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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

M/S. Bd & P Hotels (India ) Pvt. Ltd, Mumbai vs. DCIT, Central Circle -1(4), Mumbai

The appeal is allowed

ITA 1628/MUM/2022[2014-15]Status: DisposedITAT Mumbai15 Nov 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Dcit,Cc-1(4) M/S Bd & Hotels (India) Pvt. Room No. 902, 9 Th Floor, Old Ltd. Cgo Bldg, Ground Floor, Db House, Gen. Vs. A.K.Vaidya Marg, Goregoan (E), M.K.Road, Mumbai-400 063 Mumbai- 400 063 (Appellant) (Respondent) Pan No. Aabcb4615J Assessee By : Shri. Siddharth Kothari, Ca Revenue By : Shri. Chetan M. Kacha, Sr. Ar. Date Of Hearing: 15.11.2022 Date Of Pronouncement : 15.11.2022

For Appellant: Shri. Siddharth Kothari, CAFor Respondent: Shri. Chetan M. Kacha, Sr. AR
Section 14Section 143(3)Section 14A

against appeal of assessee challenging the assessment order passed under section 143(3) of the Income Tax Act, 1961 dated 27.12.2016 wherein disallowance under section 14A read with rule 8D of ₹76,22,179/- was dismissed. The assessee has raised the following grounds of appeal: “1. The learned Assessing Officer ... section 14 of the Act. The assessee submitted that, the assessee is holding strategic investment and has not earned any exempt income. Therefore, disallowance under section 14A cannot be made. The learned Assessing Officer rejected the argument of the assessee. He held M/s. BD & P Hotels (INDIA

Deputy CIT-5(1)(1), Mumbai vs. M/S Essar Shipping Limited, Mumbai

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

ITA 821/MUM/2022[2015-16]Status: DisposedITAT Mumbai14 Nov 2022AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri M Balaganesh, Am आयकरअपीलसं./ I.T.A. No. 821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2015-16) M/S Essar Shipping Dy. Cit-Circle – 5(3)(1), Limited R. No. 568, Aayakar बिधम/ Essar House, 11, K K Bhavan, M. K. Road, Vs. Marg, Mahalaxmi, Mumbai-400 020 Mumbai-400 034 स्थायीलेखासं./जीआइआरसं./ Pan No. Aacce3707D (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Prakash R. Mane, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Manoj Patwari/ Shri Rishav Patwari, Ld. Ars सुनवाईकीतारीख/ : 18.08.2022 Date Of Hearing घोषणाकीतारीख / : 14.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Impugned Order Dated 28.02.2022, Passed By Ld. Cit (Appeals)-56, Mumbai For The Quantum Of Assessment Passed U/S 143(3) R.W.S.

For Appellant: Shri Prakash R. ManeFor Respondent: Shri Manoj Patwari/ Shri
Section 115VSection 143(3)Section 28Section 43Section 92Section 92F

company, whose income was computed under the special provisions of Chapter XII-G. The Tribunal set aside the addition observing thus' No disallowance under section 14A is warranted in this case when the assessee has admittedly not claimed any expenditure, towards taxable income i.e. it has not claimed any deduction

Keystone Realtors Pvt Ltd, Mumbai vs. Dy CIT CC 2(4), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 611/MUM/2020[2014-15]Status: DisposedITAT Mumbai14 Nov 2022AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Shri Rakesh Ranjan
Section 14ASection 250Section 37

assessee is in appeal before us. 6. The issue arising in ground No. 1, raised in assessee’s appeal, is pertaining to disallowance under section 14A r/w Rule 8D of the Income Tax Rules, 1962. Keystone Realtors Pvt. Ltd. ITA No.3004/Mum./2019 ITA No.611/Mum./2020 ITA No.4229/Mum./2019 ITA No.1228/Mum ... case pertaining to this issue are: During the course of assessment proceedings, the assessee was asked to show cause why the disallowance under section 14A of the Act be not made. In response, assessee submitted that it has already disallowed Rs. 7,49,654, under section 14A for the year

Keystone Realtors Pvt Ltd., Mumbai vs. Dy CIT CC 2(4), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 1228/MUM/2020[2015-16]Status: DisposedITAT Mumbai14 Nov 2022AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Shri Rakesh Ranjan
Section 14ASection 250Section 37

assessee is in appeal before us. 6. The issue arising in ground No. 1, raised in assessee’s appeal, is pertaining to disallowance under section 14A r/w Rule 8D of the Income Tax Rules, 1962. Keystone Realtors Pvt. Ltd. ITA No.3004/Mum./2019 ITA No.611/Mum./2020 ITA No.4229/Mum./2019 ITA No.1228/Mum ... case pertaining to this issue are: During the course of assessment proceedings, the assessee was asked to show cause why the disallowance under section 14A of the Act be not made. In response, assessee submitted that it has already disallowed Rs. 7,49,654, under section 14A for the year

