“disallowance under section 14A”

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

lacs on account of levy of interest rates on issue of comfort letter. The assessing officer also made addition / disallowance under section 14A, depreciation on leased asset, disallowance of bad debt, business expenses disallowance of loss and other expenses, disallowance of depreciation on fixed asset capitalised on 31.03.2009. By making ... allowed substantial relief to the assessee on various additions and disallowances viz; transfer pricing adjustment, on disallowance under section 14A, on bad debt, business loss. ICICI Bank Limited ITA No. 1550/Mum/2016 (AY 2009-10) Further aggrieved both the parties have filed their respective appeals taking various grounds of appeal

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

lacs on account of levy of interest rates on issue of comfort letter. The assessing officer also made addition / disallowance under section 14A, depreciation on leased asset, disallowance of bad debt, business expenses disallowance of loss and other expenses, disallowance of depreciation on fixed asset capitalised on 31.03.2009. By making ... allowed substantial relief to the assessee on various additions and disallowances viz; transfer pricing adjustment, on disallowance under section 14A, on bad debt, business loss. ICICI Bank Limited ITA No. 1550/Mum/2016 (AY 2009-10) Further aggrieved both the parties have filed their respective appeals taking various grounds of appeal

Oceanic Marketing Agencies India Ltd, Mumbai vs. Dy. Commissioner of Income Tax Central Circle -2(2), Mumbai

In the result ITA No. 4542/Mum/2025 is dismissed as

from A.Y.2009-10) are applicable in respect of STCG whereas no tax is chargeable in respect of LTCG. 20. On the issue of disallowance under section 14A we find that the Assessing Officer invoked Rule 8D without recording the satisfaction required under section 14A(2). The assessee had claimed only ... been recorded in the assessment order. The approach is mechanical and contrary to settled law. 21. It is also well settled that disallowance under section 14A cannot exceed the expenditure actually claimed. There is nothing on record to show that any further specific expenditure was incurred for earning the exempt

M/S. Oceanic Marketing Agencies India Ltd., Delhi vs. The Dy. Commissioner of Income Tax, (OSD), Circle 2(2), Mumbai

In the result ITA No. 4542/Mum/2025 is dismissed as

from A.Y.2009-10) are applicable in respect of STCG whereas no tax is chargeable in respect of LTCG. 20. On the issue of disallowance under section 14A we find that the Assessing Officer invoked Rule 8D without recording the satisfaction required under section 14A(2). The assessee had claimed only ... been recorded in the assessment order. The approach is mechanical and contrary to settled law. 21. It is also well settled that disallowance under section 14A cannot exceed the expenditure actually claimed. There is nothing on record to show that any further specific expenditure was incurred for earning the exempt

Sanjay Kothari (HUF), Mumbai vs. DCIT, Circle 19(3), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailsanjay Kothari (Huf), 1404, 14Th Floor, A Wing, Naman Midtown, Senapati Bapat Marg, Elphistone West, ............... Appellant Mumbai – 400013 Pan: Aajhs9132A V/S National Faceless Assessment Centre, ……………… Respondent Delhi

best judgment determination, as earlier prevailing, would become applicable. 11. Therefore, we find that the action of the AO in computing the disallowance under section 14A read with Rule 8 of the Rules is in conformity with the law laid down by the Hon’ble Supreme Court in the aforesaid ... year under consideration, the assessee claimed an expenditure of Rs. 69,455/- in its profit and loss account; therefore, the 6 disallowance under Section 14A, read with Rule 8D of the Rules, should be restricted to that extent. 14. Having considered the submissions and perused the material available on record

J.M Financial and Investment Consultancy Service Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16

computation under section 10(38) of the Act. In the computation assessee had suo-motu motu worked out disallowance under section 14A worked out disallowance under section 14A at ₹19,79,144/-, along with Securities Transaction Tax (STT) of , along with Securities Transaction Tax (STT) of , along with Securities Transaction ... submitted that the total disallowance under Thus, it was submitted that the total disallowance under Thus, it was submitted that the total disallowance under section 14A amounting to ₹22,55,878/- comprised ( section 14A amounting to comprised (i) employee cost of ₹3,90,000/-, (ii) Investment Committee expenses

Assisstant Commissioner of Income Tax, Mumbai vs. Centrum Retail Services Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

Bench: BEFORESHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. ANIKESH BANERJEE (Judicial Member)

failed to appreciate that expenses are necessarily incurred to manage and hold investments, and such expenses are disallowable under Section 14A even if no exempt income is actually earned during the year, whereas the appellant held substantial investments of Rs. 281,39,85,058 which are capable of yielding exempt ... failed to consider the binding nature of CBDT Circular No. 5/2014 dated February 11, 2014, which explicitly clarifies that disallowance under Section 14A must be made even in a year where no exempt income has been earned by the assessee.” 3. Brief facts of the case are that the assessee

Nilesh Ishwar Mehta, Mumbai vs. Deputy Commissioner of Income Tax-17(1), Mumbai

In the result, the appeal is of the assessee is partly allowed

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarnilesh Ishwar Mehta V/S. Deputy Commissioner Of 2301/A, 23Rd Floor, बनाम Income Tax-17(1) Parthenon Building, J.P. Room No. 117, Kautilya Road, Mumbai – 400 053, Bhavan, C-41 To C-43, G-Block, Maharashtra Bandra Kurla Complex, Bandra (East), Mumbai 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacpm2417P Appellant/अपीलार्थी .. Respondent/प्रतिवादी

case of Hon’ble Supreme Court in Maxopp Investment Ltd. v. CIT (2018) 402 ITR 640 (SC), in which it was held that disallowance under Section 14A is permissible even in cases where the assessee claims that no expenditure was incurred, if the AO records dissatisfaction. 4. Before

S D Bhalerao Constructions Private Limtied, Mumbai vs. DCIT Circle 3(2)(1), Mumbai

In the result, both appeals of the assessee are treated as allowed for statistical purposes, with the matters restored to the file of the learned CIT(A) for fresh adjudication

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

merits, the assessee has challenged the estimation of profit at 7.5 percent on closing stock for both assessment years, and the disallowance under section 14A. It has been urged that the appellate proceedings before the NFAC were finalized entirely exparte, as the assessee was not aware of any notices, communications ... assessee’s submissions. S.D. Bhalerao Constructions Pvt. Ltd., 8. The issues involved in both years relate to estimation of profit and disallowance under section 14A, which necessarily require a factual evaluation of the accounting records, nature of expenses, and justification for the estimation made. Without a comprehensive appraisal