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“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

Prasad Film Laboratories Private Limited, Hyderabad vs. ACIT., Circle-6(1), Hyderabad

In the result appeal of the assessee is dismissed

ITA 113/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Aug 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Sri V. Siva Kumar, AdvocateFor Respondent: Sri Vinodh Kannan, Sr. AR
Section 10(34)Section 115JSection 14ASection 14A(2)

expenditure incurred for earning non-taxable income is a ground for the Assessing Officer to reject the arguments of the assessee and computing disallowance under section 14A with reference to Rule 8D of I.T. Rules, 1962. The CIT(A) further held that, the object of section 14A is to ensure ... motu disallowance made by the assessee for Rs.5,000/- and applied provisions of Rule 8D of I.T. Rules, 1962 and computed the disallowance under section 14A read with Rule 8D of I.T. Rules, 1962 and made addition of Rs.10,67,172/- @ 1% of annual average of monthly average investments

Compact Agencies Pvt. Ltd., Kolkata vs. DCIT/ACIT, Circle 3(1), Kolkata

Appeal of the assessee is allowed

ITA 1259/KOL/2025[2018-2019]Status: DisposedITAT Kolkata13 Aug 2025AY 2018-2019

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250

reported in 166 taxmann.com 607 (Gauhati). It was further argued by the Ld. AR that it is also a settled position that any disallowance under Section 14A of the Act cannot be used to enhance income for the purposes of section 115JB of the Act. 2.1 The Ld. DR relied ... Court in the case of PCIT Vs. J.J. Glastronics Pvt. Ltd. reported in 446 ITR 712 (Kar) has specifically directed that the amount disallowed under Section 14A could not be added to net profit while computing book profit under Section 115.JB of the Act. Similarly, the Hon'ble Delhi High

Didu Investments Private Limited, Kolkata vs. D.C.I.T., Circle-6(1), Kolkata

The appeal of the assessee is partly allowed

ITA 2585/KOL/2024[2014-15]Status: DisposedITAT Kolkata13 Aug 2025AY 2014-15

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250

been apparently considered therein. Considering the entirety of the facts, I am of the opinion that the tax free income calls for disallowance under section 14A, the AO having duly recorded his satisfaction. 6.2 The application of Rule 8D does not preclude an assessee from contending that ... Court in the case of PCIT Vs. J.J. Glastronics Pvt. Ltd. reported in 446 ITR 712 (Kar) has specifically directed that the amount disallowed under Section 14A could not be added to net profit while computing book profit under Section 115.JB of the Act. Similarly, the Hon'ble Delhi High

M/S T vs. Motor Company Limited, Chennaivs.ACIT Corporate Circle 3 (1), Chennai

ITA 2405/CHNY/2019[2014-14]Status: DisposedITAT Chennai13 Aug 2025AY 2014-14

Bench: Shri Aby T Varkey & Shri Amitabh Shukla

Section 92C(2)

Respectfully following the decision of Special Bench (supra), the AO is directed to verify the computation provided by the assessee andre-compute the disallowance under Section 14A read with Rule 8D(2)(iii) accordingly. This ground is therefore partly allowed..." 15.0 We have noted that the facts of the present

Zodiac Ventures Limited, Mumbai vs. Income Tax Officer- 11 (3) (1), Mumbai

The appeal of the assessee is allowed

ITA 4135/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Aug 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri S. C. Tiwari, AR
Section 143(1)Section 14ASection 199Section 250

section 14A r.w.r.8D cannot be invoked. The assessee submitted that no exempt income has been earned during the year under consideration and therefore disallowance under section 14A cannot be invoked. The assessee further submitted that the investment made is a strategic investment and not made with an intention to earn ... income not forming part of total income. The AO’s reliance on CBDT Circular No. 5/2014 is justified as it clarifies that the disallowance under Section 14A can apply even if no exempt income is earned during the year. (ii) The balance sheet of the appellant shows substantial investments

Shreeji Ceramic Industries, Morbi vs. The Principal Commissioner of Income Tax-1, Rajkot

