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“disallowance u/s 14A”

DisallowancesSection 14ASection 14A2,938 judgments

The decision most relied on for disallowance u/s 14A is CIT v. Corrtech Energy (P.) Ltd. (223 Taxmann 130), cited in 579 judgments on BharatTax.

Leading authorities on disallowance u/s 14A

CIT v. Corrtech Energy (P.) Ltd.
223 Taxmann 130 · 2014 · High Court
579
citing judgments

Disallowance under Section 14A read with Rule 8D is not warranted if the assessee has not earned any exempt income in the relevant assessment year.

CIT v. Gem Plus Jewellery India Ltd.
330 ITR 175 · 2011 · High Court
207
citing judgments

Disallowances made under various sections, such as for PF/ESIC contributions, result in an increase in business profits, and these enhanced profits are eligible for deduction under Sections 10A and 10AA. Similarly, gains from foreign exchange fluctuations directly linked to export sales are also eligible for deduction under Section 10A.

Cargo Motors (P.) Ltd. v. DCIT
145 Taxmann.com 641 · 2022 · High Court
46
citing judgments

The disallowance under Section 14A read with Rule 8D, particularly Rule 8D(iii) for administrative expenses, should only consider investments that have actually yielded exempt income during the relevant assessment year. Section 14A empowers the Assessing Officer to determine expenditure related to income not forming part of total income.

Sobha Developers Ltd. v. DCIT
125 Taxmann.com 72 · 2021 · High Court
44
citing judgments

Disallowance under section 14A is a notional disallowance and cannot be added back while computing Book Profits under section 115JB for Minimum Alternate Tax purposes.

Tata Industries Ltd. v. ITO
181 TTJ 600 · 2016 · ITAT
29
citing judgments

Disallowance under Section 14A cannot exceed the exempt income earned by the assessee. Even if interest expenditure is considered, it cannot be solely attributed to earning exempt dividend income as investors also consider potential capital gains.

PCIT v. J.J. Glastronics (P.) Ltd.
139 Taxmann.com 375 · 2022 · High Court
28
citing judgments

Additions made under Section 14A of the Income-tax Act, read with Rule 8D, cannot be considered for computing book profit under Section 115JB of the Act.

M/s.Bajaj Allianz General Insurance Co. Ltd. v. ACIT
38 DTR 282 · 2010 · Reported
26
citing judgments

Section 14A of the Income-tax Act is not applicable to insurance businesses governed by specific provisions of Section 44 and Schedule 1. Profit on sale of investments by insurance companies is not taxable, especially after the deletion of sub-rule (b) of Rule 5 of the First Schedule.

PCIT v. Dipesh Lalchand Shah
143 Taxmann.com 419 · 2022 · High Court
18
citing judgments

Disallowance under section 14A cannot be made if the assessee has not earned any exempt income in the relevant assessment year. This applies even if the assessee has made investments in shares or has income from a partnership that is negative.

Judgments citing disallowance u/s 14A

Deputy Commissioner of Income Tax, Gandhinagar vs. Gujarat State Petroleum Corporation Limited, Gandhinagar

ITA 1254/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 30/03/2021 Notice issued u/s 148 of the Act to disallow u/s. 14A- Average value of investment @ 0.5% which is short deducted by Rs.25,40,345/- 3. Aggrieved against the reassessment orders, assessee filed appeals before ... learned CIT(A) has grossly erred in law in confirming the action of the learned A.O. of reopening the case to increase disallowance u/s. 14A r.w.r. BD of the Act merely due to a change in opinion, despite the appellant having fully disclosed all material facts and information during

Deputy Commissioner of Income Tax, Gandhinagar vs. Gujarat State Petroleum Corporation Limited, Gandhinagar

ITA 1249/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 30/03/2021 Notice issued u/s 148 of the Act to disallow u/s. 14A- Average value of investment @ 0.5% which is short deducted by Rs.25,40,345/- 3. Aggrieved against the reassessment orders, assessee filed appeals before ... learned CIT(A) has grossly erred in law in confirming the action of the learned A.O. of reopening the case to increase disallowance u/s. 14A r.w.r. BD of the Act merely due to a change in opinion, despite the appellant having fully disclosed all material facts and information during

Gujarat State Petroleum Corporation Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