Keystone Realtors Pvt Ltd., Mumbai vs. DCIT, Central Circle-2(4), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 4229/MUM/2019[2015-16]Status: DisposedITAT Mumbai14 Nov 2022AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Shri Rakesh Ranjan
Section 14ASection 250Section 37

assessee is in appeal before us. 6. The issue arising in ground No. 1, raised in assessee’s appeal, is pertaining to disallowance under section 14A r/w Rule 8D of the Income Tax Rules, 1962. Keystone Realtors Pvt. Ltd. ITA No.3004/Mum./2019 ITA No.611/Mum./2020 ITA No.4229/Mum./2019 ITA No.1228/Mum ... case pertaining to this issue are: During the course of assessment proceedings, the assessee was asked to show cause why the disallowance under section 14A of the Act be not made. In response, assessee submitted that it has already disallowed Rs. 7,49,654, under section 14A for the year

Keystone Realtors Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 2(4), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 3004/MUM/2019[2013-14]Status: DisposedITAT Mumbai14 Nov 2022AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Shri Rakesh Ranjan
Section 14ASection 250Section 37

assessee is in appeal before us. 6. The issue arising in ground No. 1, raised in assessee’s appeal, is pertaining to disallowance under section 14A r/w Rule 8D of the Income Tax Rules, 1962. Keystone Realtors Pvt. Ltd. ITA No.3004/Mum./2019 ITA No.611/Mum./2020 ITA No.4229/Mum./2019 ITA No.1228/Mum ... case pertaining to this issue are: During the course of assessment proceedings, the assessee was asked to show cause why the disallowance under section 14A of the Act be not made. In response, assessee submitted that it has already disallowed Rs. 7,49,654, under section 14A for the year

Raymond Limited, Mumbai vs. Addl C.I.T. -2(3), Mumbai

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

ITA 2660/MUM/2008[2002-2003]Status: DisposedITAT Mumbai14 Nov 2022AY 2002-2003

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Raymond Limited V. Addl. Cit– Range 2(3) New Hind House 5Th Floor, Aayakar Bhavan Narottam Morarjee Marg M.K. Road, Mumbai - 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A (Appellant) (Respondent) Acit–2(3) V. M/S. Raymond Limited Room No. 555 New Hind House Aayakar Bhavan, Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A (Appellant) (Respondent)

For Appellant: Shri Nitesh Joshi &For Respondent: Shri Samuel Pitta
Section 115JSection 14ASection 35DSection 92C

amount invested from time to time in such investments and accordingly, the learned Assessing Officer was not justified in making the aforesaid disallowance under section 14A of the Act. 3 ITA NO. 2660& 2519/MUM/2008 (A.Y: 2002-03) M/s. Raymond Limited 4. The Commissioner of Income Tax (Appeals) erred in disallowing

M/S. ACIT 2(3), Mumbai vs. Raymond Ltd., Mumbai

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

ITA 2519/MUM/2008[2002-2003]Status: DisposedITAT Mumbai14 Nov 2022AY 2002-2003

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Raymond Limited V. Addl. Cit– Range 2(3) New Hind House 5Th Floor, Aayakar Bhavan Narottam Morarjee Marg M.K. Road, Mumbai - 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A (Appellant) (Respondent) Acit–2(3) V. M/S. Raymond Limited Room No. 555 New Hind House Aayakar Bhavan, Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A (Appellant) (Respondent)

For Appellant: Shri Nitesh Joshi &For Respondent: Shri Samuel Pitta
Section 115JSection 14ASection 35DSection 92C

amount invested from time to time in such investments and accordingly, the learned Assessing Officer was not justified in making the aforesaid disallowance under section 14A of the Act. 3 ITA NO. 2660& 2519/MUM/2008 (A.Y: 2002-03) M/s. Raymond Limited 4. The Commissioner of Income Tax (Appeals) erred in disallowing

