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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

ITO WD 2(1) Kol, Kolkata vs. Unicorn Plaza (P) Ltd., Kolkata

In the result, the appeal filed by the revenue is dismissed and cross-objection of the assessee is also dismissed

ITA 2213/KOL/2024[2011-12]Status: DisposedITAT Kolkata19 Nov 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2011-12 Ito, Ward-2(1), Kolkata…………...….……………….……….……….……Appellant Vs. Unicorn Plaza (P) Ltd….………………………………….....……...…..…..Respondent Commerce House, 2A, Ganesh Chandra Avenue Room No.4, 2Nd Floor, Kolkata-700013. [Pan: Aaacu8963B] C.O. 53/Kol/2024 (In Ita No.2213/Kol/2024) Assessment Year: 2011-12 Unicorn Plaza (P) Ltd.….………………. ….……….…….……….……Cross-Objector Commerce House, 2A, Ganesh Chandra Avenue Room No.4, 2Nd Floor, Kolkata-700013. [Pan: Aaacu8963B] Vs. Ito, Ward-2(1), Kolkata ……………………………..…...…..…………….Respondent Appearances By: Shri S. Jhajharia, Fca, Appeared On Behalf Of The Assessee. Shri P. N. Barnwal, Cit- Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : November 03, 2025 Date Of Pronouncing The Order : November 19, 2025 Order Per Pradip Kumar Choubey:

Section 132Section 133ASection 139(1)Section 143(2)Section 14ASection 153ASection 250Section 68Section 69C

added u/s 69C on account of Commission paid to the broker (iii) Expenses of Rs.88,375/- was arbitrarily disallowed u/s 14A of the Act read with Rule 8D(2) of the IT Rules. 3. Aggrieved by the said order, the assessee preferred appeal before the ld. CIT(A) wherein ... under: “Similarly the other additions made by the AO towards unexplained expenditure u/s 69C to the tune of Rs. 32,500/- and the disallowance u/s 14A to the tune of Rs.88,375/- have been made without reference to any incriminating material. ITA No.2213/Kol/2024 & C.O. 53/Kol/2024 Unicorn Plaza

Sterling Finvest Pvt. Ltd., Kolkata vs. DCIT, Cir. 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 113/KOL/2024[2014-15]Status: DisposedITAT Kolkata19 Nov 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Circle-5(1), Sterling Finvst Private Ltd. Aaykar Bhavan 1, Bonafide Lane, First Floor, P-7, Chowringhee Square, Vs. Kolkata-700001, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aacca8245L Assessee By : Shri Abhishek Bansal, Ar Revenue By : Shri P.P. Ranjan, Dr Date Of Hearing: 18.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri P.P. Ranjan, DR
Section 10(38)Section 111ASection 143(3)Section 14ASection 68

sale of equity shares of the said company. 04. In the appellate proceeding, the Learned CIT (A) deleted the addition in respect of disallowance u/s 14A, read with Rule 8D of the Rules, while sustaining the addition of ₹53,84,681 as made by the Learned AO under Section

DCIT 2(3)(1), Mumbai vs. Tata Industries Ltd, Mumbai

Accordingly, Ground No 2(a) & (b) of the revenue in ITA No. 4109/Mum/2012, therefore stands dismissed

ITA 5690/MUM/2015[2006-07]Status: DisposedITAT Mumbai19 Nov 2025AY 2006-07

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI ARUN KHODPIA (Accountant Member)

Section 115JSection 143(3)Section 14ASection 271(1)(c)Section 37Section 40

3157/MUM/2012, which are dealt with and adjudicated as under: 6. Ground No. 1(a), (a-i), (a-ii), (b), (b-ii): Regarding disallowance u/s 14A of the Income Tax Act. 6.1 Apropos, the aforesaid disallowance, Ld. AR referred to the relevant findings from the assessment order, according to which ... appeal before the Ld. CIT(A), wherein the issue was discussed, deliberated, observed and decided as under: 1. Ground 1 is regarding disallowance u/s 14A of Rs. 27,45,00,000/-. The AO has discussed the issue of disallowance u/s. 14A from Para 3.1 to Para 3.22 Page

Addl CIT 2(3), Mumbai vs. Tata Industries Ltd, Mumbai

ITA 4109/MUM/2012[2006-07]Status: DisposedITAT Mumbai19 Nov 2025AY 2006-07
Section 115JSection 143(3)Section 14ASection 271(1)(c)Section 37Section 40

3157/MUM/2012, which are dealt with and adjudicated as under: 6. Ground No. 1(a), (a-i), (a-ii), (b), (b-ii): Regarding disallowance u/s 14A of the Income Tax Act. 6.1 Apropos, the aforesaid disallowance, Ld. AR referred to the relevant findings from the assessment order, according to which ... appeal before the Ld. CIT(A), wherein the issue was discussed, deliberated, observed and decided as under: 1. Ground 1 is regarding disallowance u/s 14A of Rs.27,45,00,000/-. The AO has discussed the issue of disallowance u/s.14A from Para 3.1 to Para 3.22 Page

