“section 14A disallowance”

DisallowancesSection 14ASection 14A169 judgments

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

ITA 1782/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 14A(2)

light of numerous High Court decisions and the Supreme Court's dismissal of SLPs for AY 2017-18, strongly supports the principle that Section 14A disallowance is not attracted for investments that did not yield exempt income during the year. Furthermore, the availability of sufficient own funds generally negates

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

ITA 1781/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Section 143(1)Section 143(2)Section 143(3)Section 14A

light of numerous High Court decisions and\nthe Supreme Court's dismissal of SLPs for AY 2017-18, strongly supports the\nprinciple that Section 14A disallowance is not attracted for investments that did\nnot yield exempt income during the year. Furthermore, the availability of\nsufficient own funds generally negates

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

Consequently, the adjustment made by the Assessing Officer to the book profit under section 115JB on account of section 14A disallowance is also directed to be deleted. The grounds of appeal raised by the Revenue are, therefore, dismissed.” 11.3 In the year under consideration, the facts and circumstances remain identical

DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 1560/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

{ "clean_text": "आयकर अपीलीय अधिकरण न्याय पीठ मुंबई में।\nIN THE INCOME TAX APPELLATE TRIBUNAL\n“H” BENCH, MUMBAI\nBEFORE

ICICI BANK LTD,MUMBAI vs. DCIT 2(3)(2), MUMBAI

Appeal is partly allowed

ITA 1446/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

{ "clean_text": "आयकर अपीलीय अधिकरण न्याय पीठ मुंबई में।\nIN THE INCOME TAX APPELLATE TRIBUNAL\n“H” BENCH, MUMBAI\nBEFORE

JINDAL PIPES LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI

In the result, the appeal of the assessee is allowed and\nappeal of the Revenue is dismissed

ITA 3661/DEL/2023[2020-21]Status: DisposedITAT Delhi16 Feb 2026AY 2020-21

Section 143(3)Section 14ASection 37Section 37(1)

services, the Tribunal found that the assessee had provided extensive documentary evidence and that the AO's contentions were based on conjecture. Regarding Section 14A disallowance, the Tribunal reiterated that it cannot exceed the exempt income and followed jurisdictional High Court decisions. The Tribunal also noted that the AO failed

BAJAJ CONSULTANTS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), MUMBAI

In the result the appeal of the assessee is dismissed

ITA 2676/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Ms. Srushti ChawdaFor Respondent: 17/12/2025

Section 14A

finding Department had challenged the alternative finding of the CIT(A) and not the finding related to section 14A disallowance. related to section 14A disallowance. This is evident from the para 8 of the order of This is evident from the para 8 of the order

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

Section 14ASection 250

ground that\nsuch investments were \"capable of generating exempt income.\" It is now\nwell settled position that for the purpose of section 14A, disallowance must\nbe made not only in respect of investments which actually yield exempt\nincome during the year but also in respect of investments which are capable ... income. The CIT(A) deleted the addition of the capital subsidy but sustained the disallowance under Section 14A.", "held": "The Tribunal held that Section 14A disallowance can only be made if there is exempt income. Since the assessee did not earn any exempt income during the assessment year, the disallowance

DCIT, NEW DELHI vs. PRUDENTIAL HOTELS PVT. LTD., DELHI

In the result both the grounds raised by the revenue are dismissed

ITA 2936/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. DR

Section 143(2)

that the assessee discharged its\nonus and provided the identity, genuineness and creditworthiness of the\nperson returned the advances.\n12. With regard to Section 14A disallowances, after considering the detailed\nsubmissions of the assessee Ld. CIT(A) observed that there was no\nexempt income earned during the year ... nAfter considering the detailed findings of the Ld. CIT(A) we do not see\nany reason to disturb the same.\n15.With regard to Section 14A disallowances, we observed that assessee has\nnot earned any exempt income and further assessee has claimed\nexpenditure of Rs.82,068/- only. Therefore the Section 14A

M/S. TOPGRAIN CORPORATE SERVICE PVT. LTD.,KOLKATA vs. I.T.O., WARD - 4(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2276/KOL/2025[2017-2018]Status: DisposedITAT Kolkata05 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 10Section 10(34)Section 10(38)Section 11Section 115JSection 12Section 14Section 14ASection 234BSection 234C

LTCG is to be added. We also gone through the cited Special Bench decision in Vireet Investment (supra) wherein it was held that section 14A disallowance cannot be added to Book Profit u/s 115JB and disallowance under Section 14A could not be added back while computing book profits under Section

ACIT, MUMBAI vs. RAHEJA UNIVERSAL PVT LIMITED, MUMBAI

In the result, the appeal of the Revenue is partly allowed for statistical purposes whereas the cross-objection of the assessee is allowed for statistical purposes