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

ITA 266/RJT/2024[2015-16]Status: DisposedITAT Rajkot12 Aug 2025AY 2015-16

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144Section 263Section 263o

assessee was selected for limited scrutiny under CASS and the issue which the Commissioner sought to reopen namely, the issue of disallowance under section 14A of the Act, read with rule 8D in respect of the exempt income was not one of the issues which was selected for scrutiny

Prem Devi Baid, Jaipur vs. ITO Ward 6(5), Jaipur, Ncrb, Statue Circle, C-Scheme

In the result, the appeal of the assessee is allowed

ITA 50/JPR/2024[2014-15]Status: DisposedITAT Jaipur12 Aug 2025AY 2014-15

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Dheeraj Borad, CA. Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT, Ld. Sr. DR
Section 10(38)Section 115BSection 14ASection 250Section 57Section 68

case, the ld. AR of the assessee submitted that he did not wish to press Ground No. 7 raised in relation to the disallowance under Section 14A of the Act. Accordingly, Ground No. 7 raised by the assessee is dismissed as not pressed. 5. Brief facts of the case

Ankur Power Project Pvt Ltd, Mumbai vs. Income Tax Officer Ward 15(1)(1), Mumbai

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

ITA 4432/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Aug 2025AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ankur Power Project Pvt. Ltd., Ito Ward 15(1)(1), Office No. 201, 2Nd Floor, Kailash Aayakar Bhavan, Complex, A-2, Wing, Bhandup, Vs. Mumbai-400038. West, S.O. Mumbai-400078. Pan No. Aaica 9913 H Appellant Respondent

For Respondent: None
Section 143(2)Section 14ASection 14A(3)

earned any exempt income during the year under consideration. during the year under consideration. 3.1 The issue whether disallowanc The issue whether disallowance under section 14A of the Act e under section 14A of the Act can be made in the absence of exempt income is no longer ... disallowance under [(2015) 378 ITR 33 (Del)] has held that no disallowance under [(2015) 378 ITR 33 (Del)] has held that no disallowance under section 14A is warranted where no exe section 14A is warranted where no exempt income is earned during mpt income is earned during the relevant assessment

Hdfc Asset Management Company Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 1(1)(1), Aayakar Bhavan, Mumbai

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

ITA 3252/MUM/2025[2021-22]Status: DisposedITAT Mumbai12 Aug 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Prabhash Shankarhdfc Asset Management V/S. Deputy Commissioner Of Company Limited, 2Nd बनाम Income Tax, Circle – Floor, Hdfc House, 165 & 1(1)(1), 5Th Floor, Aayakar 166, H.T. Parekh Marg, Bhavan, Maharishi Karve Backbay Reclamation, Marg, Marine Lines, Churchgate, Mumbai–400020, Mumbai – 400020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach7614L Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Niraj Sheth,ARFor Respondent: Shri Ritesh Misra (CIT DR)
Section 143(3)Section 14ASection 154ASection 234Section 234ASection 234B

HDFC Asset Management Company Limited 2. The grounds of appeal are as under: 1. Re.: Disallowance under section 14A of the Income-tax Act, 1961 (“the Act”); 1.1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the additional ... return of income of Rs. 5,50,000 thereby not accepting the method employed by the Appellant for the purpose of computing disallowance under Section 14A of the Act. 2. Re.: Erroneous ad-hoc addition in the computation sheet of Rs. 212,53,21,151: 2.1. On the facts

ACIT 8(3)(1), Mumbai, Aayakar Bhavan vs. Thirumalai Chemicals Limited, Mumbai

In the result, this ground-3 of CO is allowed for statistical purposes

ITA 4945/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Aug 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankaracit 8(3)(1), Mumbai Vs Thirumalai Chemicals Limited Plot No. 101/102, 2Nd Floor, Aayakar Bhavan, M.K. Road, Mumbai-400 020 Thirumalai House, Road No.29, Sion, Matunga, Mumbai-400 022 Pan: Aaact2015M Appellant Respondent

For Appellant: Shri Dharan GandhiFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(2)Section 143(3)Section 14ASection 250Section 32Section 36(1)(vii)Section 40A(7)Section 43BSection 90

