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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

Ircon International Ltd., New Delhi vs. Addl. CIT, Circle-12(2), New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 5460/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Jan 2022AY 2012-13

Bench: Sh. A. D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Rakesh Gupta, Adv. &For Respondent: Ms. Meenakshi J. Goswami, CIT(DR)
Section 801ASection 80I

consideration, respectfully following the findings of the co-ordinate bench, we direct the Assessing Officer to allow deduction u/s 80IA of the Act. Disallowance u/s 14A: 5. During the year, the assessee had income from tax free bonds of Rs.12.39 crores and claimed the same as exempt u/s ... same ratio applies. The appeal of the revenue on this ground is dismissed. ITA No. 2401 & Ors 18 M/s. Ircon International Ltd. DTAA Disallowance u/s 14A: 25. The appeal of the revenue on this ground is dismissed in view of the ratio laid down with regard to the income through

M/S. Ghaziabad Development Authority, New Delhi vs. DCIT (E), Ghaziabad

In the result, both the appeals of the assessee are allowed

ITA 1829/DEL/2017[2006-07]Status: DisposedITAT Delhi28 Jan 2022AY 2006-07

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 2137/Del/2016 : Asstt. Year : 2010-11 Ita No. 2138/Del/2016 : Asstt. Year : 2011-12 M/S Ireo Waterfront Pvt. Ltd., Vs Acit, 5, Dhanraj Chambers, 1St Floor, Central Circle-26, Satbari, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaccv2433R Assessee By : Sh. S. Krishnan, Adv. Revenue By : Ms. Meenakshi J. Goswami, Cit Dr Date Of Hearing: 28.10.2021 Date Of Pronouncement: 28.01.2022

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 132Section 14ASection 153ASection 37(1)

there is no call to go into the technicalities of the issue. Hence, the appeal of the assessee on this ground is allowed. Disallowance u/s 14A: 6. Not pressed. Disallowance ABP expenses: 7. During the year, the assessee incurred an amount of Rs.4.72 crores on account of advertisement and business

M/S. Ghaziabad Development Authority, New Delhi vs. ACIT, Ghaziabad

In the result, both the appeals of the assessee are allowed

ITA 1828/DEL/2017[2003-04]Status: DisposedITAT Delhi28 Jan 2022AY 2003-04

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 2137/Del/2016 : Asstt. Year : 2010-11 Ita No. 2138/Del/2016 : Asstt. Year : 2011-12 M/S Ireo Waterfront Pvt. Ltd., Vs Acit, 5, Dhanraj Chambers, 1St Floor, Central Circle-26, Satbari, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaccv2433R Assessee By : Sh. S. Krishnan, Adv. Revenue By : Ms. Meenakshi J. Goswami, Cit Dr Date Of Hearing: 28.10.2021 Date Of Pronouncement: 28.01.2022

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 132Section 14ASection 153ASection 37(1)

there is no call to go into the technicalities of the issue. Hence, the appeal of the assessee on this ground is allowed. Disallowance u/s 14A: 6. Not pressed. Disallowance ABP expenses: 7. During the year, the assessee incurred an amount of Rs.4.72 crores on account of advertisement and business

M/S Ireo Waterfront Private Ltd., New Delhi vs. DCIT, New Delhi

In the result, both the appeals of the assessee are allowed

ITA 2138/DEL/2016[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi28 Jan 2022

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 2137/Del/2016 : Asstt. Year : 2010-11 Ita No. 2138/Del/2016 : Asstt. Year : 2011-12 M/S Ireo Waterfront Pvt. Ltd., Vs Acit, 5, Dhanraj Chambers, 1St Floor, Central Circle-26, Satbari, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaccv2433R Assessee By : Sh. S. Krishnan, Adv. Revenue By : Ms. Meenakshi J. Goswami, Cit Dr Date Of Hearing: 28.10.2021 Date Of Pronouncement: 28.01.2022

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 132Section 14ASection 153ASection 37(1)

there is no call to go into the technicalities of the issue. Hence, the appeal of the assessee on this ground is allowed. Disallowance u/s 14A: 6. Not pressed. Disallowance ABP expenses: 7. During the year, the assessee incurred an amount of Rs.4.72 crores on account of advertisement and business

