“disallowance under section 14A”

DisallowancesSection 14ASection 14A2,288 judgments

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

Leading authorities on disallowance under section 14A

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 disallowance under section 14A

Maharashtra Airport Development Company Limited, Mumbai vs. ACIT, Circle-3(2)(1), Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 37/MUM/2024[2016-17]Status: DisposedITAT Mumbai09 Sept 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Prabhash Shankar

For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Ritesh Misra, (CIT DR)

Section 143(3)Section 57

PCIT vs. Era Infrastructure (India) Ltd. (2022) 141 taxmann.com 289 (Delhi). Similarly, when there is no disallowance under the normal provisions no disallowance under section 14A readwith rule 8D under MAT provisions is sustainable as has been held by Hon'ble Bombay High Court in case

DCIT, C-V, Ludhiana vs. M/S Hero Cycles Ltd., Ludhiana

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

ITA 588/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh08 Sept 2025AY 2012-13

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

For Appellant: Shri Ashwani Kumar, Shri Ashish Aggarwal &For Respondent: Shri Manav Bansal, CIT, DR

Section 10(38)Section 143(1)Section 14ASection 36(1)(iii)

provisions of section 14A of the Act read with Rule 8D of the Income Tax Rules 1962. The A.O. worked out the disallowance under section 14A of the Act at Rs.14,15,10,213/-, the calculations are given at page no. 22 & 23 of the aforesaid assessment order. 6. Being ... generated or available with the company if the interest free funds were sufficient to meet the investment.” 9. Therefore, in such circumstances, no disallowance under section 14A of the Act on account of interest can be made. Though the learned counsel for the assessee has made alternative submissions

M/S Hero Cycles Ltd., Ludhiana vs. ACIT, C-V, Ludhiana

ITA 473/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh08 Sept 2025AY 2012-13

For Respondent: Shri Ashwani Kumar, Shri Ashish Aggarwal &

Section 10(38)Section 143(1)Section 14ASection 36(1)(iii)

provisions of section 14A of the Act read with Rule 8D of the Income Tax Rules 1962. The A.O. worked out the disallowance under section 14A of the Act at Rs.14,15,10,213/-, the calculations are given at page no. 22 & 23 of the aforesaid assessment order. 6. Being ... generated or available with the company if the interest free funds were sufficient to meet the investment." 9. Therefore, in such circumstances, no disallowance under section 14A of the Act on account of interest can be made. Though the learned counsel for the assessee has made alternative submissions

Assistant Commissioner of Income Tax, Corporate Circle 1 1, Chennai vs. Idfc Limited, Chennai

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

ITA 1649/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Sept 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1649/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 The Acit, Idfc Limited, Corporate Circle 1 (1), Vs. Krm Towers, Chennai. 7Th Floor, No.1, Harrington Road, Chetpet, Chennai – 600 031. Pan: Aaaci 2663N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shiva Srinivas, Cit ""यथ" क" ओर से/Respondent By : Shri Ketan K. Ved, Ca (Through Virtual Mode) सुनवाई क" तारीख/Date Of Hearing : 02.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 03.09.2025

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri Ketan K. Ved, CA

Section 10Section 143(3)Section 14ASection 250Section 260A

that of earlier and subsequent years, respectfully following the Hon’ble ITAT order for A.Y. 2016-17, it is held that no disallowance under Section 14A of the Act with respect to interest cost is called for on such investments subject to verification of the details (regarding own funds

Star Chemicals Bombay Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 3(3)(2), Mumbai

ITA 4388/MUM/2025[2017-18]Status: DisposedITAT Mumbai03 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Swapnil Choudhary, Sr. DR

Section 115JSection 14ASection 154Section 250

Bombay Pvt. Ltd. dated 13.06.2025 for AY 2018-19. The common grounds raised by the assessee for both the AYs pertain to the disallowance under section 14A r.w.r. 8D and the adjustment of the said disallowance to the book profits under section 115JB of the Act. 2. The assessee ... moto disallowed STT expenses over and above 14A disallowance computed by assessee. However the AO has mechanically proceeded to compute the notional disallowance under Section 14A read with Rule 8D. Rule 8D can be invoked only if the AO having regard to the accounts of the assessee, is not satisfied