Praxair India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

ITA 200/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Nov 2022AY 2016-17
For Respondent: Shri T. Suryanarayana
Section 92C

case in AY 2008-09 which Page 5 of 20 IT(TP)A No. 200/Bang/2021 directed the learned AO to delete the disallowance under section 14A of the Act on the basis that original investments in the Appellant's case were not geared or intended for earning exempt income such ... case in AY 2008-09 Page 6 of 20 IT(TP)A No. 200/Bang/2021 which directed the learned AO to delete the disallowance under section 14A of the Act in computation of book profits under section 115JB of the Act on the basis that section 115JB

M/S United Breweries Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

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

ITA 481/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 40Section 43B

Officer made following disallowances / additions to the returned income of the assessee:- Particulars Amount in Rs. Depreciation on goodwill 3,73,88,587 Disallowance under section 14A 1,31,50,663 Disallowance under section 40(a)(ia) 8,24,77,951 Disallowance under section 43B 49,27,979 Foreign royalty ... fund available during the year is more than sufficient to cover this investment. The CIT(A) therefore provided partial relief and held that disallowance under section 14A is not called for on the value of fresh investment of Rs.6 lakhs made by the assessee during the year. As regards

ACIT CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd (Successor to M/S Bellissimo Hi-Rise Builders Pvt Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 490/MUM/2022[2014-15]Status: DisposedITAT Mumbai10 Nov 2022AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Niraj ShethFor Respondent: Shri Tejinder Pal Singh Anand
Section 143(3)Section 14ASection 250Section 253(3)Section 36(1)(iii)

Revenue is dismissed. 8. The issue arising in ground No. 2, raised in Revenue’s appeal is pertaining to deletion of disallowance under section 14A r/w Rule 8D of the Income Tax Rules, 1962. 9. The brief facts of the case pertaining to this issue are: During the course ... No.490/Mum./2022 investment of Rs. 1,02,49,010, in shares of subsidiary companies. The assessee was asked to explain why disallowance under section 14A r/w Rule 8D should not be made. In response thereto assessee submitted that it has not earned any exempt income during the year and therefore

DCIT-Ltu - 2, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2958/MUM/2019[2010-11]Status: DisposedITAT Mumbai07 Nov 2022AY 2010-11
Section 143(3)Section 14A

Officer, is paragraph 6.1 of the assessment order that “during the year, the assessee has not received any dividend income” and yet a disallowance under section 14A is made. This is also an assessment year prior to the insertion of Explanation to section 14A, by the Finance Act 2022. Dealing ... 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. As regards the disallowance

Mahindra & Mahindra Ltd, Mumbai vs. ACIT RG 2(2)(2), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 7287/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Nov 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri H.P. MahajaniFor Respondent: Smt. Mahita Nair
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 92C

learned ACIT erred in proposing and the DRP erred in rejecting the claim of the Appellant that section 115JB does not provide for disallowance under section 14A of Rs.40,14,67,454 for the purpose of computing the Book profit u/s 118JB The claim of the Appellant be accepted ... raised in assessee‟s appeal is allowed. 15. The issue arising in ground No. 3, raised in assessee‟s appeal, is pertaining to disallowance under section 14A read with Rule 8D. `Mahindra & Mahindra Ltd. ITA No.7287/Mum./2018 16. The brief facts of the case pertaining to this issue are: During

Asst CIT Ltu, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 6405/MUM/2013[2007-08]Status: DisposedITAT Mumbai07 Nov 2022AY 2007-08
Section 143(3)Section 28

fact that the assessee had earned tax exempt dividends aggregating to Rs 1,61,03,487, and did not offer any disallowance under section 14A in respect of expenses incurred to earn this tax-exempt income. The Assessing Officer computed the disallowance by invoking rule 8D and computed the same ... Tribunal in assessee’s own cases for the assessment years 2005-06 and 2006-07. Respectfully following the same, we restrict the disallowance under section 14A to 1% of tax-exempt income. Ordered, accordingly. The assessee gets the relief accordingly. As regards the question of adjustment of book profits under

R K Powergen P Ltd, Chennai vs. PCIT Central I Chennai, Chennai

In the result, the primary condition to invoke the revisional jurisdiction u/s 263 remains unsatisfied

ITA 259/CHNY/2022[2017-18]Status: DisposedITAT Chennai02 Nov 2022AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri V. Ravichandran (CA) – Ld. ARFor Respondent: Shri S. Senthilkumaran (CIT) – Ld. DR
Section 143(3)Section 14ASection 263

case. 2. The Learned PCIT has erred in holding that the order of assessment was erroneous when the Assessing Officer had restricted the disallowance under Section 14A to the amount of exempt income received applying the decisions of the Hon'ble Supreme Court of India and the Hon'ble Madras ... amendment to Rule 8D with effect from Assessment Year 2017-18 the principle of law enunciated by the various courts that the disallowance under Section 14A could not exceed the quantum of exempt income would no longer apply. 4. The Learned PCIT ought to have appreciated that Section 14A

