FAHIM SULTAN ALI, RAJNANDGAON,RAJNANDGAON vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

ITA 349/RPR/2026Status: DisposedITAT Raipur21 July 2026AY 2013-1415 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that Section 14A can only be invoked if the assessee has earned income which does not form part of the total income. Since the assessee did not earn any exempt income, the disallowance under Section 14A was not warranted.

What were the facts?

The assessee claimed no exempt income, such as dividend income, was earned during the assessment year. The Assessing Officer (AO) disallowed expenditure under Section 14A, which was upheld by the CIT(Appeals).

What were the issues?

Whether disallowance under Section 14A is permissible when the assessee has not earned any exempt income.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: Shri Bikram Jain, CA
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 13.07.2026Pronounced: 21.07.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals), Raipur-3 dated 26.02.2026 for the assessment year 2013-14 as per the grounds of appeal on record.

2.

It is the case of the assessee that he was not having any exempt income in the form of dividend during the year and therefore, prime contention for invoking Section 14A of the Income Tax Act, 1961 (for s

The order continues below.

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