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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

DCIT 2(1)(1), Mumbai vs. Bajaj Electricals Ltd, Mumbai

ITA 5750/MUM/2015[2011-12]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-12

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

For Appellant: Shri Nitesh S. Joshi, ARFor Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance: (i) Disallowance under section 14A r.w.r. 8D - Rs.1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP Rs. 7,35,861/- (iii) Disallowance of prior period expenses ... confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A (ii) Ad-hoc disallowance of commission expenses (iii) Disallowance of ESOP expenses (iv) Disallowance of prior period expenses Ground No. 1.1 to 1.4 Ground

DCIT 2(1)(1), Mumbai vs. Bajaj Electricals Ltd, Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 5749/MUM/2015[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

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

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance: (i) Disallowance under section 14A r.w.r. 8D - Rs. 1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP - Rs. 7,35,861/- (iii) Disallowance of prior period expenses ... confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A - Ground No. 1.1 to 1.4 (ii) Ad-hoc disallowance of commission expenses - Ground No. 2 (iii) Disallowance of ESOP expenses - Ground

Bajaj Electricals Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 4172/MUM/2013[2009-10]Status: DisposedITAT Mumbai01 Jul 2025AY 2009-10

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

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance: (i) Disallowance under section 14A r.w.r. 8D - Rs. 1,19,07,328/- (ii) Disallowance of Expenditure towards ESOP - Rs. 7,35,861/- (iii) Disallowance of prior period expenses ... confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A - Ground No. 1.1 to 1.4 (ii) Ad-hoc disallowance of commission expenses - Ground No. 2 (iii) Disallowance of ESOP expenses - Ground

Vadilal International Private Limited, Ahmedabad vs. The Dy.CIT, Circle-4(1)(2), Ahmedabad

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

ITA 1982/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14A

Circle 4(1)(2)- Ahmedabad ('Ld.AO') without considering the submission filed. 2. In doing so, the CIT(A) further erred in upholding the disallowance under section 14A read with Rule 8D without addressing the fundamental requirement that the AO must record dissatisfaction with the appellant's I.T.A No. 1982/Ahd/2024

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

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

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

facts and in the circumstances of the case and in law, the Ld. AD erred in invoking Rule 8D for determining the disallowance under section 14A without analyzing the correctness of the disallowance offered by the Appellant in its return of income and the Hon'ble 6 ITA.No.111/Hyd./2022

Yashaswini Investments Company Private Limited, Mumbai vs. Income Tax Officer, Ward 11(3)(4), Mumbai

ITA 3124/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jun 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Yogesh JoijodeFor Respondent: Shri Swapnil Choudhary
Section 115JSection 143(3)Section 14A

further contended that the Assessee had also not earned any exempt income and for that reason also no disallowance under Section 14A of the Act was warranted. However, the Assessing Officer rejected the aforesaid contentions of the Assessee and proceeded to compute the disallowance under Section 14A ... noted that the Assessee had disallowed the entire expenditure (excluding depreciation) amounting to INR.1,29,967/- and has treated the same as amount disallowed under Section 14A of the Act. Thus, we find that in the present case the Assessee had (a) not earned any exempt income during the relevant

ACIT-6(1)(1), Mumbai vs. Essel Utilities Distribution Company Ltd., Mumbai

ITA 2725/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jun 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

Section 10Section 11Section 115JSection 12Section 14A

Assessing Officer observed that the assessee had made investments to the tune of ₹82.80 crores in shares of related entities. However, no disallowance under Section 14A of the Act was offered suo-motu by the assessee. In response, the assessee submitted that no exempt income had been earned during ... relevant previous year and, therefore, no disallowance under Section 14A was warranted. 2.2 The Assessing Officer, not being satisfied with the explanation tendered, proceeded to disallow expenditure under Section 14A of the Act read with Rule 8D of the Income Tax Rules, 1962. The said disallowance was made not only

M/S. Parvesh Construction Pvt Ltd, Mumbai vs. DCIT 8(2)(1), Mumbai

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

ITA 2714/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Jun 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Mr. Nishit Gandhi
Section 147Section 148Section 14ASection 56(2)(viib)Section 68

believe” was indeed sustained and formed part of the reassessment. In addition, the Assessing Officer has also made other additions, such as disallowance under Section 14A and losses claimed on account of futures and options trading. The Ld. CIT(A), having examined the legal position and the factual backdrop, came