Infres Methodex Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Circle 12(1), Delhi

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

ITA 449/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Nov 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2017-18] Infres Methodex Pvt. Ltd. Vs Acit Block-B-1, Plot No.D-7, Circle-12(1) Mohan Co-Operative Delhi Industrial Estate, Mathura Road, New Delhi-110044 Pan-Aabci1964R Appellant Respondent Assessee By Shri Rahul Kant, Ca Revenue By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 19.11.2025 Date Of Pronouncement 19.11.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 28.11.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-4/10728/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 23.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Filed Its Return Of Income On 29.10.2017, Declaring Total Income At Inr 22,86,60,530/-. The Assessee Is Engaged In The Business Of Manufacturing & Marketing Of Currency Counting Machines & Verifiers & Paper Shredders Etc. The Case Of The Assessee Was Selected For Scrutiny & The Ao Has Made The Disallowance Of Inr 22,91,385/- U/S 14A Of The Act. Besides This, The Disallowance Of Inr 14,82,901/- Is Made Out Of Payment Made To Clubs & Inr 31,57,057/- Were Disallowed Out Of Travelling & Conveyance Expenses. The Ao Also Made Addition Of Inr 2,02,76,999/- On Account Of Custom Duty Paid By Holding The Same As Unexplained Expenditure.

Section 143(3)Section 14ASection 250Section 37Section 69C

other hand, Ld. Sr. DR for the Revenue supported the orders of the lower authorities and submits that the AO has made disallowance u/s 14A by following the computation provided under Rule 8D of the Income Tax Rules, 1962 (the Rules). Once it is accepted that provisions of section 14A ... necessary verification. 12. Heard both parties and perused the material available on record. With respect to the issue of disallowance u/s 14A of the Act, both the parties have agreed that in the instant case, there is exempt income and assessee has also incurred expenses to earn such exempt income

DCIT, Circle - 19(1), Delhi vs. Ptc India Ltd., Delhi

Appeal of the Revenue is dismissed

ITA 3225/DEL/2024[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 143(3)Section 14ASection 250

direct expenses of INR 15,41,654/- alongwith 18% of the indirect expenses of INR 1,87,40,905/- as amount of disallowance u/s 14A and accordingly, assessee has made total disallowance of INR 49,51,789/- in the return of income filed. 8. It is relevant to state that ... made in Rule 8D of the Rules w.e.f. 01.04.2016, according to which upon satisfied about the correctness of the claim of expenditure, the disallowance u/s 14A would be aggregate of the expenditure directly relatable to earning exempt income and 1% of the average investment i.e. monthly average of opening

Ptc India Limited, Delhi vs. DCIT, Circle-19(1), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 961/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] Ptc India Ltd. Vs Dcit 2Nd Floor, Nbcc Tower, Circle-19(1), Delhi Bhikaji Cama Place, 15, R.K.Puram (Main), New Delhi-110066. Pan-Aabcp7947F Appellant Respondent [Assessment Year : 2018-19] Dcit Vs Ptc India Ltd. Circle-19(1), 2Nd Floor, Nbcc Tower, Delhi Bhikaji Cama Place, 15, R.K.Puram (Main), New Delhi-110066. Pan-Aabcp7947F Appellant Respondent Appellant By Shri Salil Kapoor, Adv. & Ms. Soumya Singh, Adv Respondent By Shri D S Sidhu, Cit Dr Date Of Hearing 25.08.2025 Date Of Pronouncement 19.11.2025

Section 143(3)Section 14ASection 250

direct expenses of INR 15,41,654/- alongwith 18% of the indirect expenses of INR 1,87,40,905/- as amount of disallowance u/s 14A and accordingly, assessee has made total disallowance of INR 49,51,789/- in the return of income filed. 8. It is relevant to state that ... made in Rule 8D of the Rules w.e.f. 01.04.2016, according to which upon satisfied about the correctness of the claim of expenditure, the disallowance u/s 14A would be aggregate of the expenditure directly relatable to earning exempt income and 1% of the average investment i.e. monthly average of opening

Capricon Realty Private Limited, Mumbai vs. Income Tax Officer, Central Circle Mumbai

In the result, the appeal of the assessee is allowed

ITA 5696/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Nov 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2018-19

