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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

Yes Bank Limited, Mumbai vs. DCIT - 2(2)(2), Mumbai

In the result, both the appeals of the Revenue and assessee he appeals of the Revenue and assessee are allowed partly for statistical purposes

ITA 3501/MUM/2018[2014-15]Status: DisposedITAT Mumbai30 Jun 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Dcit-2(2)(2), M/S Yes Bank Ltd., Room No. 545, 5Th Floor, 9Th Floor, Nehru Centre, Discovery Of Vs. Aayakar Bhavan, India, Dr. Ab Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent Assessment Year: 2014-15 M/S Yes Bank Ltd., Dcit-2(2)(2), 9Th Floor, Nehru Centre, Room No. 545, 5Th Floor, Aayakar Discovery Of India, Dr. Ab Vs. Bhavan, Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent

For Appellant: Mr. Yogesh Thar/Ms. Ayushi ModaniFor Respondent: Dr. Kishor Dhule, DR
Section 14ASection 251

WITHOUT PREJUDICE TO GROUND NOS. I AND II, WITHOUT PREJUDICE TO GROUND NOS. I AND II, GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF THE ACT: M/s Yes Bank Ltd. ITA Nos.3501 & 3239/M/2018 ... number of treasury deals done in the financial year, has number of treasury deals done in the financial year, has computed the disallowance under section 14A of the Act as computed the disallowance under section 14A of the Act as computed the disallowance under section 14A

DCIT-2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, both the appeals of the Revenue and assessee he appeals of the Revenue and assessee are allowed partly for statistical purposes

ITA 3239/MUM/2018[2014-15]Status: DisposedITAT Mumbai30 Jun 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Dcit-2(2)(2), M/S Yes Bank Ltd., Room No. 545, 5Th Floor, 9Th Floor, Nehru Centre, Discovery Of Vs. Aayakar Bhavan, India, Dr. Ab Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent Assessment Year: 2014-15 M/S Yes Bank Ltd., Dcit-2(2)(2), 9Th Floor, Nehru Centre, Room No. 545, 5Th Floor, Aayakar Discovery Of India, Dr. Ab Vs. Bhavan, Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent

For Appellant: Mr. Yogesh Thar/Ms. Ayushi ModaniFor Respondent: Dr. Kishor Dhule, DR
Section 14ASection 251

WITHOUT PREJUDICE TO GROUND NOS. I AND II, WITHOUT PREJUDICE TO GROUND NOS. I AND II, GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF GROUND NO. III: DISALLOWANCE UNDER SECTION 14A OF THE ACT: M/s Yes Bank Ltd. ITA Nos.3501 & 3239/M/2018 ... number of treasury deals done in the financial year, has number of treasury deals done in the financial year, has computed the disallowance under section 14A of the Act as computed the disallowance under section 14A of the Act as computed the disallowance under section 14A

DCIT Cir. 4(3)(2), Mumbai vs. Morgan Stanley India Co. Pvt. Ltd., Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 2720/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Morgan Stanley India Company P. Ltd, Mumbai vs. Addl CIT 4(3), Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 1714/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

DCIT 4(3), Mumbai vs. Jm Morgan Stanley Securities P. Ltd, Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 2637/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 Jun 2023AY 2003-04
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Morgan Stanley India Company P.Ltd, Mumbai vs. Asst CIT RG 4(3), Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 1952/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 Jun 2023AY 2003-04
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

ACIT 4(3), Mumbai vs. Morgan Stanley India Co. Pvt. Ltd., Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 1235/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Morgan Stanley India Company P.Ltd, Mumbai vs. Addl CIT RG 4(3), Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 1018/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Addl CIT RG 4(3), Mumbai vs. Morgan Stanley India Co P. Ltd, Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 831/MUM/2013[2007-08]Status: DisposedITAT Mumbai30 Jun 2023AY 2007-08
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Morgan Stanley India Company P.Ltd, Mumbai vs. Addl CIT RG 4(3), Mumbai

In the result, appeal of the assessee is partly allowed and ground of the Revenue is dismissed

ITA 7675/MUM/2012[2007-08]Status: DisposedITAT Mumbai30 Jun 2023AY 2007-08
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

transactions) for determining ALP while applying CUP. 1.2 Applicability of TNMM 1.3. To grant benefit of +/- 5 percent u/s. 92C(2) 2 Disallowance under section 14A 3 Disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository under section ... provision of equity broking services, since it was not in accordance with the provisions of section 92CA(1) of the Act 4. Disallowance under section 14A 49. Ground Nos.2.1.1 to 2.3 are similar to the grounds raised in A.Y.2003-04 and 2007-08 wherein following the decisions of the Tribunal