Star Chemicals Bombay Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 3(3)(1), Mumbai

ITA 4387/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Swapnil Choudhary, Sr. DR

Section 115JSection 14ASection 154Section 250

M/S. Gateway Distriparks Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 2(1), Mumbai

The appeal of the assessee is allowed

ITA 3300/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Ashok Kumar Jain, ARFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 115JSection 139(1)Section 143(1)Section 143(3)Section 14ASection 154Section 250

impugned issue the ld. AR submitted that for AY 2016-17 and 2017-18 the CIT(A) has decided the issue pertaining to disallowance under section 14A in favour of the assessee and that the revenue filed further appeal before the Tribunal against the said order. The ld. AR further ... order of Reliance Power Ltd (supra) we find that the Ld. CIT(A) has rightly accepted the assessee's computation and restricted the disallowance under section 14A of the Act to Rs.59,50,496/-which is in accordance with the law applicable to the assessment year under consideration. M/s Gateway

Maruti Traders & Investors, Kolkata vs. ACIT, Circle 35, Kolkata

ITA 959/KOL/2025[2016-2017]Status: DisposedITAT Kolkata01 Sept 2025AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

IN THE INCOME TAX APPELLATE TRIBUNAL 'SMC' BENCH KOLKATA Before Shri Sonjoy Sarma, Judicial Member and Shri Rakesh Mishra, Accountant

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. Ambattur Clothing Private Limited, Tiruvallur

In the result, the appeal filed by Revenue is dismissed

ITA 1663/CHNY/2025[2011-12]Status: DisposedITAT Chennai29 Aug 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1663/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 The Assistant Commissioner Of Vs. Ambattur Clothing Private Limited, Income Tax, 86/E2, Industrial Estate, Corporate Circle 1(1), Ambattur Industrial Estate S.O., Chennai. Ambattur, Thiruvallur 600 058. [Pan:Aaaca4127D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Rajakumar, Addl. Cit ""थ" की ओर से/Respondent By : Shri Vinay Jain, Ca सुनवाई की तारीख/ Date Of Hearing : 26.08.2025 घोषणा की तारीख /Date Of Pronouncement : 29.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 31.12.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai For The Assessment Year 2011-12. 2. We Find That This Appeal Is Filed With A Delay Of 67 Days. The Appellant-Revenue Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Revenue Are Bonafide, Which 2

For Appellant: Shri N. Rajakumar, Addl. CITFor Respondent: Shri Vinay Jain, CA

Section 14A

assessee company that it has investments capable of earning dividend income. After considering the submissions of the assessee, the Assessing Officer determined the disallowance under section 14A r.w. Rule 8D at ₹.5,87,37,582/- and added to the total income of the assessee. On appeal ... I.T.A. No.1663/Chny/25 5. The ld. DR Shri N. Rajakumar, Addl. CIT submits that the ld. CIT(A) erred in holding that the disallowance under section 14A of the Act could not exceed exempt income earned by the assessee ignoring the amendment brought in by Finance Act, 2022 in section 14A

ACIT Central Circle 8(3), Mumbai vs. Rosy Blue (India) Private Limited, Mumbai

In the result, the appeal of the Revenue is partly allowed in terms indicated above

ITA 4284/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Aug 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 143(3)Section 144Section 144CSection 14ASection 92BSection 92C

year under consideration. It has been claimed that the Assessing Officer, in addition to the suo-moto disallowance by appellant computed a further disallowance under Section 14A of the Act read with Rule 8D(2)(ii) @ 1% investment of Rs.97,10,05,142/- on which no exempt income is received ... that only those investments from which exempt income has been earned during the year, ought to be considered for the purpose of computing disallowance under Section 14A r.w.r. 8D. The relevant extract of the order, as submitted by the appellant is as under: “12.3. The ld. AR argued before