Dai-Ichi Karkaria Limited, Mumbai vs. DCIT, Circle-1(1)(1), Mumbai

In the result, ground no. 4 of the assessee is allowed

ITA 1588/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jun 2025AY 2017-18

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 115JSection 14ASection 254(1)Section 270A

without considering the fact that they did not yield any dividend income. Accordingly, the JCIT(A) should have restricted the disallowance under section 14A to Rs. 10,26,245 (as against Rs. 25,86,319 computed by the Ld. AO). 3. Without prejudice, on the facts and the circumstances ... action of AO the assessee filed appeal before CIT(A). 4. Before CIT(A) the assessee filed its detailed return submission. On the disallowance of section 14A, the assessee reiterated that additional disallowance made by AO is unwarranted. The assessee made suo-moto disallowance of Rs. 20,56,871/- which

Dcm Shriram Limited, Delhi vs. Assessment Unit, Delhi

ITA 4328/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

separate code and has to be interpreted in its literal sense and therefore, no adjustment should be made on account of disallowance under section 14A of the Act in the book profits. He thus prayed for the confirmation of the order of Ld. CIT(A) in deleting the disallowance under ... Special Bench in the case of Virit Investment (supra) where it is held that no addition could be made on account of disallowance under section 14A to the book profit. This being so, we do not find any force in the arguments of Ld. CIT DR accordingly, the additional grounds

DCIT, New Delhi vs. Dcm Shriram Ltd, New Delhi

ITA 927/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

separate code and has to be interpreted in its literal sense and therefore, no adjustment should be made on account of disallowance under section 14A of the Act in the book profits. He thus prayed for the confirmation of the order of Ld. CIT(A) in deleting the disallowance under ... Special Bench in the case of Virit Investment (supra) where it is held that no addition could be made on account of disallowance under section 14A to the book profit. This being so, we do not find any force in the arguments of Ld. CIT DR accordingly, the additional grounds

Dcm Shriram Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

ITA 2587/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

separate code and has to be interpreted in its literal sense and therefore, no adjustment should be made on account of disallowance under section 14A of the Act in the book profits. He thus prayed for the confirmation of the order of Ld. CIT(A) in deleting the disallowance under ... Special Bench in the case of Virit Investment (supra) where it is held that no addition could be made on account of disallowance under section 14A to the book profit. This being so, we do not find any force in the arguments of Ld. CIT DR accordingly, the additional grounds

Dcm Shriiram Limited, New Delhi vs. Neac, New Delhi

ITA 704/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

separate code and has to be interpreted in its literal sense and therefore, no adjustment should be made on account of disallowance under section 14A of the Act in the book profits. He thus prayed for the confirmation of the order of Ld. CIT(A) in deleting the disallowance under ... Special Bench in the case of Virit Investment (supra) where it is held that no addition could be made on account of disallowance under section 14A to the book profit. This being so, we do not find any force in the arguments of Ld. CIT DR accordingly, the additional grounds

ACIT, Circle- 1, Ltu, New Delhi vs. C&S Electric Ltd., New Delhi

In the result, the revenue’s appeal stands dismissed as above

ITA 8274/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. v. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

C & S Electric Ltd., New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the revenue’s appeal stands dismissed as above

ITA 7981/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. v. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

C & S Electric Ltd., New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the revenue's appeal stands dismissed as above

ITA 2623/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jun 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. v. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

C & S Electric Ltd., New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the revenue's appeal stands dismissed as above

ITA 2622/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jun 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. V. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

DCIT, Circle- 1, Ltu, New Delhi vs. C & S Electric Ltd., New Delhi

In the result, the revenue's appeal stands dismissed as above

ITA 2533/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jun 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. V. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

DCIT, Circle- 1, Ltu, New Delhi vs. C & S Electric Ltd., New Delhi

In the result, the revenue’s appeal stands dismissed as above

ITA 2532/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jun 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Section 10ASection 14ASection 80Section 80I

appeals are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of foreign travelling expenses. v. Disallowance of Club expenses. vi. Disallowance of depreciation on software license ... appeal are summed up as under: i. Deduction under section 80IC of the Act. ii. Deduction under section 10AA of the Act. iii. Disallowance under section 14A of the Act. iv. Disallowance of depreciation on software license. 22. The Ld. AR submitted that the issue relating to claim of deduction

Bright Paints Pvt Ltd, Mumbai vs. Dy Commissioner of Income Tax - 12(1)(2), Mumbai

In the result, the ground no

ITA 6817/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Jun 2025AY 2014-15

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. Nitesh JoshiFor Respondent: Shri. Leyaqat Ali, SR. DR
Section 143(1)Section 143(2)Section 143(3)(ii)Section 14ASection 250Section 73

cannot exceed the exempt income earned during the year of Rs.36,855. 4. That the NFAC ought to have held that the disallowance under section 14A of the Act is to be restricted in respect of such investments which have actually yielded exempt income during the year. 5. That