“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

Ponni Sugars (Erode) Ltd., Chennai vs. DCIT, Circle-1, Ltu, Chennai

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

ITA 23/CHNY/2025[2009-10]Status: DisposedITAT Chennai06 Aug 2025AY 2009-10

Bench: Shri George George Kand Shri Amitabh Shuklaआयकर अपील सं./Ita No.: 23/Chny/2025 िनधा"रण वष"/Assessment Year:2009-10 Ponni Sugars (Erode) Limited, The Deputy Commissioner Esvin House, No.13, Vs. Of Income Tax, Rajiv Gandhi Salai (Omr), Circle-1, Ltu, Perungudi, Chennai. Chennai – 600 096. Pan: Aaccp 2779A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N.R. Suresh, C.A. ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 05.08.2025 घोषणा क" तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Shri N.R. Suresh, C.AFor Respondent: Ms. Anitha, Addl.CIT

Section 115JSection 14ASection 250

before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance under Section 14A was not correct. It will be in those cases where the assessee in his return has himself apportioned

Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru vs. Infosys Limited, Bengaluru

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR

Section 1Section 10ASection 155Section 250

merits. 16. The Ground No 1 is general in nature and does not require any adjudication. 16.1 The Ground No 2 deals with disallowance under section 14A read with rule 8D. The brief facts of the case are as under- During the year, the assessee earned exempt income being interest ... Treasury Head and other employees. 16.2 In the assessment order, a sum of Rs. 19,09,13,241/- has been computed as the disallowance under section 14A read with rule 8D. After reducing the voluntarily disallowance amounting

Infosys Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bangalore

ITA 881/BANG/2023[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 1Section 10ASection 155Section 250

ITA No.881/Bang/2023 ITA No.245/Bang/2024 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT

Dy..C.I.T., Bangalore vs. M/S State Bank of Mysore, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 683/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

3645/Mum/2016 dated 06/06/2023 for A.Υ. 2010–11, wherein it was held that for the purpose of disallowance under section 14A: Investments held as stock-in-trade should be excluded from the computation under Rule 8D; and only those investments which have yielded exempt income during the year should ... India (Mum ITAT), and Central Bank of India v. DCIT (Mum ITAT), which have consistently held, even post-Maxopp Investment Ltd. (supra), that disallowance under section 14A is not warranted in respect of investments held as stock-in-trade, particularly in the case of banks and financial institutions. We further

State Bank of Mysore, Bangalore vs. JCIT, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 660/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

assessee’s own cae in ITA No. 3645/Mum/2016 dated 06/06/2023 for A.Y. 2010–11, wherein it was held that for the purpose of disallowance under section 14A: Investments held as stock-in-trade should be excluded from the computation under Rule 8D; and only those investments which have yielded exempt ... India (Mum ITAT), and Central Bank of India v. DCIT (Mum ITAT), which have consistently held, even post-Maxopp Investment Ltd. (supra), that disallowance under section 14A is not warranted in respect of investments held as stock-in-trade, particularly in the case of banks and financial institutions

Eris Lifesciences Limited, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

Accordingly, the appeal of the assessee is also allowed for A

ITA 1038/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad04 Aug 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 143Section 143(3)Section 144BSection 14ASection 263

Rs.11,62,133/- on ITA Nos. 1037 & 1038/Ahd/2025 Eris Lifesciences Ltd. vs. PCIT Asst. Years –2020-21 & 2021-22 - 5– account of disallowance under Section 14A, addition of Rs.69,39,723/- on account of disallowance of channel partners/retail promotion expenses as grouped under the head other selling & Distribution expenses, addition

Eris Lifesciences Limited, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

Accordingly, the appeal of the assessee is also allowed for A

ITA 1037/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Aug 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 143Section 143(3)Section 144BSection 14ASection 263

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Phulchand Exports Private Limited, Mumbai

In the result, appeals of the Revenue in ITA No

ITA 3103/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Aug 2025AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Shankarlal Jain & Shri Satish KumarFor Respondent: Shri R.A Dhyani, (CIT-DR)

Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

Bombay High Court in the case of Nirved Traders Pvt. Ltd. (ITA No. 149 of 2017) approved the claim that the disallowance under section 14A was to be restricted to the tax-exempt income earned during the year. 5.1 He further observed that vide the Finance Act 2022 the following

Dy. Commissioner of Income Tax, Central Circle- 3(3), Mumbai vs. Phulchand Exports Private Limited, Mumbai

In the result, appeals of the Revenue in ITA No

ITA 3102/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Shankarlal Jain & Shri Satish KumarFor Respondent: Shri R.A Dhyani, (CIT-DR)

Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

Phulchand Exports Pvt Ltd, Mumbai vs. Asst. Commissioner of Income Tax Central Circle 3(3), Mumbai

In the result, appeals of the Revenue in ITA No

ITA 2415/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Respondent byFor Respondent: Shri Shankarlal Jain & Shri Satish Kumar

Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

DCIT, Circle-5(1)(1), Mumbai vs. Blue Star Diamonds Pvt. Ltd., Mumbai

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

ITA 1375/MUM/2024[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeedcit, Circle 5(1)(1), Mumbai Vs Blue Star Diamonds Pvt Ltd Ce-9010,9013, 9Th Floor, Tower-C, Room No.568, Aayakar Bhavan, M.K. Road, Mumbai- Bharat Diamond Bourse, Bkc, 400 020 Bandra (East), Mumbai-400 051 Pan: Aadcb6475E Appellant Respondent

For Appellant: Shri Nitesh Joshi & Ashwin KashinathFor Respondent: Shri Satyaprakash R. Singh, CIT DR

Section 143(3)Section 144Section 144BSection 145(3)Section 14ASection 250

assesse is maintaining the stock under “Cost or Net Realisable Value (NRV)”, whichever is lower. Further, the Ld.AO made disallowance under section 14A read with rule 8D(2)(iii) of the I.T. Rules, 1962 (in short, the “Rule”). Accordingly, the Ld.AO completed the assessment by addition in closing stock amount ... Rs.92,80,87,527/- and disallowance under section 14A of Rs.39,97,753/-. Aggrieved assesse filed an appeal before the Ld. CIT(A). The Ld. CIT(A) deleted the addition related to addition of closing stock and related to disallowance under section 14A of the Act, he has set aside

ACIT 2(2)(1) Mumbai, Aayakar Bhavan Mumbai vs. National Peroxide Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No 2816/Mum/2023 is partly allowed

ITA 2816/MUM/2023[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeeacit 2(2)(1) Mumbai Vs National Peroxide Limited 4Th Floor, Naville House, J N Heredia Aayakar Bhavan M.K. Road, Mumbai-400 020 Marg, Ballard Estate, Mumbai-400 001 Pan: Aabcn7072K

For Appellant: Shri Yogesh TharFor Respondent: Shri Satyaprakash R Singh, CIT DR

Section 115Section 143Section 143(1)(a)Section 143(3)Section 14ASection 250Section 43B

2816/Mum /2023 National Peroxide Ltd the Application against the fraudsters, Respondent No. 1 to 5 has been dismissed. 7. With respect to the disallowance under section 14A of the Act, the Ld. AR submitted that the assessee had suo motu disallowed an amount of Rs.19,48,631/- towards expenditure incurred

Assistant Commissioner of Income Tax, Circle-25(1), Delhi vs. Unison Hotels Private Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 4471/DEL/2024[2014-15]Status: DisposedITAT Delhi04 Aug 2025AY 2014-15

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2014-15] Acit, Vs Unison Hotels Pvt.Ltd., Cirlce-25(1), Plot No.2, Nelson Mandela Road, Delhi Vasant Kunj, Phase-2Nd, New Delhi-110070. Pan-Aaacu0455C Appellant Respondent Revenue By Shri Virender Kumar Singh, Sr.Dr Assessee By Ms. Kavita Jha, Sr.Adv., Shri Himanshu Agarwal, Adv. & Shri Akash Shukla, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 04.08.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 12.08.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10712/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Order Dated 23.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is A Private Limited Company & Is Running Hotels. The Return Of Income Was E-Filed On 29.11.2014, Declaring Total Income At Inr 7,21,35,196/-. The Case Was Selected For Scrutiny Under Cass By Way Of Issue Of Notice U/S 143(2) Of The Act On 01.09.2015. Thereafter, Various Notices Were Issued From Time To Time & Submissions Were Taken From The Assessee & Finally, The Assessment Was Completed At An Income Of Inr 30,38,83,394/- By Making Various Additions/Disallowances.

Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(vii)

restricted the addition to the extent of exempt income received. - The assessee is not in appeal against the restriction of disallowance under section 14A to Rs. 2.65 Lakhs by CIT(A). - It is a settled law that, in any case, the disallowance cannot exceed the exempt income earned ... Civil Appeal No. 9607-9615 of 2011, 2963 and 3367 of 2012, wherein while dealing with the issue of disallowance under section 14A of the Act, where interest-free owned funds of the assessee exceeded the amount of investment made by it in assets which yielded tax free income

Nayara Energy Limited (Formerly Known As Essar Oil Limited ), Mumbai vs. The Principal Commissioner of Income Tax Centre -1, Mumbai

In the result, the appeal filed by the assesse bearing

ITA 3504/MUM/2025[2019-20]Status: DisposedITAT Mumbai01 Aug 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeenayara Energy Limited Vs The Principal Commissioner Of (Formerly Known As ‘Essar Oil Income-Tax (Central), Mumbai-1 10Th Limited’), Room No.1001, Floor, 5Th Floor, Jet Airways Godrej Pratishtha Bhavan, Old Cgo Bkc Plot No.C-68, G Block, Annexe, M.K. Road, Mumbai-400 Bandra Kurla Complex, Bandra 020 East, Mumbai-400 051 Pan: Aaace0890P Appellant Respondent