ITA 1166/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 30/03/2021 Notice issued u/s 148 of the Act to disallow u/s. 14A- Average value of investment @ 0.5% which is short deducted by Rs.25,40,345/- 3. Aggrieved against the reassessment orders, assessee filed appeals before ... learned CIT(A) has grossly erred in law in confirming the action of the learned A.O. of reopening the case to increase disallowance u/s. 14A r.w.r. BD of the Act merely due to a change in opinion, despite the appellant having fully disclosed all material facts and information during

Gujarat State Petroleum Corporation Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

ITA 1165/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

Appellate Order by Ld. CIT(A) Appeal dismissed confirming the disallowance made u/s 14A 30/03/2021 Notice issued u/s 148 of the Act to disallow u/s. 14A- Average value of investment @ 0.5% which is short deducted by Rs.25,40,345/- 3. Aggrieved against the reassessment orders, assessee filed appeals before ... learned CIT(A) has grossly erred in law in confirming the action of the learned A.O. of reopening the case to increase disallowance u/s. 14A r.w.r. BD of the Act merely due to a change in opinion, despite the appellant having fully disclosed all material facts and information during

The Bombay Dyeing and Manufacturing Company Limited, Mumbai vs. Income Tax Central Circle 2(1)(1), Mumbai

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

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm & Ms. Kavitha Rajagopal, Am

For Appellant: Shri Yogesh Thar, A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

perusal of the said Rules the expression “value of investment” cannot be interpreted as “fair market value” for the purpose of computing disallowance u/s 14A r.w.r. 8D. At the outset, it is observed that Rule 8D in itself is a self-contained computational mechanism prescribing the method for determining

Reliance Industrial Infrastructure Limited, Mumbai vs. Principal Commissioner of Income Tax -3, Mubmai

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

ITA 3751/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 263Section 37(1)Section 80G

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, AM AND MS. KAVITHA RAJAGOPAL, JM

Meghalaya Energy Corporation Limited Gpf Trust, Lumjingshai, East Khasi Hills vs. ACIT-Circle, Shillong

In the result, the appeal filed by the assessee in ITA No

ITA 240/GTY/2025[2017-18]Status: DisposedITAT Guwahati13 Mar 2026AY 2017-18

Bench: Shriduvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Section 14A

that the assessee has claimed the expenditure towards accrued interest on G.P.F. subscriptions at Rs.6,91,33,739/-. Ld. AO firstly computed the disallowance u/s 14A of the Act at Rs.3,67,13,164/- and thereafter, while dealing with the interest expenditure came to a conclusion that the said expenditures ... direct nexus to income at Rs.3,24,20,575/-. When the issue came before Id. CIT(A), he, on one hand, reduced the disallowance u/s 14A of the Act to the extent of the exempt income but enhanced the interest disallowance to Rs.6,42,82,320/-. The basis of disallowance

ACIT, Circle-5(1), Hyderabad vs. Ushodaya Enterprises Private Limited, Hyderabad

In the result, the appeal of the Revenue in ITA No

ITA 1782/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

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

investment for the financial year 2015-16 2016-17 is Rs.208,03,64,000/- & Rs.352,65,48,000/- respectively. The calculation of disallowance u/s 14A is as under: Opening Investment Closing Investment Average Investment (In Rs.) (In Rs.) (In Rs.) April ... cannot be accepted. 11.18. In view of above discussion, the matter is restored back to the file of AO for recomputing the disallowance u/s 14A in terms of above observations. Thus, revenue's appeal is dismissed and assessee's cross-objection, on the issue in question, stand allowed for statistical

ACIT, Circle-5(1), Hyderabad vs. Ushodaya Enterprises Private Limited, Hyderabad

In the result, the appeal of the Revenue in ITA No

ITA 1781/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

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

investment for the financial year 2015-16 2016-17 is Rs.208,03,64,000/- & Rs.352,65,48,000/- respectively. The calculation of disallowance u/s 14A is as under: Opening Investment Closing Investment Average Investment (In Rs.) (In Rs.) (In Rs.) April ... cannot be accepted. 11.18. In view of above discussion, the matter is restored back to the file of AO for recomputing the disallowance u/s 14A in terms of above observations. Thus, revenue's appeal is dismissed and assessee's cross-objection, on the issue in question, stand allowed for statistical