ITA 5344/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Feb 2026AY 2018-19

Section 143(2)Section 143(3)Section 14ASection 14A(2)Section 36(2)

filed a cross-objection regarding the inclusion of income under Section 44AE.", "held": "The Tribunal upheld the CIT(A)'s decision to restrict Section 14A disallowance to the extent of exempt income earned. The Tribunal also dismissed the Revenue's grounds regarding bad debt deduction for the loan

KARUPPANNA GOUNDER PARAMASIVAM,ERODE vs. DCIT, CIRCLE-1, ERODE, ERODE

In the result, appeal filed by the assessee is allowed for statistical

ITA 3363/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Jan 2026AY 2017-18

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Appellant: MR. S. Senthil Kumar, Adv

Section 143(3)Section 14ASection 69

opportunity to appear and file the relevant evidence/documents before the Ld. CIT(A) to substantiate the addition of cash deposit and issue of section 14A disallowance. 8. Accordingly, the impugned order is set aside and the appeal is restored back to the file of the Ld.CIT(A) for hearing

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

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

Section 143(3)Section 43(1)

affect this claim as the goodwill arises for the first time post-amalgamation. The Tribunal also dismissed the grounds related to Section 14A disallowance and transfer pricing issues.", "result": "Allowed", "sections": [ "Sec 14A", "Sec 92CA(3)", "Sec 92C(3)", "Sec 43(1)", "Sec 43(6)", "Sec 32(1)(ii)", "Rule

DELITE INFRASTRUCTURE PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 7(1), DELHI, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 954/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Section 143(3)Section 14ASection 250

confirmed the addition.", "held": "The Tribunal observed that borrowed funds were not utilized for investments in mutual funds yielding dividend income, making the Section 14A disallowance contrary to facts. The claim for interest paid on loans as expenses against capital gains was also disallowed and allowed to be carried forward

ACIT-CC-7(3), MUMBAI vs. LODHA DEVELOPERS LIMITED (FORMERLY KNOWN AS MACROTECH DEVELOPERS LIMITED), MUMBAI

In the result, the appeal filed by the Revenue is partly\nallowed for statistical purposes

ITA 4754/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Jan 2026AY 2016-17

Section 115JSection 143(3)Section 14ASection 250

average value of investments only to such\ninvestments which had yielded exempt income during the year.\n5. On the issue of applicability of section 14A disallowance to\nthe computation of book profit under section 115JB, the CIT(A)\nrecorded that no disallowance of direct expenditure under Rule ... disallowance of direct expenditure under Rule\n8D(2)(i), no addition could be made to the book profit on account\nof section 14A disallowance.\n25. The learned AR supported the decision of the CIT(A).\n26. We have carefully considered the rival submissions and\nperused the orders of the lower

KAISHAR INTERIORS PRIVATE LIMTIED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2)(2), MUMBAI

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi

Section 143(3)Section 147Section 148Section 14A

erred in confirming the additions made by the Ld. AO at Rs. 55,88,020/- comprising bogus purchases at Rs. 39,25,193/-, Section 14A disallowance at Rs. 31,935/-, and motor car expenses at Rs. 16,30,892/-. On Jurisdiction to issue notice

VIKUNJ REAL ESTATE PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, DELHI

In the result, the appeal filed by the assessee is dismissed

ITA 3179/DEL/2025[2011-12]Status: DisposedITAT Delhi22 Dec 2025AY 2011-12

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Shyam Sunder Mangla, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR

Section 143Section 143(3)Section 148Section 263Section 41(1)

expense, reassessment being mere change of opinion of Assessing Officer on same set of facts was not justified . INCOME TAX: Where issue of section 14A disallowance was very much there before Assessing Officer during assessment proceedings and Assessing Officer made no addition on account of disallowance under section 14A, reopening

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

could be claimed only through a revised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally, the AO added the section 14A disallowance to book profit under section 115JB, relying on Explanation 1(f), and completed assessment by computing MAT income at ₹318.57 crore, which was higher ... computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order, the CIT(A) first dealt with the section 14A disallowance. After analyzing the assessee’s contention that no expenditure had been incurred and that own funds were sufficient, the CIT(A) noted that

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

Appeal are dismissed

ITA 914/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

could be claimed only through a\nrevised return as per Goetze (India) Ltd. and CBDT Circular No. 549. Finally,\nthe AO added the section 14A disallowance to book profit under section\n115JB, relying on Explanation 1(f), and completed assessment by\ncomputing MAT income at ₹318.57 crore, which was higher

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

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