M/S Ireo Waterfront Private Ltd., New Delhi vs. DCIT, New Delhi

In the result, both the appeals of the assessee are allowed

ITA 2137/DEL/2016[2010-11]Status: DisposedITAT Delhi28 Jan 2022AY 2010-11

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 2137/Del/2016 : Asstt. Year : 2010-11 Ita No. 2138/Del/2016 : Asstt. Year : 2011-12 M/S Ireo Waterfront Pvt. Ltd., Vs Acit, 5, Dhanraj Chambers, 1St Floor, Central Circle-26, Satbari, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaccv2433R Assessee By : Sh. S. Krishnan, Adv. Revenue By : Ms. Meenakshi J. Goswami, Cit Dr Date Of Hearing: 28.10.2021 Date Of Pronouncement: 28.01.2022

For Appellant: Sh. S. Krishnan, AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 132Section 14ASection 153ASection 37(1)

there is no call to go into the technicalities of the issue. Hence, the appeal of the assessee on this ground is allowed. Disallowance u/s 14A: 6. Not pressed. Disallowance ABP expenses: 7. During the year, the assessee incurred an amount of Rs.4.72 crores on account of advertisement and business

DCIT, New Delhi vs. M/S. Ircon International Ltd., New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 528/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2022AY 2007-08

Bench: Sh. A. D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Rakesh Gupta, Adv. &For Respondent: Ms. Meenakshi J. Goswami, CIT(DR)
Section 801ASection 80I

consideration, respectfully following the findings of the co-ordinate bench, we direct the Assessing Officer to allow deduction u/s 80IA of the Act. Disallowance u/s 14A: 5. During the year, the assessee had income from tax free bonds of Rs.12.39 crores and claimed the same as exempt u/s ... same ratio applies. The appeal of the revenue on this ground is dismissed. ITA No. 2401 & Ors 18 M/s. Ircon International Ltd. DTAA Disallowance u/s 14A: 25. The appeal of the revenue on this ground is dismissed in view of the ratio laid down with regard to the income through

Jsw Investment Pvt Ltd., Mumbai vs. Dy CIT 5 (2)(1), Mumbai

In the result, both the appeals are dismissed

ITA 8007/MUM/2019[2012-13]Status: DisposedITAT Mumbai27 Jan 2022AY 2012-13
For Appellant: Hiro RaiFor Respondent: Ujjawal Kumar
Section 10(34)Section 14A

treated as withdrawn. Therefore, the appeal of the assessee is stand dismissed. 4. During the course of assessment the assessing officer has computed disallowance u/s 14A r.w.rule 8D of the I.T Rule to the amount of Rs.87,04,68,604/- u/s 14A of the Act in respect of dividend income

Sun Vaccum Formers Pvt. Ltd., New Delhi vs. ACIT, Central Circle-6, New Delhi

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

ITA 1965/DEL/2018[2014-15]Status: DisposedITAT Delhi24 Jan 2022AY 2014-15

Bench: Shri N.K. Billaiya & Shri Amit Shukla

For Appellant: Ms. Apoorva Bhardwaj, CAFor Respondent: Shri Kumar Pranav, Senior DR
Section 143(3)Section 14A

incurred any expenditure which can be directly said to be related to earning of any exempt income. Thereafter, AO proceeded to make disallowance u/s 14A at Rs.19,52,949/- and after reducing the amount disallowed by the assessee itself, the final disallowance was computed at Rs.9 ... Before us, ld. counsel has filed a comparative detail showing disallowance u/s 14A and the computational aspect by the assessee vis-à-vis AO as well as ld. CIT(A) which was for the sake of ready reference is reproduced as under :- 7. Ld. Counsel submitted that the only dispute

Universal Buildwelll (P) Ltd., New Delhi vs. Addl. CIT, New Delhi

The appeal of the assessee stands allowed

ITA 1166/DEL/2017[2011-12]Status: DisposedITAT Delhi24 Jan 2022AY 2011-12

Bench: The Ld.