DCIT Central Circle-5(4), Mumbai vs. Satyam Realtors Private Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 6283/MUM/2024[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Jagadishdcit Cc-5(4), Mumbai Vs Satyam Realtors Private Ltd. Room No.436, 4Th Floor, Room No.4, 3Rd Floor Capri, Anant Kautilya Bhawan, Bandrakurla Kanekar Marg Bandra (East) Complex, Mumbai-400051 Mumbai-400051 Pan:Aaccs7290P Appellant Respondent Assessee By : None, Respondent By : Shri Arun Kanti Datta (Cit Dr) Date Of Hearing : 09/03/2026 Date Of Pronouncement : 13/03/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Revenue Was Preferred Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-53, Mumbai [For Brevity The “Ld. Cit(A)”], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2017-18, Date Of Order 24.09.2024. The Impugned Order Emanated From The Order Of The Ld. Assistant Commissioner Of Income Tax

For Appellant: NoneFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 143(3)Section 14ASection 14A(1)Section 250Section 43B

Income Tax rules by holding that investment which yielded exempt income are only to be considered for the purpose of disallowance u/s 14A r.w.r. 8D(2) and to exclude such investment which did not earn exempt income from the total investment for the purpose of computation of disallowance u/s 14A ... thereby ignoring clarificatory Explanation of disallowance u/s. 14A(1) inserted vide the Finance Act 2022 that the provisions of this section shall apply and shall be deemed to have always applied even in a case when exempt income has not accrued or arises or has not been received during

Bombay Minerals Limited, Khambhalia vs. DCIT, Central Circle 3(3), Mumbai

In the result, appeal of the Revenue

ITA 5410/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

amounting to Rs.6,49,073/- ; (iv) prior period expenses amounting ; (iv) prior period expenses amounting to Rs.46,08,954/- and (vi) disallowance u/s 14A of the Act and (vi) disallowance u/s 14A of the Act and (vi) disallowance u/s 14A of the Act amounting to Rs.1,55,05,320/ amounting ... Revenue are inter connected and are in 4 of the appeal of the Revenue are inter connected and are in relation to disallowance u/s 14A r.w.r. 8D of the Income owance u/s 14A r.w.r. 8D of the Income owance u/s 14A r.w.r. 8D of the Income-tax Rules

Dy. Commissioner of Income Tax, Central Cicle-3(3), Mumbai vs. Bombay Minerals Limited, Gujarat

In the result, appeal of the Revenue

ITA 5409/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

amounting to Rs.6,49,073/- ; (iv) prior period expenses amounting ; (iv) prior period expenses amounting to Rs.46,08,954/- and (vi) disallowance u/s 14A of the Act and (vi) disallowance u/s 14A of the Act and (vi) disallowance u/s 14A of the Act amounting to Rs.1,55,05,320/ amounting ... Revenue are inter connected and are in 4 of the appeal of the Revenue are inter connected and are in relation to disallowance u/s 14A r.w.r. 8D of the Income owance u/s 14A r.w.r. 8D of the Income owance u/s 14A r.w.r. 8D of the Income-tax Rules

Bombay Minerals Limited, Khambhaliya vs. DCIT, Central Circle 3(3), Mumbai

In the result, appeal of the Revenue for AY 2016-17 is

ITA 5408/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Respondent: Mr. Gaurang R. Sanghavi (Virtually
Section 143(3)Section 14ASection 35Section 35(1)(i)Section 36(1)(iii)

employee's contribution to provident fund amounting to Rs.6,49,073/- ; (iv) prior period expenses amounting to Rs.46,08,954/- and (vi) disallowance u/s 14A of the Act amounting to Rs.1,55,05,320/- etc. 4. On further appeal, the Ld. CIT(A) partly allowed the appeal of the assessee ... appeal of the assessee and ground No. 4 of the appeal of the Revenue are inter connected and are in relation to disallowance u/s 14A r.w.r. 8D of the Income-tax Rules, 1962 (in short ‘the Rules'). 5.1 Brief facts qua the issue in dispute are that the Assessee reported

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

circumstances of the case and in law, the Ld. CIT(A) erred in directing the assessing officer to not add the disallowance u/s 14A of the Act, while computing book profit u/s 115JB of the Act without appreciating the fact that clause (f) of explanation 1 to 115JB which provide ... circumstances of the case and in law. the Ld. ClT(A) erred in directing the assessing officer to not add the disallowance u/s 14A of the Act, while computing book profit u/s 115JB of the Act without appreciating the fact that clause (f) of explanation 1 to 115JB which provide

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

circumstances of the case and in law, the Ld. CIT(A) erred in directing the assessing officer to not add the disallowance u/s 14A of the Act, while computing book profit u/s 115JB of the Act without appreciating the fact that clause (f) of explanation 1 to 115JB which provide ... circumstances of the case and in law. the Ld. ClT(A) erred in directing the assessing officer to not add the disallowance u/s 14A of the Act, while computing book profit u/s 115JB of the Act without appreciating the fact that clause (f) of explanation 1 to 115JB which provide

