← All Phrases

“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

Union Bank of India, Hyderabad vs. Dy. Commissisoner of Income Tax, Circle-1(1), Hyderabad

In the result, the appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

ITA 1018/HYD/2017[2012-13]Status: DisposedITAT Hyderabad28 Aug 2024AY 2012-13

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1018/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Andhra Bank Vs. Dy. C. I. T. Hyderabad Circle 1(1) Pan:Aabca7375C Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.1230/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13 ) Dy. C. I. T. Vs. Andhra Bank Circle 1(1) Hyderabad Hyderabad Pan:Aabca7375C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ananthan, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 02/07/2024 घोषणा की तारीख/Pronouncement: 28/08/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue, Are Directed Against The Order Dated 16/02/2016 Of Page 1 Of 59

For Appellant: Shri Ananthan, CAFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 36(1)(vi)Section 36(1)(vii)Section 36(1)(viia)Section 41(4)

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

Idfc First Bank Limited, Chennai vs. DCIT, Range Corporate Circle-2(2), Chennai

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

ITA 221/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Aug 2024AY 2018-19

Bench: Shri Mahavir Singh & Shri S.R. Raghunatha

For Appellant: Shri Ketan Ved, C.A ""For Respondent: Shri R.Clement Ramesh Kumar, CIT
Section 10(34)Section 115JSection 143(3)Section 14A

case and in law, the learned CIT (A) erred in not accepting the method employed by the Appellant for the purpose of computing disallowance under Section 14A of the Act. 1.1.1. On the facts and in circumstances of the case and in law, the CIT(A) ought to have held ... 115JB of the Act. Since the Assessee has already disallowed Rs.1.85crores in its return, the remaining amount of Rs.49.88 crores is hereby disallowed under section 14A of Income Tax Act.” Aggrieved, the assessee preferred appeal before CIT(A). 4. Before the CIT(A) the assessee has taken various pleas, including

State Bank of India, Mumbai vs. Principle Commissioner of Income Tax-2, Mumbai

ITA 1533/MUM/2023[2019-20]Status: DisposedITAT Mumbai28 Aug 2024AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Ketan Ved &For Respondent: Shri Dr. Kishor Dhule, CIT DR
Section 143(3)Section 144BSection 263

case of American Express (258 ITR 601) by stating that the same is contrary to the facts of the case. 7. Disallowance under section 14A 7.1 The learned PCIT erred in setting aside the said matter to the AO for examination without appreciating that the said issue is outside ... interest expenses and administrative expenses related to shares held as stock-in-trade should not be considered for the purpose of calculation of disallowance under section 14A. 8. Disallowance of amortization of premium paid on securities in Held to Maturity [HTM] category

Assistant Commissioner of Income-Tax, Circle-2(1)(1), Vadodara vs. Oriental Enterprises Private Limited, Pcc Notified Area

ITA 807/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri Ashok Natha Bhalekar, Sr.DR
Section 143(3)Section 36(1)(va)Section 37

appeal on this ground is allowed in favour of the assessee. Assessee’s Ground No. 2 and 3 relates to disallowance under Section 14A read with Rule 8D amounting to Rs. 52,07,537/-. 15. During the assessment proceedings, the AO identified that the assessee had made significant investments, income ... average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section 14A:Interest Expenses: Rs. 21,80,985/-. (+) Administrative/Other Expenses: Rs. 30,26,552/- = Rs. 52,07,537/-. 16. Before the Ld. CIT(A), The assessee argued that

Assistant Commissioner of Income-Tax, Circle 2(1)(1), Vadodara vs. Oriental Enterprises Private Limited, Pcc Notified Area

ITA 732/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri Ashok Natha Bhalekar, Sr.DR
Section 143(3)Section 36(1)(va)Section 37

appeal on this ground is allowed in favour of the assessee. Assessee’s Ground No. 2 and 3 relates to disallowance under Section 14A read with Rule 8D amounting to Rs. 52,07,537/-. 15. During the assessment proceedings, the AO identified that the assessee had made significant investments, income ... average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section 14A:Interest Expenses: Rs. 21,80,985/-. (+) Administrative/Other Expenses: Rs. 30,26,552/- = Rs. 52,07,537/-. 16. Before the Ld. CIT(A), The assessee argued that

Oriental Enterprise Private Limited, Vadodara vs. The ACIT, Circle-2(1)(2), Vadodara

ITA 661/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri Ashok Natha Bhalekar, Sr.DR
Section 143(3)Section 36(1)(va)Section 37

appeal on this ground is allowed in favour of the assessee. Assessee’s Ground No. 2 and 3 relates to disallowance under Section 14A read with Rule 8D amounting to Rs. 52,07,537/-. 15. During the assessment proceedings, the AO identified that the assessee had made significant investments, income ... average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section 14A:Interest Expenses: Rs. 21,80,985/-. (+) Administrative/Other Expenses: Rs. 30,26,552/- = Rs. 52,07,537/-. 16. Before the Ld. CIT(A), The assessee argued that