Section 14ASection 40A(2)(b)Section 41(1)

Disallowance of mutation expenses – Rs. 98,000/- 2. Disallowance of filing fee and Registration charges paid to ROC – Rs. 1,11,242/- 3. Disallowance u/s 14A – Rs. 28,44,995/- 4. Disallowance of depreciation on unsold stock – Rs. 7,81,806/- 5. Disallowance on commitment charges

Sunayana Commercial P. Ltd., Mumbai vs. Pr. CIT -City-3, Mumbai

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

ITA 900/MUM/2021[2011-12]Status: DisposedITAT Mumbai20 Jan 2022AY 2011-12

Bench: Shri Promod Kumar ()And Ms. Suchitra Kamble () Assessment Year: 2011-12 Sunayana Commercial Pvt. Ltd., Pr. Commissioner Of Income Tax, 609, 6Th Floor, Inizio, Cardial Vs. City-3, Room No. 612, 6Th Floor, Gracious Road, Opp. P & G Plaza, Andheri (East), Aayakarbhavan, Maharshikarve Mumbai-400099. Road, Mumbai-400020. Pan No. Aajcs 4896 A Appellant Respondent Assessee By : Mr. Prakash Jhunjhunwala, Ar Revenue By : Mr. Harendra Narayan Singh, Cit-Dr Date Of Hearing : 11/01/2022 Date Of Pronouncement : 20/01/2022

For Appellant: Mr. Prakash Jhunjhunwala, ARFor Respondent: Mr. Harendra Narayan Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 14ASection 263Section 263d

Assessing Officer Ward-15(2), Kolkata has given reasons which are as under : Sunayana Commercial Pvt. Ltd. 3 Thereafter the Assessing Officer made disallowance u/s 14A towards ₹5,84,041/-. Sunayana Commercial Pvt. Ltd. 4 4. The Pr. CIT vide notices dated 19.03.2020, 05.03.2020 u/s 263 of the Income ... documents more specifically mentioned in the reply filed by the assessee along with audited accounts has taken cognizance and made the disallowance u/s 14A r.w. Rule 8D. Therefore, the interest of the Revenue was protected by the Assessing Officer by taking cognizance of the evidences produced before the Assessing Officer

Security Printing & Minting Corporation of India Ltd., New Delhi vs. Addl. CIT, Range- 8, New Delhi

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2018[2011-12]Status: DisposedITAT Delhi18 Jan 2022AY 2011-12

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing)

For Appellant: Sh. Y. K. Maghan, CAFor Respondent: Sh. H. K. Choudhary, CIT DR
Section 10(34)Section 143(3)Section 14ASection 263Section 40

Mint, Kolkata 7. There remains stock of Gold, Silver and other precious metals in various located mints. Gold and Silver is also refined. Disallowance u/s 14A: 8. During previous year 2010-11, the assessee has received dividend from UTI Treasury Advantage Fund under Institutional Plan Scheme amounting to Rs.4 ... order u/s 263 on dated 30.03.2016 setting aside the order passed u/s 143(3) dated 28.02.2014 with the direction to AO to make disallowance u/s 14A. Following to the direction of the ld. PCIT(8), the Assessing Officer passed the revised assessment order u/s 263/143(3) dated 19.12.2016 by making

Dy CIT CC-2(3), Mumbai vs. Gauri Avinash Bhosale, Mumbai

Appeal of the Revenue is dismissed

ITA 244/MUM/2021[2013-14]Status: DisposedITAT Mumbai17 Jan 2022AY 2013-14

Bench: Shri Promod Kumar ()And Ms. Suchitra Kamble () Assessment Year: 2013-14

For Appellant: Mr. Vijay Mehta, ARFor Respondent: Mr.Hoshang B. Irani, DR
Section 10(38)Section 132Section 132(1)Section 143(1)Section 143(3)Section 14ASection 153A

section10(38) of the Income Tax Act. 2. On the fact and circumstances of the case the Ld.CIT(A) erred in deleting the disallowance u/s 14A for A. Y. 2015-16 without appreciating the fact that circular no. 5 of 2014 dated 11th February, 2014, issued by the Central Board ... admitted : 1. The learned CIT (A) ought to have held that disallowance of claim of carry forward of long-term capital loss and disallowance u/s 14A of the Act by the Assessing Officer are bad in law since no incriminating material pertaining to the same was found during the course

