal is filed by the assessee against the order of the Addl./Joint Commissioner of Income Tax (Appeals)-1, Visakhapatnam, dated 28.01.2026 for the assessment year 2017-18. 2. The assessee in its appeals has raised the following grounds of appeal.
ITA 3238/MUM/2026 SESHADRI VISHWANATH
“The lea
The order continues below.
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