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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

Mondelez India Foods P.Ltd (Formerly Known As Cadbury India Limited), Mumbai vs. Asst CIT RG 5(1)(2), Mumbai

In the result, appeal filed by the assessee for AY 2013-14 is allowed for statistical purpose

ITA 7104/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Sept 2023AY 2013-14

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14A

Ground Nos. 31 to International Holdings LLC 33 Adjustment on account of information technology Ground Nos. 34 to charges 37 Disallowance under section 14A of the Act read Ground No. 34 Ground No.38 with Rule 8D Allocation of expenditure at Baddi Unit-I & II Ground Nos.35 to 36 Ground Nos.39 ... incorporating the TP adjustments. The Assessing Officer, besides the TP adjustment also made additions on the corporate tax front as listed below – (1) Disallowance under section 14A Rs. 6,79,072/- (2) Denial of deduction under section 80IC Unit I Rs. 12,10,78,108/- Unit

M/S. United Phosphorus Ltd., Mumbai vs. DCIT Cent. Cir. - 38, Mumbai

In the result, appeal of the revenue is partly allowed

ITA 4695/MUM/2005[1999-2000]Status: DisposedITAT Mumbai20 Sept 2023AY 1999-2000

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W), Mumbai – 400 052 Pan: Aaacu3440P ...... Appellant Vs. Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ..... Respondent Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ...... Appellant Vs. M/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W) Mumbai – 400 052 Pan: Aaacu3440P ...... Respondent (Now Known As Uniphos Enterprises Ltd.)

For Appellant: Ms. Vasanti B Patel / Shri KiritFor Respondent: Shri Rajneesh Yadav
Section 143(3)Section 37(1)

total investment of Rs. 11,053.68 lakhs as attributable to earning exempt income. Since, the same was more than the dividend income, the disallowance under section 14A was restricted to dividend income of Rs. 16, 36,570/-. 18. In the Ld. CIT (A)'s order, relying on the appellate order

Justice Mohan Lal Varma (Retd.), New Delhi vs. ACIT, Circle-63(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1010/DEL/2019[2013-14]Status: DisposedITAT Delhi20 Sept 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Shri B.K. Anand, FCAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR
Section 143(3)Section 14A

dividend income. 4. We find that the issue has been examined by the Co-ordinate Bench in favour of the Assessee. Besides, the disallowance under Section 14A with reference to investment in mutual funds has been answered in favour of the assessee in the case of M/s. I.T.A. No.1010/Del/2019 ... Computer Training (Guj) Pvt. Ltd. vs. DCIT in ITA No.3065/Ahd/2013 order dated 30.11.2016. The Co-ordinate Bench has addressed the issue of disallowance under Section 14A in relation to the mutual funds in following terms; “10. We have carefully considered the rival submissions, perused the material available on record

Aarti Sponge and Power Ltd., Raipur vs. Assistant Commissioner of Income Tax, -1(1), Raipur

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

ITA 70/RPR/2023[2013-14]Status: DisposedITAT Raipur20 Sept 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.70/Rpr/2023 िनधा"रण वष" /Assessment Year: 2013-14 V. Aarti Sponge & Power Ltd. Acit -1 (1) Aarti House, Ashoka Ratna Shankar Raipur Nagar, Raipur, Chhattisgarh – 492 001

For Respondent: Sr. D.R
Section 143(3)Section 14ASection 250

consequent assessment order passed by Assessing Officer enhancing addition made under section 14A – High Court upheld order of Tribunal holding that amount of disallowance under section 14A could be restricted to amount of exempt income only and not a higher figure – Whether on facts, SLP filed against decision of High ... applicability of new explanation inserted in 14A under the Finance Act, 2022, to clarify that bereft exempt income being earned in any year, disallowance under Section 14A will still be attracted. which reads as under: :: 14 :: “In section 14A of the Income-tax Act, – (a) in sub-section