Excel Industries Ltd., Mumbai vs. The CIT -CC-6(3), Mumbai

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

ITA 238/MUM/2021[2016-17]Status: DisposedITAT Mumbai13 Jan 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleexcel Industries Ltd Vs. The Cit-Cc 6(3) 184-87, Excel Estate, 19Th Floor, Air India Sv Road, Jogeshwari Bldg, Nariman Point, (West)Mumbai – 400102 Mumbai – 400 021. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaace2488F Appellant .. Respondent Appellant By : Mr.Kirit Kamdar. Ar Respondent By : Mr.Ajay Kumar. Dr Date Of Hearing 13.01.2022 Date Of Pronouncement 19.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Cit(A)-54, Mumbai Passed U/S 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal. 1. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Erred In Confirming The Action Of The Ao In Disallowing A Sum Of Rs. 1,00,50,000/- Out Of Interest Paid Attributable To Loan To A Subsidiary. 2. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Erred In Confirming The Action Of The Ao In Levying An Amount Of Rs. 5,42,910/- On Account Excel Industries Ltd, Mumbai. Of Interest U/S 115P For Dividend Distributed Under Section 115-O, For Which Dividend Distribution Tax Had Already Been Paid. 3. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Erred In Not Adjudicating The Ground On Additions Made To Book Profits U/S 115Jb.

For Appellant: Mr.Kirit Kamdar. ARFor Respondent: Mr.Ajay Kumar. DR
Section 115Section 115JSection 115PSection 143(2)Section 143(3)Section 14ASection 36(1)(iii)

subsequent year and disallowed Rs. 23,05,497/- in the current Asst year.(ii) On the second disputed issue, the A.O made disallowance u/s 14A r.w.r 8D(2) of the IT Rules of Rs. 17,20,492/-(iii) The A.O. found that the assessee has claimed Rs.8 ... case and directed the A.O to delete the addition. Similarly, the CIT(A) has granted relief to the assessee in respect of disallowance u/s 14A r.w.s 8D(2) of the Rules and directed the A.O to recompute the disallowance u/s 14A of the Act considering the investments which yielded exempt

Vijay Steel Corporation P.Ltd, Mumbai vs. DCIT 13 (3)(2), Mumbai

In the result, the assessee appeal

ITA 6928/MUM/2018[2013-14]Status: DisposedITAT Mumbai13 Jan 2022AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Pavan Kumar Gadale & M/S. Vijay Steel Vs. Dcit 13(3)2 Corporation Pvt Ltd Mumbai.-400020 2 Sabhapati Bhavan, 19 Meena Baugh, Santacruz (West) Mumbai-400054 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacv3517E Appellant .. Respondent Appellant By : Mr.Vivek Jain. Ar Respondent By : Mr.Hoshang B Irani. Dr Date Of Hearing 17.12.2021 Date Of Pronouncement 27.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Mr.Vivek Jain. ARFor Respondent: Mr.Hoshang B Irani. DR
Section 133(6)Section 143(2)Section 143(3)Section 271(1)(c)Section 40A(2)(b)Section 44ASection 68

Vijay Steel Corporation Pvt Ltd Rs.8,85,61,790) of total purchases worked out to Rs.88,56,179/-.(v) the A.O has made disallowance u/s 14A r.w.r 8D(2) (ii) & (iii) of IT Rules Rs.32,04,273/- as the assessee has not disallowed any expenditure for earning the exempted income

Hdfc Bank Ltd (Successor to Businss of Centurion Bank of Punjab Ltd), Mumbai vs. DCIT 2(3), Mumbai

In the result, appeal is partly allowed

ITA 374/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Jan 2022AY 2008-09

Bench: Shri G.S.Pannu (Hon’Ble) & Shri Saktijit Dey (Hon’Ble)

Section 14A

Appellant's submissions that the investments has been made from own funds and internal cash accrual. 4. The Appellant prays that the disallowance u/s 14A r.w.r 8D of Rs.3,66,00,000/- be deleted. 5. Without prejudice, the Appellant prays that disallowance be appropriately reduced. GROUND

Holtec Consulting Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range - 4, New Delhi

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 5891/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Jan 2022AY 2014-15

Bench: Shri R.K. Panda & Ms. Suchitra Raghunath Kamble

For Appellant: Shri Atul Ninawat, C.AFor Respondent: Shri Kumar Padmapani Bora, Sr
Section 10Section 14A

income. From the perusal of the computation of total income filed by the assessee, he noted that an amount of Rs.79,880/- was disallowed u/s 14A of the Income Tax Act, 1961. Since the amount disallowed by 5 ITA.No.5891/Del./2018 M/s. Holtec Consulting India Pvt. Ltd., New Delhi ... from these two LLPs amounting to Rs.4,62,09,397/- which have been claimed exempt u/s 10(2A). The AO worked out the disallowance u/s. 14A r.w. Rule 8D at Rs.l,04,14,880/-and 6 ITA.No.5891/Del./2018 M/s. Holtec Consulting India Pvt. Ltd., New Delhi. after reducing