Gujarat State Fertilisers & Chemicals Ltd., Vadodara vs. The Dy, CIT, Circle-1(1)(1), Vadodara

Appeal is dismissed and assessee’s appeal is partly allowed

ITA 624/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah, A.RFor Respondent: Shri H. Phani Raju, CIT D.R. &
Section 14A

earning exempted income. Ground No. 1 and 2 of Assessee’ Cross Objection against ITA No.547/Ahd/2016 1. Without prejudice to the claim that no disallowance under Section 14A of the Act is justified in the facts of the case, in the event the ground no.1 of the captioned appeal is decided ... held in favour of the assessee. It is submitted that it be so held now. 2. Without prejudice to the claim that no disallowance under Section 14A of the Act is justified in the facts of the case, in the event the ground no.1 of the captioned appeal is decided

The DCIT, Circle-1(1), Vadodara vs. Gujarat State Fertilizers & Chemicals Ltd., Vadodara

Appeal is dismissed and assessee’s appeal is partly allowed

ITA 547/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Yogesh Shah, A.RFor Respondent: Shri H. Phani Raju, CIT D.R. &
Section 14A

earning exempted income. Ground No. 1 and 2 of Assessee’ Cross Objection against ITA No.547/Ahd/2016 1. Without prejudice to the claim that no disallowance under Section 14A of the Act is justified in the facts of the case, in the event the ground no.1 of the captioned appeal is decided ... held in favour of the assessee. It is submitted that it be so held now. 2. Without prejudice to the claim that no disallowance under Section 14A of the Act is justified in the facts of the case, in the event the ground no.1 of the captioned appeal is decided

DCIT, 14(1)(2), Mumbai vs. Vedhas Realtors Private Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 750/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Aug 2024AY 2015-16

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Surendra Meena, Sr DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 154Section 250Section 68Section 69C

Realtors Pvt. Ltd. ITA no.660/Mum./2024, ITA no.750/Mum./2024 13. The next issue that arises for our consideration pertains to the deletion of disallowance under section 14A of the Act. 14. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings ... including a fresh investment of HDFC mutual funds of Rs.2 crores. Accordingly, the assessee was asked to show cause as to why the disallowance under section 14A read with Rule 8D should not be made. In response thereto, the assessee submitted that it has not received any income which

DCIT, Circle-14(1)(2), Mumbai vs. Vedhas Realtors Private Limited, Mumbai

ITA 660/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Aug 2024AY 2015-16

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Surendra Meena, Sr DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 154Section 250Section 68Section 69C

Realtors Pvt. Ltd. ITA no.660/Mum./2024, ITA no.750/Mum./2024 13. The next issue that arises for our consideration pertains to the deletion of disallowance under section 14A of the Act. 14. We have considered the submissions of both sides and perused the material available on record. During the assessment proceedings ... including a fresh investment of HDFC mutual funds of Rs.2 crores. Accordingly, the assessee was asked to show cause as to why the disallowance under section 14A read with Rule 8D should not be made. In response thereto, the assessee submitted that it has not received any income which

Elegant Dealmark Pvt. Ltd., Kolkata vs. ITO, Ward-5(3), Kolkata

In the result, the appeal filed by the assessee is partly allowed, with Ground No

ITA 51/KOL/2024[2012-13]Status: DisposedITAT Kolkata21 Aug 2024AY 2012-13

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 131Section 14ASection 68

even in the Page 13 of 15 I.T.A. No.: 51/KOL/2024 Assessment Year: 2012-13 Elegant Dealmark Pvt. Ltd. absence of any exempt income disallowance under section 14A had to be made, is binding on the revenue authority, had no merit. [Para 12] ■ No illegality or perversity could be demonstrated

Asstt Commissioner of Income Tax-4 (2) (1), Mumbai vs. S P Jain Securities Pvt Ltd, Fort

In the result, the appeal by the Revenue is dismissed

ITA 606/MUM/2024[2011-12]Status: DisposedITAT Mumbai21 Aug 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Bhavya SundeshaFor Respondent: Shri Surendra Meena, Sr. DR
Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 14ASection 250Section 68

passed under section 143(3) of the Act the total income of the assessee was assessed at Rs.1,11,01,830 after making disallowance under section 14A read with Rule 8D of the Income Tax Rules, 1962, and expenses allocated to speculative business. Subsequently, based on the information received from

Nirmal Narendrakumar Kotecha, Mumbai vs. Int. Tax, Ward-3(1)(1), Mumbai

In the result, in terms of paragraph 24 above, the appeal preferred by the Assessee is allowed

ITA 4592/MUM/2023[2009-10]Status: DisposedITAT Mumbai19 Aug 2024AY 2009-10

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Kinjal BhutaFor Respondent: Shri Ashok Kumar Ambastha
Section 143(3)Section 14ASection 271(1)(c)