International Tractors Ltd., Delhi vs. DCIT, New Delhi

Accordingly. Accordingly, this ground is allowed for

ITA 160/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Aug 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘F’”: NEW DELHI) BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI KRINWANT

International Tractors Ltd., New Delhi vs. DCIT (Ltu), New Delhi

Accordingly. Accordingly, this ground is allowed for

ITA 3519/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Aug 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member

For Appellant: Sh. Shankey Agrawal, Adv., Nikky Jhamtani, CA, ShFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 35Section 37Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘F’”: NEW DELHI) BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI KRINWANT

Rajasthan Industries Ltd, Kolkata vs. DCIT, Cir. -5(1), Kolkata

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

ITA 267/KOL/2024[2017-18]Status: DisposedITAT Kolkata28 Aug 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 267/Kol/2024 Assessment Year: 2017-2018 Rajasthan Industries Limited,…….…...……Appellant Birla Building, 11Th Floor, 9/1, R.N. Mukherjee Road, B.B.D. Bagh, Kolkata-700001 [Pan:Aabcr3997B] -Vs.- Deputy Commissioner Of Income Tax,…....Respondent Circle-5(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069

Section 142(1)Section 143(2)Section 14A

disallowed a sum of Rs.1,30,821/- under section 14A read with the Rule 8D, the balance amount of Rs.6,82,775/- was disallowed under section 14A read with Rule 8D by the ld. Assessing Officer and added to the total income of the assessee. Finally, ld. Assessing Officer determined ... appeal of the assessee by relying judgment of different Hon’ble High Courts saying that if there is no exempt income, no disallowance under section 14A can be made. 4. On being aggrieved, the assessee preferred an appeal before the Tribunal and raised the following ground:- “The ld. CIT(Appeals

Arusuvai Food Processors Pvt. Ltd., Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 416/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, Advocate

Section 133(6)Section 142(1)Section 143(3)Section 264Section 270ASection 270A(1)Section 270A(9)(a)Section 270A(9)(c)Section 271Section 41(1)

This Court is of the opinion that the only addition in the assessment order framed by Respondent No.1 is in respect of disallowance under section 14A of the Act. The Petitioner has made a disallowance of Rs.3,20,14,010/- which was recomputed by the Assessing Officer at Rs.6 ... well as assessee has used the same details to arrive at different conclusions i.e. differing quantum of disallowances under Section 14A of the Act. This by no stretch of imagination can be held to be ‘misreporting’. 8. This Court also finds that there is not even a whisper

Bounteous Digital Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Chennai

In the result, the appeal filed by the assessee is partly allowed

ITA 1600/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1600/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Bounteous Digital Private Limited, Vs. The Deputy Commissioner Of Block A, 8Th Floor, Global Infocity Park Income Tax, No. 40, Mgr Salai, Perungudi, Corporate Circle 4(1), Chennai 600 096. Chennai. [Pan:Aaacl6079R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri A.R. Raghunathan, Ca (Virtual) ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.08.2025 घोषणा की तारीख /Date Of Pronouncement : 28.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.02.2025 Passed By The Addl/Jcit(A) – 10, Mumbai For The Assessment Year 2017-18. 2. The First Issue Raised By The Assessee Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Disallowance Of Csr Expenses In The Facts & Circumstances Of The Case.

For Appellant: Shri A.R. Raghunathan, CA (Virtual)For Respondent: Shri C. Sivakumar, Addl. CIT

Section 143(2)Section 30Section 36Section 37Section 37(1)Section 80G

made by the Assessing Officer and also rejected the rectification petition filed under section 154 of the Act dated 21.03.2025 towards confirmation of disallowance under section 14A of the Act. 11. Having heard both the parties, we note that the Assessing Officer invoked the provisions of Rule

The Cosmos Co-Op Bank Ltd Successor in the Interest of the National Co-Op Bank Ltd, Pune vs. Dc/ACIT Circle-5(1)(1), Blr, Bengaluru

