DCIT, CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD vs. ADANI TOTAL GAS LIMITED, AHMEDABAD

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ITA 785/AHD/2026Status: DisposedITAT Ahmedabad22 June 2026AY 2020-215 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that since the assessee did not earn any exempt income during the relevant assessment year, the disallowance under Section 14A could not be invoked. The amendment to Section 14A, which allows disallowance even without exempt income, was held to be prospective.

What were the facts?

The Assessing Officer (AO) made a disallowance of Rs. 2,38,25,000/- under Section 14A read with Rule 8D. The assessee contended that no exempt income was earned during the year, and therefore, no disallowance was warranted.

What were the issues?

Whether disallowance under Section 14A can be made when no exempt income is earned by the assessee. Applicability of the prospective amendment to Section 14A.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: DR. B.R.R. KUMAR, VICE- & SHRI RAHUL CHAUDHARY

For Appellant: Shri Dhrunal Bhatt, AR
For Respondent: Shri Abhijit, Sr.DR
Hearing: 10.06.2026Pronounced: 22.06.2026

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. संबंिधत आयकर आयु� / Concerned CIT 3. 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file.

आदेशानुसार/ BY ORDER, True Copy

सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad

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