For Appellant: Ms. Neha ParanjpeFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 143(3)Section 14A

r.w.s. 144B of the Income Tax Act, 1961 („the Act‟) vide order dt. 21-05-2021, wherein the AO made a disallowance u/s. 14A of the Act amounting to Rs. 56,14,060/- which, on appeal by the assessee, has been sustained by the Ld.CIT(A) and against the said ... nowhere in the Assessment order given any specific reason that why the disallowance made by the appellants is not acceptable and the disallowance u/s. 14A ought to be made by applying Rule 8D in the appellants case. The Assessing officer has simply copy pasted the reasons for making disallowance u/s

J.M Financial and Investment Consultancy Service Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 5768/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Nov 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16

For Appellant: Mr. K Shivram a/wFor Respondent: 11/11/2025
Section 14A

Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2015-16, raising following grounds: A) Additional Disallowance u/s. 14A read with Rule 8D, Rs.1,46,29,110/-. J.M. Financial and Investment Consultancy J.M. Financial and Investment Consultancy 2 Services Pvt. Ltd. Recording of satisfaction ... learned CIT(A) 1) The learned CIT(A) failed to appreciate that the appellant failed to appreciate that the appellant had made the disallowance u/s. 14A on a scientific basis had made the disallowance u/s. 14A on a scientific basis had made the disallowance u/s. 14A on a scientific basis

DCIT, Circle - 19(1), Delhi vs. Punjab National Bank, Maharashtra

In the result, appeal of assessee in ITA No

ITA 3039/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri K. Sampath, AdvFor Respondent: Shri Jitender Singh, CIT-DR
Section 115JSection 36(1)Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)

above at the time of hearing of this appeal.” 12. At the very outset, both the rival representatives concurred that the issue of disallowance u/s 14A is a recurring one and is squarely covered in favour of the assessee and against the Revenue by the order Page

Punjab National Bank, Delhi vs. DCIT, Circle-19(1), Delhi

In the result, appeal of assessee in ITA No

ITA 2712/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri K. Sampath, AdvFor Respondent: Shri Jitender Singh, CIT-DR
Section 115JSection 36(1)Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)

above at the time of hearing of this appeal.” 12. At the very outset, both the rival representatives concurred that the issue of disallowance u/s 14A is a recurring one and is squarely covered in favour of the assessee and against the Revenue by the order Page

Assistant Commissioner of Income Tax, Pune vs. Praj Industries Limited, Pune

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

ITA 2096/PUN/2025[2018-19]Status: DisposedITAT Pune14 Nov 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2096/Pun/2025 Assessment Year 2018-19

For Appellant: Shri Amit BobdeFor Respondent: Shri Paresh Shaparia
Section 115JSection 143(1)Section 143(3)Section 14ASection 35

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL

Dabur India Ltd., New Delhi vs. PCIT - 1, New Delhi

In the result, appeal filed by the assessee is allowed

ITA 2075/DEL/2024[2018-19]Status: DisposedITAT Delhi14 Nov 2025AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Shri Sanjeev Kaushal, CITDR
Section 143(3)Section 263Section 32Section 35Section 35(1)Section 80GSection 80I

impact of accounting standards in the light of auditor's notes regarding financial statements, necessary addition or disallowance may be made. 4. The disallowance u/s 14A may be verified and examined. 5. The AO may examine the allowability of deduction u/s 80JJAA as the conditions of the section need ... verify and examine, as already submitted before the Pr. CIT that the assessee need not exempt income and in such circumstances no disallowance u/s 14A of the Act can be made as held by various High Courts and the Hon’ble Supreme Court from time to time (See separate note

Pure Home & Living Private Limited (Formerly Known As Dlf Brands Private Limited), New Delhi vs. Assisstant Commissioner of Income Tax, New Delhi

In the result, appeal of the Assessee is allowed

ITA 2349/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Nov 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2349/Del/2025 िनधा"रणवष"/Assessment Year:2017-18 बनाम Pure Home & Living Private Acit, Limited, Vs. Circle 7(1), (Formerly Known As Dlf Brands C.R. Building, Ito, Private Limited), New Delhi. 204, Ground F/F, Okhla Industrial Estate, Phase-Iii, New Delhi. Pan No.Aafca7971E अपीलाथ" Appellant ""यथ"/Respondent

Section 14ASection 14A(2)Section 250

total disregard to past history and decision of Hon’ble ITAT in assessee’s own case in preceding years wherein the disallowance u/s 14A was deleted on identical ground. 2.4 That in any case, in absence of recording of proper satisfaction in terms of section 14A(2), the disallowance made ... condoned and the appeal is admitted. 4. Coming to the merits the Ld. Counsel for the assessee submitted that the Assessing Officer made disallowance u/s 14A read with Rule 8D of the Act even though there was no exempt income earned by the assessee during the assessment year under consideration

Deputy Commissioner of Income Tax, Central Circle -1, Ludhiana vs. Aarti International Ltd., Ludhiana

