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“section 14A disallowance”

DisallowancesSection 14ASection 14A169 judgments

The decision most relied on for section 14A disallowance is CIT v. Reliance Petroproducts Pvt. Ltd. (322 ITR 158), cited in 2,228 judgments on BharatTax.

Leading authorities on section 14A disallowance

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

ACIT v. Vireet Investment Pvt. Ltd.
165 ITD 27 · 2017 · ITAT
882
citing judgments

No disallowance under section 14A can be made while computing book profits under section 115JB unless the expenditure is debited to the profit and loss account and satisfies clause (f) of Explanation 1 to section 115JB(2).

Judgments citing section 14A disallowance

Besmak Components P Ltd, Kanchipuram vs. ACIT, Corporate Circle 1(2), Chennai

The appeal of the assessee is allowed

ITA 3373/CHNY/2025[2016-17]Status: DisposedITAT Chennai06 Feb 2026AY 2016-17

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3373/Chny/2025 निर्धारण वर्ष / Assessment Year: 2016-17 Besmak Components P. Ltd., Plot No.A-45, Sipcot Industrial Vs. Growth Centre, Sriperumbudur, Oragadam, Kanchipuram District – 602 105. Pan: Aaacb 2531N (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से /Respondent By The Asst. Commissioner Of Income Tax, Corporate Circle-1(2), Chennai. (प्रत्यर्थी/Respondent) Mr. M.K. Rangaswamy, C.A Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 28.01.2026 घोषण की तारीख /Date Of Pronouncement 06.02.2026 आदेश / Order Per Padmavathy.S, A.M: This Appeal By The Assessee Is Against The Order Of The Commissioner Of Income Tax (Appeals), Addl./Jcit(A), Agra (In Short "Faa") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") Dated 09.06.2025 For

Section 14ASection 250

ground that such investments were "capable of generating exempt income." It is now well settled position that for the purpose of section 14A, disallowance must be made not only in respect of investments which actually yield exempt income during the year but also in respect of investments which are capable

Assisstant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R