DCIT-3(2)(1), Mumbai vs. Millennium Appliances, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1389/MUM/2023[2016-2017]Status: DisposedITAT Mumbai15 Sept 2023AY 2016-2017

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – 3(2)(1) V. M/S. Millennium Appliances India Ltd., 17Th Floor, C Wing Mittal Court Room No. 608, 6Th Floor Nariman Point, Mumbai - 400021 Aayakar Bhavan, M.K. Road Mumbai - 400020 Pan: Aaccm7838D (Appellant) (Respondent)

Section 14A

disallowed, is a question of fact. The contention of the revenue that directly or indirectly some expenditure is always incurred which must be disallowed under section 14A and the impact of expenditure so incurred cannot be allowed to be set off against the business income which may nullify the mandate ... section 14A, cannot be accepted. Disallowance under section 14A requires finding of incurring of expenditure where it is found that for earning exempted income no expenditure has been incurred, disallowance under section 14A cannot stand" (emphasis applied) Reliance is also placed on the judgment of ITAT Mumbai J Bench

ACIT(Ltu-1), Mumbai vs. M/S. Tcs Ltd, Mumbai

ITA 5904/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

treated as capital in nature has become academic and does not warrant any separate adjudication. 38 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd Disallowance under section 14A – Ground 3 46. The assessee, in the return of income, has claimed an amount of Rs.28,56,30,503/- as dividend income exempt ... Assessing Officer held that he is not satisfied with regard to the disallowance of the claim of expenditure and proceeded to make a disallowance under section 14A read with rule 8D of I.T. Rules, 1962. The CIT(A) deleted the disallowance. 47. The Ld.DR submitted that the assessee

Tata Consultancy Serrvices Limited, Mumbai vs. DCIT-1, Mumbai

ITA 5199/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

treated as capital in nature has become academic and does not warrant any separate adjudication. 38 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd Disallowance under section 14A – Ground 3 46. The assessee, in the return of income, has claimed an amount of Rs.28,56,30,503/- as dividend income exempt ... Assessing Officer held that he is not satisfied with regard to the disallowance of the claim of expenditure and proceeded to make a disallowance under section 14A read with rule 8D of I.T. Rules, 1962. The CIT(A) deleted the disallowance. 47. The Ld.DR submitted that the assessee

Hira Infra-Tek Ltd., Raipur vs. Assistant Commissioner of Income Tax, Circle-1(1), Raipur

In the result, appeal of the assessee is partly allowed for statical purposes, in terms of our aforesaid observations

ITA 77/RPR/2023[2012-13]Status: DisposedITAT Raipur15 Sept 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.77/Rpr/2023 िनधा"रण वष" /Assessment Year: 2012-13 V. Hira Infra-Tek Limited Acit Hira Arcade Near New Bus Stand, Circle – 1(1) Pandri, Raipur Raipur

For Respondent: Shri Satya Prakash Sharma
Section 143(3)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. (ii) HDFC Bank vs. DCIT (2016) 383 ITR 529 (Bom.), wherein Hon’ble Bombay High Court has held, extracted ... issue on merits has been decided in favour of the assessee in State Bank of Patiala's case(supra). The amount of disallowance under Section 14A was restricted to the amount of exempt income only and not at a higher figure. Once that was so, High Court do not consider

Chowdry Associates, New Delhi vs. ACIT, Circle-6(1), New Delhi

The appeal is allowed and impugned addition is deleted

ITA 6526/DEL/2019[2014-15]Status: DisposedITAT Delhi14 Sept 2023AY 2014-15

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmash. Chowdry Associates Vs. Acit, 4Th Floor, Punjabi Circle-6(1), Bhawan, 10, Rouse New Delhi Avenue, New Delhi Pan : Aaacc0387R (Appellant) (Respondent)