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Satyaprakash R. Singh, CIT DR

Section 142(1)Section 143(2)Section 143(3)Section 144CSection 144C(3)Section 14ASection 263

capital expenditure. Further, the Ld. CIT(A) had taken a view that the Ld.AO has not taken any action for disallowance under section 14A of the Act. Taken both the issue together, the Ld. PCIT, issued the notice to the assessee and the assessee complied with the said notice issued ... exempt income and has issued a show cause related 3 ITA 3504/Mum /2025 Nayara Energy Limited (formerly known as Essar Oil limited) to disallowance under section 14A of the Act. The relevant notice is annexed at APB pages 43 to 45. In pursuance of the said notice, the assesse replied

Hira Power & Steels Limited, Raipur vs. Deputy Commissioner of Income Tax-1, Raipur

In the result ground no 6 of the appeal of the assessee is partly allowed for statistical purposes

ITA 233/RPR/2025[2012-13]Status: DisposedITAT Raipur31 Jul 2025AY 2012-13

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.233/Rpr/2025 "नधा"रण वष" / Assessment Year : 2012-13 Hira Power & Steels Limited 557, Urla Industrial Area, Urla Industrial Complex, Raipur (C.G.)-493 221 Pan: Aabcj0138Q ........अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 14A

funds and the assessee has available, non-interest-bearing funds larger than the investments made in tax- free securities then in such cases, disallowance under Section 14A cannot be made.” Also, we find that the Hon’ble High Court of Bombay in the case of 11. Commissioner of Income

M/S. Bodal Chemicals Ltd., Ahmedabad vs. The Dy.CIT, Circle-1, Ahmedabad

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR

Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

assessment order. 49. The Ld. AR submitted that the assessee company itself made the disallowance, hence the CIT(A) has rightly deleted the disallowance under Section 14A of the Act. For the year under consideration as against increase in investment of Rs.3,59,100/- the increase in own funds were ... There is no need to interfere with the findings of the CIT(A). Hence Ground No. 2 is dismissed. 60. Ground No.3 : Disallowance under section 14A 3. On the facts and in the circumstances of the case and in law, the ld CIT(A) has erred in deleting the disallowance

Ambattur Clothing Limited, Chennai vs. DCIT Company Circle 1(1), Chennai

ITA 1957/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Jul 2025AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1957/Chny/2017 निर्धारण वर्ष / Assessment Year: 2013-14 M/S. Ambattur Clothing Ltd [Now Demerged & Known As M/S. Ambattur Fashion India Pvt. Ltd.] No.86/E-2, Ambattur Industrial Estate Ambattur, Chennai– 600 058. (Pan:Aaaca-4127-D) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement The Deputy Commissioner Of Vs. Income-Tax, Corporate Circle -1(1), Chennai. (प्रत्यर्थी/Respondent) Shri. Sp Chidambaram, Advocate. Mr. Arv Sreenivasan, Cit. 09.07.2025 31.07.2025 आदेश /Order Per S. R. Raghunatha, Am : The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 21.06.2017 Of The Deputy Commissioner Of Income Tax, Corporate Circle 1(1) For The Assessment Year 2013-14 Passed In Compliance To Directions Of Dispute Resolution Panel-2, Bengaluru (Drp) Vide Order Dated 11.05.2017. 2. The Brief Facts Of The Case Are That The Assessee Is A Company Engaged In The Business Of Manufacturing & Sale Of Readymade Garments To Ae & Non- Ae'S. The Assessee Filed Its Return Of Income For The A.Υ.2013-14 On 30.11.2013 Declaring A Total Income Of Rs.11,57,20,670/-. The Case Was Selected For Scrutiny Through Cass & Accordingly Statutory Notices Were Issued To The Assessee. A :-2-:

Section 92C

order u/s.92CA(3) of the Act dated 31.10.2016. 3.3 The AO passed a Draft Assessment Order dated 08.12.2016 wherein the AO made a disallowance under section 14A of the Act of Rs.1,57,67,288/- and also incorporated the TP adjustment proposed by the TPO and provided 30 days time

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4140/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

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

Section 143(3)Section 14ASection 80G

deduction. 3. For the sake of convenience, we shall first adjudicate the appeal for the assessment year 2017–18 on the issue of disallowance under section 14A, which is common to all the years under consideration. Our findings and conclusions on this issue shall apply mutatis mutandis to the other ... specific nature of investments or expenses incurred. In addition to this, the Assessing Officer made a corresponding adjustment by adding the disallowance under section 14A while computing the book profits under section 115JB of the Act. Both these disallowances under the regular provisions as well as under the MAT provisions

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4139/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

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

Section 143(3)Section 14ASection 80G

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4138/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

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

Section 143(3)Section 14ASection 80G