Infiniti Retail Ltd, Mumbai vs. Chief CIT (OSD) (I/C. Pr. CIT - 2 ), Mumbai

In the result, appeal of the assessee is allowed

ITA 3685/MUM/2019[2013-14]Status: DisposedITAT Mumbai31 Oct 2022AY 2013-14
Section 115JSection 143(3)Section 263Section 32(1)

returned loss of the assessee: Sr. No. Particulars Amount (in Rs) Business loss as per return of income (53,26,02,366) Add: Disallowance under section 14A of the 53,31,545 Act Add: Disallowance of stock revaluation 5,57,94,825 Add: Disallowance of advance written

Sudharsan Logistics Private Limited, Chennai vs. ACIT, Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 809/CHNY/2022[2013-2014]Status: DisposedITAT Chennai28 Oct 2022AY 2013-2014

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.809/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Sudharsan Logistics Private Ltd., Vs. The Assistant Commissioner Of New No. 24 & 25, S T Tower, Parrys, Income Tax, Chennai 600 001. Non Corporate Circle 18, Chennai. [Pan:Aaacs8428K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate & Shri Saroj Kumar Parida, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 26.10.2022 घोषणा की तारीख /Date Of Pronouncement : 28.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), New Delhi, Dated 25.07.2022 Relevant To The Assessment Year 2013-14. 2. The Appeal Filed By The Assessee Is Delayed By Three Days In Filing The Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition In The Form Of An Affidavit To Condone The Delay. Since The 2

For Appellant: Shri R. Vijayaraghavan, Advocate &For Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(3)Section 14A

Assessing Officer has completed the assessment under section 143(3) of the Income Tax Act, 1961 [“Act” in short] dated 31.03.2016 by making disallowance under section 14A r.w. Rule 8D for ₹.11,75,118/-. On appeal, by order dated 26.09.2018, the ld. CIT(A) directed the Assessing Officer to verify

Assisstant Commissioner of Income Tax-14(1)(2), Mumbai vs. Schoolnet India Ltd., Mumbai

In the result, the present appeal is dismissed

ITA 2015/MUM/2022[2014-15]Status: DisposedITAT Mumbai28 Oct 2022AY 2014-15
For Appellant: NoneFor Respondent: Shri Sanyam Suresh Joshi
Section 115JSection 143(3)Section 14A

submission advanced by the Ld. Departmental Representative and perused the material on record. We note that the CIT(A) has deleted the disallowance under Section 14A of the Act, inter alia, on the ground that (a) the Assessing Officer has failed to record his dissatisfaction regarding the disallowance/computation under Section ... assessee in respect of such expenditure. The aforesaid mandatory requirement has not been fulfilled by the Assessing Officer before making the disallowance under section 14A of the Act Reliance is drawn in the case of Essilor India (P) Ltd v. Deputy Commissioner of Income-tax [2022] 137 taxmann.com 60 (Karnataka

Umesh A Mishra, Mumbai vs. ITO 8(2)(4), Mumbai

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

ITA 870/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Oct 2022AY 2009-10
Section 143Section 250Section 28Section 30Section 37

learned CIT(A) and dismiss this ground of appeal filed by the assessee. Ground No. 4 11. The assessee has challenged the disallowance under section 14A r.w.r. 8D amounting to Rs.1,70,995/-. Briefly stated the assessee has received dividend of Rs. 3,290/- on investment in shares

ACIT Circle-3 (1)(2), Mumbai vs. M/S Force Appliances Pvt Ltd., Mumbai

In the result, the present appeal is dismissed

ITA 7560/MUM/2019[2013-14]Status: DisposedITAT Mumbai27 Oct 2022AY 2013-14
For Appellant: Shri Jay DharoodFor Respondent: Shri Achal Sharma
Section 10(34)Section 143(3)Section 14A

been claimed to be exempt under Section 10(34) of the Act. Therefore, the CIT(A) restricted the disallowance under Section 14A of the Act to INR 6,27,811/- and deleted the balance disallowance made by ITA. No. 7560/Mum/2019 Assessment Year: 2013-14 the Assessing Officer under Section 14A ... before us. We have considered the rival submission and perused the material on record. We note that the CIT(A) has restricted the disallowance under Section 14A of the Act to the amount of exempt income (INR 6,27,811) by following the decision of the Hon‟ble Supreme Court