Hcl Training & Staffing Services Private Limited, Nehru Place vs. Circle 11(1), Delhi, I P Estate, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7383/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri Vimal Kumar & Shri Amitabh Shuklaassessment Year : 2017-18

For Appellant: Shri Aditya Vohra, AdvocateFor Respondent: Ms. Ankush Kalra, Senior DR
Section 143(2)Section 143(3)Section 14ASection 234B

vide order dated 05.11.2019 at assessed income of Rs. 50,27,86,300/- after making addition of Rs.60,06,137l- on account of disallowance u/s 14A read with rule 8D. The appellant proceeded to file an appeal before the ld. First Appellate Authority qua invocation of section 14A

Nowrosjee Wadia and Sons Ltd (Sucessor to Sunflower Investment and Textiles Pvt Ltd ), Mumbai vs. ITO Ward 2(3)(2), Mumbai

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

ITA 189/MUM/2026[2014-15]Status: DisposedITAT Mumbai05 Mar 2026AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2014-15 Nowrosjee Wadia & Sons Ltd., Ito, Ward-2(3)(2), (Being Successor To Sunflower Mumbai. Investments & Textiles Pvt. Ltd), Vs. 4Th Floor, Neville House, J.N. Heredia Marg, Balard Estate, Mumbai-400001. Pan : Aaacn1836A (Appellant) (Respondent) For Assessee : Shri Chaitanya Joshi For Revenue : Shri Pravin Salunkhe, Sr.Dr Date Of Hearing : 19-02-2026 Date Of Pronouncement : 05-03-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Chaitanya JoshiFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 10(34)Section 143(2)Section 14A

Rules, 1962 („the Rules‟) and thereafter, considering the submissions filed by the assessee, but not finding the same acceptable, the AO worked out disallowance u/s. 14A of the Act amounting to Rs. 38,26,807/- and after allowing adjustment of suo moto disallowance done by the assessee ... been debited and out of the said expenditure, expenditure towards stamp duty, expenses relating to ROC fees and suo moto disallowance u/s. 14A comes to Rs. 31,24,592/- which has not been claimed by the assessee for income tax purposes and, therefore, the expenses claimed by the assessee

ACIT, Circle- 19(2), New Delhi vs. Pvr Ltd., New Delhi

In the result, the Revenue’s appeals in ITA No

ITA 4071/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 143(3)Section 250(6)

clarificatory in nature. 5. On the facts and in the circumstances of the case, the Id. CIT(A) has erred in deleting the disallowance u/s 14A of Rs.21,77,373/- made by the Assessing Officer for the purpose of computation u/s 1157B. 6. The Appellant craves to add, modify ... deleted the entire addition based on judicial precedents and held that that since there is no investments yielding exempt income, no disallowance u/s 14A is warranted. It is submitted that this is a covered issue in favour of assessee by the consolidated order of the ITAT. 15. Weare

Odean Shrine Multiplex Pvt. Ltd, New Delhi vs. DCIT, Circle- 19(1), New Delhi

In the result, the Revenue’s appeals in ITA No

ITA 3844/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 143(3)Section 250(6)

clarificatory in nature. 5. On the facts and in the circumstances of the case, the Id. CIT(A) has erred in deleting the disallowance u/s 14A of Rs.21,77,373/- made by the Assessing Officer for the purpose of computation u/s 1157B. 6. The Appellant craves to add, modify ... deleted the entire addition based on judicial precedents and held that that since there is no investments yielding exempt income, no disallowance u/s 14A is warranted. It is submitted that this is a covered issue in favour of assessee by the consolidated order of the ITAT. 15. Weare

Pvr Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the Revenue’s appeals in ITA No

ITA 3842/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 143(3)Section 250(6)

clarificatory in nature. 5. On the facts and in the circumstances of the case, the Id. CIT(A) has erred in deleting the disallowance u/s 14A of Rs.21,77,373/- made by the Assessing Officer for the purpose of computation u/s 1157B. 6. The Appellant craves to add, modify ... deleted the entire addition based on judicial precedents and held that that since there is no investments yielding exempt income, no disallowance u/s 14A is warranted. It is submitted that this is a covered issue in favour of assessee by the consolidated order of the ITAT. 15. Weare