Section 143(3)Section 14A

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

DCIT Cir 5(3)(2), Mumbai vs. The Great Eastern Shipping Co. Ltd, Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 2077/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5 Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

while computing the disallowance under Rule 8D(2)(ii). vii) The Appellant contends that there is no interest expenditure which is liable for disallowance under Section 14A of the Act read with Rule 8D. On a perusal of the Share Capital and Reserves and Surplus in the Balance Sheet ... contention of the Appellant that there is no further disallowance of interest expenditure or administrative expenditure, the Appellant submits that the disallowance under Section 14A read with Rule 8D2(ii) and (iii) be recomputed by excluding those investments on which no dividend income was received during the year. The statement

The Great Eastern Shipping Co. Ltd, Mumbai vs. Asst CIT Cir 5(3)(2), Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 1597/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

while computing the disallowance under Rule 8D(2)(ii). vii) The Appellant contends that there is no interest expenditure which is liable for disallowance under Section 14A of the Act read with Rule 8D. On a perusal of the Share Capital and Reserves and Surplus in the Balance Sheet ... contention of the Appellant that there is no further disallowance of interest expenditure or administrative expenditure, the Appellant submits that the disallowance under Section 14A read with Rule 8D2(ii) and (iii) be recomputed by excluding those investments on which no dividend income was received during the year. The statement

The Great Eastern Shipping Co. Ltd, Mumbai vs. Asst CIT Cir 5(3)(2), Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 374/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Sept 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

while computing the disallowance under Rule 8D(2)(ii). vii) The Appellant contends that there is no interest expenditure which is liable for disallowance under Section 14A of the Act read with Rule 8D. On a perusal of the Share Capital and Reserves and Surplus in the Balance Sheet ... contention of the Appellant that there is no further disallowance of interest expenditure or administrative expenditure, the Appellant submits that the disallowance under Section 14A read with Rule 8D2(ii) and (iii) be recomputed by excluding those investments on which no dividend income was received during the year. The statement

DCIT 5(3)(2), Mumbai vs. The Great Eastern Shipping Co.Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3272/MUM/2015[2009-10]Status: DisposedITAT Mumbai13 Sept 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of The Great Eastern Shipping Income-Tax, Co. Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Manoj Mishra, CIT DR
Section 115Section 143Section 143(3)Section 144CSection 14A

respect of several investments on which the Appellant received no dividend income during the year was also considered in average investment. Thus disallowance under Section 14A read with Rule 8D2(ii) and (iii) should have been by excluding those investments on which no dividend income was received during the year

The Great Eastern Shipping Co. Ltd, Mumbai vs. DCIT Cir 5(3)(2), Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 1216/MUM/2015[2010-11]Status: DisposedITAT Mumbai13 Sept 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

while computing the disallowance under Rule 8D(2)(ii). vii) The Appellant contends that there is no interest expenditure which is liable for disallowance under Section 14A of the Act read with Rule 8D. On a perusal of the Share Capital and Reserves and Surplus in the Balance Sheet ... contention of the Appellant that there is no further disallowance of interest expenditure or administrative expenditure, the Appellant submits that the disallowance under Section 14A read with Rule 8D2(ii) and (iii) be recomputed by excluding those investments on which no dividend income was received during the year. The statement

The Great Eastern Shipping Co. Ltd, Mumbai vs. DCIT RG 5(3), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 1656/MUM/2014[2009-10]Status: DisposedITAT Mumbai13 Sept 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of The Great Eastern Shipping Income-Tax, Co. Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Manoj Mishra, CIT DR
Section 115Section 143Section 143(3)Section 144CSection 14A

respect of several investments on which the Appellant received no dividend income during the year was also considered in average investment. Thus disallowance under Section 14A read with Rule 8D2(ii) and (iii) should have been by excluding those investments on which no dividend income was received during the year

B4S Solution P.Ltd, Ghaziabad vs. ACIT, Circle-4(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 2188/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Sept 2023AY 2017-18