Living Media India Ltd., New Delhi vs. ACIT, Circle-15(2), New Delhi

The appeal is allowed and the consequences shall follow

ITA 7594/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jun 2023AY 2013-14

Bench: Sh. G. S. Pannu, Hon’Ble & Sh. Anubhav Sharmam/S. Living Media India Ltd. Vs. Acit, K-9, Connaught Circus, Circle-15(2), New Delhi-110001 New Delhi Pan : Aaacl0087H (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 14ASection 37(1)

learned Commissioner of Income Tax (Appeals) has failed at appreciate that no objective or cogent satisfaction was recorded while working out the said disallowance under section 14A of the Act and as such the disallowance so made should be deleted. 1.2 That the learned Commissioner of Income Tax (Appeals ... 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

Wartsila India Pvt Ltd., Navi Mumbai vs. Dy CIT 15(3)(1), Mumbai

ITA 480/MUM/2020[2012-13]Status: DisposedITAT Mumbai28 Jun 2023AY 2012-13

Bench: Shri Kuldip Singh & Ms. Padmavathy S

For Appellant: Shri J.D. Mistri, A.RFor Respondent: Shri Manoj Kumar, CIT D.R
Section 14ASection 92CSection 92C(1)

delete the adjustment made u/s.92CA(3) of the Act in respect of delayed recovery of expenses from AE's beyond 30 days. B DISALLOWANCE UNDER SECTION 14A OF THE INCOME TAX ACT, 1961 Rs.73,27,236/- (PARA 17 OF THE ORDER) 10. On the facts and in the circumstances ... confirming the action of the learned DCIT; in invoking the provisions of Rule 8D of the Income Tax Rules, 1962 for computing the disallowance under section 14A of the Income Tax Act, 1961 (the Act) amounting to Rs 73,27,236/-, without considering the facts, circumstances and the submissions

Wartsila India Pvt Ltd, Navi Mumbai vs. Dy CIT 15 (3)(1), Mumbai

ITA 467/MUM/2020[2011-12]Status: DisposedITAT Mumbai28 Jun 2023AY 2011-12

Bench: Shri Kuldip Singh & Ms. Padmavathy S

For Appellant: Shri J.D. Mistri, A.RFor Respondent: Shri Manoj Kumar, CIT D.R
Section 14ASection 92CSection 92C(1)

delete the adjustment made u/s.92CA(3) of the Act in respect of delayed recovery of expenses from AE's beyond 30 days. B DISALLOWANCE UNDER SECTION 14A OF THE INCOME TAX ACT, 1961 Rs.73,27,236/- (PARA 17 OF THE ORDER) 10. On the facts and in the circumstances ... confirming the action of the learned DCIT; in invoking the provisions of Rule 8D of the Income Tax Rules, 1962 for computing the disallowance under section 14A of the Income Tax Act, 1961 (the Act) amounting to Rs 73,27,236/-, without considering the facts, circumstances and the submissions

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

ITA 1992/MUM/2016[2011-12]Status: DisposedITAT Mumbai28 Jun 2023AY 2011-12

Bench: Shri Kuldip Singh & Ms. Padmavathy Sassessment Year: 2011-12

For Appellant: Shri Ninad Patade, A.RFor Respondent: Shri Manoj Kumar, CIT D.R
Section 143Section 144C(1)Section 14ASection 92C

impugned order passed by the AO/DRP that when the assessee has not received any exempt income during the year under consideration no disallowance under section 14A required to be made and further contended that even suo-moto disallowance of Rs.58,53,114/- made under section 14A while computing the total ... earned any exempt income from its investment. By now it is settled principle of law that when there is no exempt income no disallowance under section 14A is required to be made. The co-ordinate Bench of the Tribunal in case of Orix Auto Infrastructure Services Ltd. (supra) decided

Essel Mining & Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 1(4), Mumbai

Appeal is dismissed

ITA 1018/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Jun 2023AY 2014-15
For Appellant: Shri Yogesh TharFor Respondent: Shri Biswanath Das
Section 143(3)Section 14ASection 153ASection 32ASection 801ASection 80I