4945/Mum /2024 CO 246/Mum/2024 Thirumalai Chemicals Limited During the assessment proceedings, the Ld.AO had added back under different heads by making disallowance under section 14A of the Act, disallowance under section 40A(7), disallowance under section 36(1)(vii) of the Act. Finally, the total amount disallowed was Rs.8 ... result, the appeal filed by the revenue is dismissed. CROSS OBJECTION No.246/MUM/2024 Ground 1: 18. The Ld.AR argued that the Ld.AO has made disallowance under section 14A of the Act read with rule 8D of the Income-tax Rules, 1963 (in short, ‘the rules’) amount

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

ITA 1185/BANG/2025[2018-19]Status: DisposedITAT Bangalore11 Aug 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K, JUDICIAL MEMBER

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

ITA 1184/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Aug 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K, JUDICIAL MEMBER

Bennett Coleman & Co Ltd, Mumbai vs. DCIT 1(1)(1), Mumbai

In the result, this ground-7 of appeal is dismissed

ITA 190/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17

Bench: Shri. Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Satyaprakash R Singh, CIT DR
Section 10(38)Section 143(3)Section 144(2)Section 14ASection 14A(2)Section 250Section 43C

Rs.35,01,925/-. However, the Ld. AO did not accept the assessee's computation and proceeded to determine the disallowance under section 14A read with Rule 8D of the Income Tax Rules, 1963 [in short, the “Rule”] at Rs.2,16,68,975/-. Consequently, after deducting the amount disallowed ... order of the Ld. CIT(A), the assessee has now filed the present appeal before this Tribunal. Grounds 1 to 4 related to disallowance under section 14A: 5. The Ld. AR advanced arguments and filed a paper book in two sets, comprising pages 1 to 671, which have been placed

Bennett, Coleman & Co Ltd, Mumbai vs. DCIT 1(1)(1), Mumbai

In the result, this ground-7 of appeal is dismissed

ITA 189/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16

Bench: Shri. Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Satyaprakash R Singh, CIT DR
Section 10(38)Section 143(3)Section 144(2)Section 14ASection 14A(2)Section 250Section 43C

Rs.35,01,925/-. However, the Ld. AO did not accept the assessee’s computation and proceeded to determine the disallowance under section 14A read with Rule 8D of the Income Tax Rules, 1963 [in short, the “Rule”] at Rs.2,16,68,975/-. Consequently, after deducting the amount disallowed ... order of the Ld. CIT(A), the assessee has now filed the present appeal before this Tribunal. Grounds 1 to 4 related to disallowance under section 14A: 5. The Ld. AR advanced arguments and filed a paper book in two sets, comprising pages 1 to 671, which have been placed

ACIT (Ltu)-1, Mumbai vs. Union Bank of India, Mumbai

In the result, appeal of the assessee is allowed

ITA 882/MUM/2020[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri C Naresh, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

submissions made by rival sides and have examined the orders of authorities below. The assessee in appeal has raised solitary ground against the disallowance under section 14A r.w.r. 8D of the Act. The Revenue in ground No.1 of the appeal has impugned the finding of CIT(A) in restoring ... Bank (supra) are subsequent to the order of Tribunal. 8. Thus, in the light of the decisions discussed above, we hold that no disallowance under section 14A r.w.r. 8D of the Act is warranted where the assessee has earned exempt income on shares/stocks held as 'stock-in-trade'. Consequently

Income Tax Officer, Ward-1(3), Hyderabad vs. Bhagyanagar India Limited, Secunderabad

In the result, the appeal of the Revenue is dismissed

ITA 1200/HYD/2019[2016-17]Status: DisposedITAT Hyderabad08 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri Narender Kumar Naik
Section 115JSection 143(2)Section 143(3)Section 14ASection 37(1)Section 80

decision of this Tribunal in the assessee’s own case for Assessment Years 2008–09 and 2009–10, where under similar facts, the disallowance under Section 14A had been deleted by the Tribunal. The observation of the Ld. CIT(A) have been stated at para no.4.3 of his order, which ... rival contentions and perused the material available on record. The core issue related to deletion of Rs.75,59,818/- is whether the disallowance under Section 14A of the Act was warranted in the present facts, particularly when no fresh investments were made during the year under consideration. On perusal