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

ITA 1267/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Aug 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2018-19 Cosmos Co-Operative Bank Ltd., Vs. Dc/Acit, (Maharashtra), Circle – 5(1)(1), Successor In Interest For The National Co- Bangalore. Opeartive Bank Ltd., Plot No.6, S No.132/B, Cosmos Tower, Ganeshkhind, University Road, Ics Colony, Pune, Maharashtra, India 411 007. Pan : Aaaat 0742 K Appellant Respondent Assessee By : Shri. Sumath Sudarshan,Advocate Revenue By : Shri. Srinandini Das, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 14.08.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Sumath Sudarshan,AdvocateFor Respondent: Shri. Srinandini Das, CIT(DR)(ITAT), Bangalore

Section 143(2)Section 14A

disallowance has been made under section 14A of the Act. Therefore, the AO, after considering the submission of the assessee, calculated disallowance under section 14A of the Act of Rs.10,00,14,000/-. Further, the AO noted that the assessee has claimed amortization of premium of investment of Rs.3

Dy. Commissioner of Income Tax, Central Circle 3(4), Mumbai vs. Nippon Life India Asset Management Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3887/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Aug 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nSHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 14A

following grounds: “1. On the facts and in the circumstances of the case, the learned CIT(A) erred in directing to recompute the disallowance under section 14A of the Income Tax Act, 1961 by considering only those investments which yielded exempt income, without considering the provision of section 14A ... ignoring the fact that against a similar decision of the Hon'ble Special Bench of the ITAT, Delhi on the issue of disallowance under section 14A in the case of ACIT vs. જે Vireet Investments Pvt. Ltd. [165 ITD 27 (Del)(SB)], the Department has filed further appeal before

Deputy Commissioner of Income Tax Circle 1(1)(1) Vadodara, Vadodara vs. M/S. Inox Wind Energy Limited, Vadodara

In the result, the appeal filed by the Revenue stands dismissed

ITA 654/AHD/2025[2015]Status: DisposedITAT Ahmedabad26 Aug 2025

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.654/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 The Deputy Commissioner M/S. Inox Wind Energy Of Income Tax, बनाम/ Limited, V/S. Circle-1(1)(1), Abs Tower S. No.1837 & Vadodara. 1834, Op Road, Vadodara-390007. (Gujarat) "थायी लेखा सं./Pan: Aafc14628K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Rignesh Das, Cit-Dr Assessee By : Shri Bandish Soparkar, Ar सुनवाई की तारीख/Date Of Hearing : 21/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income-Tax (Appeals)-11, Ahmedabad [Hereinafter Referred To As “The Cit(A)”] Dated 27.01.2025, Arising Out Of The Assessment Order Passed By The Assessing Officer Under Section 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], On 18.12.2017 For The Assessment Year 2015-16. Dcit Vs. Inox Wind Energy Limited Assessment Year 2015-16

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 14A

addition of Rs. 5,32,41,825/- made under section 14A read with Rule 8D under the normal provisions, holding that the disallowance under section 14A read with Rule 8D cannot exceed the exempt income, in the absence of any such restriction being there in the relevant section or rule ... Infrastructure (India) Ltd. [2022] 448 ITR 674 (Delhi), wherein it has been held that in the absence of exempt income, no disallowance under section 14A is permissible. The AR also relied upon the amendment brought in by the Finance Act, 2022 in section 14A, submitting that the amendment is prospective

G R N Finsec Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 5341/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Aug 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary

Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)

make any further disallowance over and above what has been made suo-moto by the assessee. In other words, the disallowance under Section 14A r/w Rule 8D is to be restricted to an amount of Rs 1,77,078/- as suo-moto done by the assessee and disallowance made over ... facts and circumstances of the case and in law and without prejudice to ground no.1, the appellant submits that in computing the disallowance under section 14A read with Rule 8D, only those investments on which dividend has been received ought to have been considered. Ground No. 5 On the facts

G R N Finsec Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - Circle 1(1)(2), Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 5329/MUM/2024[2015-16]Status: DisposedITAT Mumbai26 Aug 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary

Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)