Assessee at INR 573,39,28,420/- after making a number of additions/disallowances including the following: Sr.No. Particulars Amount (INR) (i) Disallowance under Section 14A of the Act 31,51,33,449/- (ii) Carbon Credit treated as Revenue Income 6,38,56,961/- (iii) Disallowance under Section 32AC ... appeal preferred by the Assessee, the CIT(A) granted relief to the Assessee by directing the Assessing Officer to compute disallowance under Section 14A read with Rule 8D(2)(ii) of the Rules according to the directions issued by the Kolkata Bench of the Tribunal in the case

Oracle Financial Services Software Limited (Formerly Known As I-Flex Solutions Limited), Mumbai vs. Additional Commissioner of Income Tax Range-8(2), Mumbai

In the result, the appeal of the assessee is partly allowed and the appeal of the revenue is treated as partly allowed

ITA 1473/MUM/2018[2006-07]Status: DisposedITAT Mumbai23 Jun 2023AY 2006-07

Bench: Shri B.R. Baskaran (Am) & Smt. Kavitha Rajagopal (Jm)

Section 10ASection 14A

exempt income in the case of Godrej Agrovet Limited (ITA No.934/2011). Following the same, we direct the Assessing Officer to restrict the disallowance under section 14A to 2% of the exempt income. The order of the learned CIT(A) would stands modify accordingly. 8. We shall take up the individual

Standard Chartered Investments & Loan India Ltd, Mumbai vs. DCIT 1(3), Mumbai

Appeal is allowed

ITA 848/MUM/2014[2009-10]Status: DisposedITAT Mumbai23 Jun 2023AY 2009-10
For Appellant: Shri Sanjiv M. ShahFor Respondent: Shri Samuel Pitta
Section 143(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 92C

same. SCCL prays that the DCIT be directed to delete the adjustments made in his order under appeal. GROUND NO. 3: Disallowance under Section 14A of the Act read with Rule 8D - Rs. 900,000 The learned DCIT pursuant to the directions issued by DRP erred in invoking Rule ... make disallowance of INR 9,00,000/- in terms of Rule 8D(2)(iii) of the Rules as the Appellant had made no disallowance under Section 14A of the Act despite earning exempt income. We have considered the rival submissions and perused the 19. material on record. We find merit

DCIT, CC-6(4), Mumbai vs. Ajay Shankarlal Mittal, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 1034/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Jun 2023AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmandcit, Cc – 6(4) Ajayshankarlalmittal, Room No. 1925, 19Th 62-A, Mittal Bhavan, बनाम/ Floor, Air India Bldg Dr.Gopalrao Vs. Nariman Point, Deshmukh Road, Mumbai – 400021. Peddar Road, Mumbai- 400026. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagpm6550R (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr.Ujjawal Kumar .DR
Section 10Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250

case of Cheminvest Ltd v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33, we uphold the plea of the assessee that no disallowance under section 14A was and in the circumstances of the case. The plea of the Assessing Officer is thus rejected". 7.8 The same view that

DCIT, CC-6(4), Mumbai vs. Archana Ajay Mittal, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 1032/MUM/2023[2017-18]Status: DisposedITAT Mumbai20 Jun 2023AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanthe Dcit, Cc-6(4) Archana Ajay Mittal Room No. 1925, 19Th 302, Level-3, Ceejay बनाम/ Floor Air India Bldg, House, Anne Besant Vs. Nariman Point, Road, Worli, Mumbai-400021. Mumbai-400018 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagpm6545C (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Ms.Kavita Kaushik.DRFor Respondent: None
Section 10Section 142(1)Section 143(2)Section 14ASection 250Section 57

case of Cheminvest Ltd vCIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33, we uphold the plea of the assesseethat no disallowance under section 14A was and in the circumstances of the case. The plea of the Assessing Officer is thus rejected". 5.10 The same view that the insertion

Mrs Aruna Paresh Patel, Mumbai vs. Commissioner of Income Tax (Appeal), NFAC, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 1015/MUM/2023[2016-2017]Status: DisposedITAT Mumbai20 Jun 2023AY 2016-2017

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmandcit, Cc – 6(4) Ajayshankarlalmittal, Room No. 1925, 19Th 62-A, Mittal Bhavan, बनाम/ Floor, Air India Bldg Dr.Gopalrao Vs. Nariman Point, Deshmukh Road, Mumbai – 400021. Peddar Road, Mumbai- 400026. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagpm6550R (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr.Ujjawal Kumar .DR
Section 10Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250

case of Cheminvest Ltd v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33, we uphold the plea of the assessee that no disallowance under section 14A was and in the circumstances of the case. The plea of the Assessing Officer is thus rejected". 7.8 The same view that