Appeal before the CIT(A) arising from penalty order dated 21/03/2017, the Tribunal passed order, dated 07/06/2017, in the quantum proceedings deleting the disallowance under Section 14A of the Act and setting aside the issue relating to characterization of income as capital gain or business income back

Rajapalayam Mills Ltd., Virudhunagar vs. DCIT, Corporate Circle, Madurai

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

ITA 1251/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Aug 2024AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1251/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 Rajapalayam Mills Limited, Vs. The Deputy Commissioner Of Post Box No. 1, Rajapalayam Mills Income Tax, Premises, P.A.C. Ramasamy Raja Corporate Circle, Salai, Rajapalayam, Madurai. Virudhunagar 626 117. [Pan: Aaacr8897F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Muralidhar, F.C.A. ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 12.08.2024 घोषणा की तारीख /Date Of Pronouncement : 14.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2017-18. 2. The Assessee Raised 9 Grounds Amongst Which The Only Issue Emanates For Our Consideration Is Whether The Ld. Pcit Is Justified In Directing The Assessing Officer For Working Out Disallowance Under Section 2

For Appellant: Shri S. Muralidhar, F.C.AFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 142(1)Section 14ASection 2Section 263

No.1251/Chny/24 year under consideration, which is at page 36 of the paper book. Considering the same, the Assessing Officer did not make any disallowance under section 14A of the Act r.w. Rule 8D of the Income Tax Rules, 1962. The case of the ld. PCIT is that the Assessing Officer ... during the course of original assessment 6 I.T.A. No.1251/Chny/24 proceedings and by applying the relevant statutory provision as it stood then, made no disallowance under section 14A of the Act. 7. Regarding the insertion of Explanation to section 14A of the Act by way of Finance Act, 2022, we find

Jagriti Job Finder Private Limited, New Delhi vs. PCIT Central - 1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2133/DEL/2024[2018-19]Status: DisposedITAT Delhi14 Aug 2024AY 2018-19

Bench: Ms.Madhumita Roy & Shri Avdhesh Kumar Mishram/S Jagriti Job Finder Vs. Pcit (Central) -1 Private Limited, 222, 2Nd New Delhi-110055 Floor Hemkunt Chamber, 89, Nehru Place, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcj5974E Appellant .. Respondent

For Appellant: Sh. Ashwani Kumar &For Respondent: Sh. Sanjay Pandey
Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

matter of Maxopp Investment Limited Vs. CIT, reported in 402 ITR 640 (SC) that in the absence of exempt income no disallowance under Section 14A of the Act is called for as was the crux of the argument advanced by the Ld. A.R. On the other hand

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 399/COCH/2023[2017-18]Status: DisposedITAT Cochin13 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

Banks for each year. Since we find that the rational adopted by the Assessing Officer to estimate the expenditure for the purpose of disallowance under section 14A is not tenable, we feel the matter should be restored to the Assessing Officer for making disallowance under section 14A by reasonably estimating ... Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking disallowance under section 14A in the case of each assessee for each assessment year. The proportionate disallowance under section 14A should be limited to only interest liability

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 397/COCH/2023[2015-16]Status: DisposedITAT Cochin13 Aug 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

Banks for each year. Since we find that the rational adopted by the Assessing Officer to estimate the expenditure for the purpose of disallowance under section 14A is not tenable, we feel the matter should be restored to the Assessing Officer for making disallowance under section 14A by reasonably estimating ... Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking disallowance under section 14A in the case of each assessee for each assessment year. The proportionate disallowance under section 14A should be limited to only interest liability

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 396/COCH/2023[2014-15]Status: DisposedITAT Cochin13 Aug 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

Banks for each year. Since we find that the rational adopted by the Assessing Officer to estimate the expenditure for the purpose of disallowance under section 14A is not tenable, we feel the matter should be restored to the Assessing Officer for making disallowance under section 14A by reasonably estimating ... Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking disallowance under section 14A in the case of each assessee for each assessment year. The proportionate disallowance under section 14A should be limited to only interest liability

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 395/COCH/2023[2013-14]Status: DisposedITAT Cochin13 Aug 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

Banks for each year. Since we find that the rational adopted by the Assessing Officer to estimate the expenditure for the purpose of disallowance under section 14A is not tenable, we feel the matter should be restored to the Assessing Officer for making disallowance under section 14A by reasonably estimating ... Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking disallowance under section 14A in the case of each assessee for each assessment year. The proportionate disallowance under section 14A should be limited to only interest liability

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 394/COCH/2023[2012-13]Status: DisposedITAT Cochin13 Aug 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

Banks for each year. Since we find that the rational adopted by the Assessing Officer to estimate the expenditure for the purpose of disallowance under section 14A is not tenable, we feel the matter should be restored to the Assessing Officer for making disallowance under section 14A by reasonably estimating ... Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking disallowance under section 14A in the case of each assessee for each assessment year. The proportionate disallowance under section 14A should be limited to only interest liability