In the result, appeal filed by the Revenue is dismissed

ITA 464/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashish Aggarwal, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 133ASection 142(1)Section 143(1)Section 143(2)Section 145(3)Section 14ASection 69

notices and detailed questionnaires u/s 142(1) were issued, to which the assessee made online submissions. During scrutiny, several issues arose related to disallowance u/s 14A, eligibility of depreciation of the Machiwara unit, unexplained excess stock found during survey, and fall in gross profit rate, which led to further verification

Rico Auto Industries Limited, Ludhiana vs. Pr. Commissioner of Income Tax-1, Ludhiana

The appeals stand allowed in terms of our above order

ITA 703/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh10 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.702/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.703/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) M/S Rico Auto Industries Ltd. Pr. Cit-1 बनाम/ B-26, Focal Point Aaykar Bhawan, Rishi Nagar Vs. Ludhiana (Punjab)-141010 Ludhiana (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-8724-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Twin Appeals, The Assessee Assails Proposed Revision Of The Assessment Order By Revisionary Authority U/S 263 For Assessment Years (Ay) 2020-21 & 2021-22. Facts Are Stated To Be Identical In Both The Years. First, We Take Up Appeal For Ay 2020-21 Wherein The Assessee Challenges Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr.

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) (Virtual) – Ld. DR
Section 142(1)Section 143(3)Section 263Section 35

assessee. The details of major expenses with complete details were filed. In show-cause notice dated 11-03-2022, Ld. AO proposed disallowance u/s 14A as well as u/s 40(a)(ia). A specific query was raised on discrepancy in turnover. The assessee duly replied to the same along with

Rico Auto Industries Limited, Ludhiana vs. Pr. Commissioner of Income Tax-1, Ludhiana

The appeals stand allowed in terms of our above order

ITA 702/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.702/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.703/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) M/S Rico Auto Industries Ltd. Pr. Cit-1 बनाम/ B-26, Focal Point Aaykar Bhawan, Rishi Nagar Vs. Ludhiana (Punjab)-141010 Ludhiana (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-8724-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Twin Appeals, The Assessee Assails Proposed Revision Of The Assessment Order By Revisionary Authority U/S 263 For Assessment Years (Ay) 2020-21 & 2021-22. Facts Are Stated To Be Identical In Both The Years. First, We Take Up Appeal For Ay 2020-21 Wherein The Assessee Challenges Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr.

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) (Virtual) – Ld. DR
Section 142(1)Section 143(3)Section 263Section 35

assessee. The details of major expenses with complete details were filed. In show-cause notice dated 11-03-2022, Ld. AO proposed disallowance u/s 14A as well as u/s 40(a)(ia). A specific query was raised on discrepancy in turnover. The assessee duly replied to the same along with

Ramanagaram Enterprises Private Limited, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, both the appeals filed by the assessee are allowed for statistical purposes in terms of our observations given hereinabove

ITA 1306/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Nov 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 115JSection 143(3)Section 14ASection 7

proceedings are completed. 9. The learned Commissioner of Income Tax (Appeals), has erred in dismissing the appeal as non-maintainable without adjudicating the disallowance u/s 14A of the Income Tax Act, 1961. 10. The learned Commissioner of Income Tax (Appeals), has erred in treating the appeal filed by the appellant

Ramanagaram Enterprises Private Limited, Hyderabad vs. ACIT., Circle-16(1), Hyderabad

In the result, both the appeals filed by the assessee are allowed for statistical purposes in terms of our observations given hereinabove

ITA 1305/HYD/2024[2017-18]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 115JSection 143(3)Section 14ASection 7

proceedings are completed. 9. The learned Commissioner of Income Tax (Appeals), has erred in dismissing the appeal as non-maintainable without adjudicating the disallowance u/s 14A of the Income Tax Act, 1961. 10. The learned Commissioner of Income Tax (Appeals), has erred in treating the appeal filed by the appellant

Nitin Dwarkadas Nyati, Pune vs. Assistant Commissioner of Income Tax, Pune

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

ITA 1251/PUN/2025[2020-21]Status: DisposedITAT Pune04 Nov 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

For Appellant: Shri Krishn V GujarathiFor Respondent: Shri Ratnakar Bhimrao Shelake
Section 143(1)Section 143(2)Section 143(3)Section 14A

assessing the total income at Rs.40,41,76,243/- after making addition of Rs.3,05,36,389/- on account of disallowance u/s 14A of the Act and Rs.50,79,854/- on account of education cess. 3. So far as the disallowance of Rs.3,05,36,389/- u/s 14A read with ... onwards and therefore, this amendment is applicable for the year under consideration. 5. In appeal, the Ld. CIT(A) partly allowed the disallowance u/s 14A read with Rule 8D and confirmed the disallowance of education cess. 6. Aggrieved with such order of the Ld. CIT(A), the assessee