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year 2017-18

For Appellant: Shri Ankit Kumar, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 10(34)Section 143(3)Section 14A

four grounds relate thereto. 6. The Ld. AR submitted that the Ld. CIT(A) is not correct in sustaining the impugned disallowance under section 14A r.w. Rule 8D of the Rules as he did not appreciate that the assessee neither incurred any expenditure to earn exempt income nor there ... subsequent years provisions of section 14A have not been invoked. In the absence of incurring any direct/indirect 3 expenditure against the exempt income, disallowance under section 14A is against the law being wholly arbitrary, he argued. 7. The Ld. DR relied on the order of Ld. AO/CIT

Citrus Check Inns Ltd., Mumbai vs. DCIT Central Circle-2(1), Mumbai

In the result, the appeal by the assessee for A

ITA 1018/MUM/2019[2015-16]Status: DisposedITAT Mumbai06 Sept 2023AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Hiro Rai a/w Ms. Ritu PunjabiFor Respondent: Shri Manish Sareen
Section 250

kept open. 37. The issue arising in grounds no.2.a to 2.d, raised in assessee’s appeal is pertaining to disallowance under section 14A r/w rule 8D. 38. The brief facts of the case pertaining to the issue, as emanating from the record, are; During the scrutiny proceedings ... apply in relation to the assessment year 2022-23 and subsequent assessment years. Thus, even in view of the aforesaid amendment also, the disallowance under section 14A r/w rule 8D is not permissible in the present case. Accordingly, the same is directed to be deleted. As a result, grounds no.2.a

Citrus Check Inns Ltd, Mumbai vs. DCIT Central Circle-2(1), Mumbai

In the result, the appeal by the assessee for A

ITA 1017/MUM/2019[2014-15]Status: DisposedITAT Mumbai06 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Hiro Rai a/w Ms. Ritu PunjabiFor Respondent: Shri Manish Sareen
Section 250

kept open. 37. The issue arising in grounds no.2.a to 2.d, raised in assessee’s appeal is pertaining to disallowance under section 14A r/w rule 8D. 38. The brief facts of the case pertaining to the issue, as emanating from the record, are; During the scrutiny proceedings ... apply in relation to the assessment year 2022-23 and subsequent assessment years. Thus, even in view of the aforesaid amendment also, the disallowance under section 14A r/w rule 8D is not permissible in the present case. Accordingly, the same is directed to be deleted. As a result, grounds no.2.a

Citrus Check Inns Ltd., Mumbai vs. DCIT Central Circle-2(1), Mumbai

In the result, the appeal by the assessee for A

ITA 1016/MUM/2019[2013-14]Status: DisposedITAT Mumbai06 Sept 2023AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Hiro Rai a/w Ms. Ritu PunjabiFor Respondent: Shri Manish Sareen
Section 250

kept open. 37. The issue arising in grounds no.2.a to 2.d, raised in assessee’s appeal is pertaining to disallowance under section 14A r/w rule 8D. 38. The brief facts of the case pertaining to the issue, as emanating from the record, are; During the scrutiny proceedings ... apply in relation to the assessment year 2022-23 and subsequent assessment years. Thus, even in view of the aforesaid amendment also, the disallowance under section 14A r/w rule 8D is not permissible in the present case. Accordingly, the same is directed to be deleted. As a result, grounds no.2.a

Citrus Check Inns Ltd, Mumbai vs. DCIT Central Circle-2(1), Mumbai

In the result, the appeal by the assessee for A

ITA 1015/MUM/2019[2012-13]Status: DisposedITAT Mumbai06 Sept 2023AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Hiro Rai a/w Ms. Ritu PunjabiFor Respondent: Shri Manish Sareen
Section 250

kept open. 37. The issue arising in grounds no.2.a to 2.d, raised in assessee’s appeal is pertaining to disallowance under section 14A r/w rule 8D. 38. The brief facts of the case pertaining to the issue, as emanating from the record, are; During the scrutiny proceedings ... apply in relation to the assessment year 2022-23 and subsequent assessment years. Thus, even in view of the aforesaid amendment also, the disallowance under section 14A r/w rule 8D is not permissible in the present case. Accordingly, the same is directed to be deleted. As a result, grounds no.2.a