DCIT-4(3)(1), Mumbai vs. Jhp Securities Pvt. Ltd., Mumbai

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

ITA 5739/MUM/2019[2013-14]Status: DisposedITAT Mumbai12 Jan 2022AY 2013-14

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaledcit-4(3)(1) Vs. Jhp Securities Pvt Ltd Room No. 649, 6Th Floor 201, Dev Neo Vikranm, Aayakar Bhavan, Mk New Link Road, Road, Mumbai –400020 Andheri (W), Mumbai – 400053. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacj2847H Appellant .. Respondent Appellant By : Mr.S N Kabra. Dr Respondent By : Mr. Vasudev Ginde .Ar Date Of Hearing 05.01.2022 Date Of Pronouncement 17.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Mr.S N Kabra. DRFor Respondent: Mr. Vasudev Ginde .AR
Section 143(2)Section 143(3)Section 14A

interest. Finallythe A.O. has charged the interest @ 18.5%p.a. on the balances and worked out Rs.1,58,19,304/-.The A.O has made disallowance u/s 14A r.w.r 8D of I T Rules of Rs. 65,747/- after setting off the amount offered of Rs. 10,000/- and Assessed the total ... overdue balance of trade receivables is not mandatory and directed the Assessing officer to delete the addition. Whereas in respect of disallowance u/s 14A r.w.r8D of I T rules, the CIT(A) has granted partial relief and partly allowed the assessee appeal. Aggrieved by the CIT(A)order, the Revenue

Dy CIT Central Cir-2(3), Mumbai vs. Amit Avinash Bhosale, Pune

In the result, appeal filed by the Revenue for the A

ITA 166/MUM/2021[2015-16]Status: DisposedITAT Mumbai11 Jan 2022AY 2015-16

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Ms. Shailja Rai
Section 10(38)Section 127(2)Section 132Section 153A

raised following ground in its appeal: - “2. On the fact and circumstances of the case the Ld. CIT(A) erred in deleting the disallowance u/s 14A or A.Y. 2015-16 without appreciating the fact that circular no. 5 of 2014 dated 11th February, 2014, issued by the Central Board ... investments, income from which is exempt from tax. All such books maintained on consolidated basis. Therefore, there is no question of making any disallowance u/s 14A as far as income from these above mentioned three proprietary businesses are concerned. The submission of assessee is duly considered and the same

Dy. CIT CC- 2(3), Mumbai vs. Amit Avinash Bhosale, Pune

In the result, appeal filed by the Revenue for the A

ITA 165/MUM/2021[2018-19]Status: DisposedITAT Mumbai11 Jan 2022AY 2018-19

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Ms. Shailja Rai
Section 10(38)Section 127(2)Section 132Section 153A

raised following ground in its appeal: - “2. On the fact and circumstances of the case the Ld. CIT(A) erred in deleting the disallowance u/s 14A or A.Y. 2015-16 without appreciating the fact that circular no. 5 of 2014 dated 11th February, 2014, issued by the Central Board ... investments, income from which is exempt from tax. All such books maintained on consolidated basis. Therefore, there is no question of making any disallowance u/s 14A as far as income from these above mentioned three proprietary businesses are concerned. The submission of assessee is duly considered and the same

Dy CIT CC-2(3), Mumbai vs. Avinash Nivrutti Bhosale, Pune

In the result, appeal filed by the Revenue for the A

ITA 123/MUM/2021[2015-16]Status: DisposedITAT Mumbai11 Jan 2022AY 2015-16

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Ms. Shailja Rai
Section 10(38)Section 127(2)Section 132Section 153A

raised following ground in its appeal: - “2. On the fact and circumstances of the case the Ld. CIT(A) erred in deleting the disallowance u/s 14A or A.Y. 2015-16 without appreciating the fact that circular no. 5 of 2014 dated 11th February, 2014, issued by the Central Board ... investments, income from which is exempt from tax. All such books maintained on consolidated basis. Therefore, there is no question of making any disallowance u/s 14A as far as income from these above mentioned three proprietary businesses are concerned. The submission of assessee is duly considered and the same