Children Welfare Trust (Regd), Faridabad vs. CIT Exemption, Chandigarh

In the result, Appeal of the Assessee is allowed

ITA 3637/DEL/2024[2016-17]Status: DisposedITAT Delhi08 Aug 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 3637/Del/2024 (A.Y 2016-17) Children Welfare Trust (Regd) Vs National Faceless C/O. Gita Balniketan Senior Assessment Centre, Secondary School, 3-E, Nit, Delhi (Nafac) Faridabad Delhi Pan: Aabtc6957B Appellant Respondent Assessee By Sh. Pavan Ved, Adv, Shri Mohit Gupta, Ca, Sh. Mirza, Ca & Shri Sarthakkh Aggarwal, Ca Revenue By Ms.Pooja Swaroop, Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 08/08/2025

Section 11(6)Section 139Section 143(3)Section 147Section 148Section 263

no.1 Assessing Officer could not have assumed the jurisdiction by invoking explanation (ii) of Section 263 is also tenable as the issue of disallowance under Section 14A of the Act was already subject matter of inquiry and therefore, the issue as to whether the inquiry was insufficient or not, could

M/S Rajasthan State Industrial Development and Investment Corporation Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, both the appeals of the assessee are allowed as indicated hereinabove

ITA 310/JPR/2025[2014-15]Status: DisposedITAT Jaipur06 Aug 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274Section 80

Explanation is Unsubstantiated and Not Bona Fide The explanation offered by the assessee for claiming deductions of CSR expenditure and for not making disallowance under Section 14A is self-serving and unsupported by any evidence. Both the Assessing Officer and the Ld. CIT(A) have:  Evaluated the factual matrix ... taxmann.com 286 (SC)  DCIT v. B.T. Patil & Sons Belgaum (P.) Ltd. [2018] 94 taxmann.com 434 (Mumbai Trib.) These rulings affirm that disallowance under Section 14A is mandatory, and failure to do so constitutes furnishing inaccurate particulars, attracting penalty. CBDT Circular No. 5/2014 dated 11.02.2014 Ratio: Clarifies that Section 14A disallowance

M/S Rajasthan State Industrial Development & Investment Corporation Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, both the appeals of the assessee are allowed as indicated

ITA 309/JPR/2025[2013-14]Status: DisposedITAT Jaipur06 Aug 2025AY 2013-14
For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274Section 80

Explanation is Unsubstantiated and Not Bona Fide The explanation offered by the assessee for claiming deductions of CSR expenditure and for not making disallowance under Section 14A is self-serving and unsupported by any evidence. Both the Assessing Officer and the Ld. CIT(A) have: • Evaluated the factual matrix ... taxmann.com 286 (SC) • DCIT v. B.T. Patil & Sons Belgaum (P.) Ltd. [2018] 94 taxmann.com 434 (Mumbai Trib.) These rulings affirm that disallowance under Section 14A is mandatory, and failure to do so constitutes furnishing inaccurate particulars, attracting penalty. CBDT Circular No. 5/2014 dated 11.02.2014 Ratio: Clarifies that Section 14A disallowance

Ananda Prasad Venigala, Hyderabad vs. DCIT, Circle-1(1), Hyderabad

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

ITA 1384/HYD/2024[2017-18]Status: DisposedITAT Hyderabad06 Aug 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1384/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Ananda Prasad Venigala, Dy. Commissioner Of Income Tax, Vs. Circle-1(1), Hyderabad. Hyderabad. Pan:Aewpp1096B (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Ananda Prasad Venigala (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 18.11.2024 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Dr. Sachin Kumar, SR-DR
Section 10Section 143(3)Section 14ASection 14A(2)Section 68

before this Tribunal. 5. At the outset, the Learned Authorised Representative (“Ld. AR”) submitted that the present appeal concerns two issues i.e. (a) disallowance under Section 14A of the Act of Rs.14,80,526/- and (b) addition under Section 68 of the Act of Rs.1 ... disallowance under Section 14A of the Act is concerned, the Ld. AR first submitted that the disallowance is unjustified because the Ld. AO failed to record proper satisfaction, as required under Section 14A(2), before invoking Rule 8D. ITA No.1384/Hyd/2024 4 6.1 In the alternative, the Ld. AR submitted that