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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

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd, Mumbai vs. Commissioner of Income Tax(Appeal)--50, Mumai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

inflated capital expenditure of Rs.45,23,580/- d) Disallowance of claim of depreciation on alleged inflated capital expenditure of Rs.68,53,590/- e) Disallowance u/s 14A of Rs.2,72,16,530/- f) Addition on account of difference in stock of Rs.10,82,560/- Adjustments to book profits under MAT provisions ... well as the additions/disallowance made on merit. However, ld. CIT(A) has decided all the issues against the assessee except for the disallowance u/s 14A against the revenue. Against the order of ld. CIT(A), assessee has filed the present appeals. Further, aggrieved by the relief provided

Mahadhan Agritech Limited (Formerly Knwon As Smartech Technologies Ltd ), Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai-50, Mumbai

In the result, the appeals filed by the assessee are

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 115JSection 132Section 143(3)Section 153ASection 69A

inflated capital expenditure of Rs.45,23,580/- d) Disallowance of claim of depreciation on alleged inflated capital expenditure of Rs.68,53,590/- e) Disallowance u/s 14A of Rs.2,72,16,530/- f) Addition on account of difference in stock of ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited 16 Rs.10 ... well as the additions/disallowance made on merit. However, ld. CIT(A) has decided all the issues against the assessee except for the disallowance u/s 14A against the revenue. Against the order of ld. CIT(A), assessee has filed the present appeals. Further, aggrieved by the relief provided

Mahadhan Agritech Limited (Formerly Known As Smartech Technologies Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai.50, Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

inflated capital expenditure of Rs.45,23,580/- d) Disallowance of claim of depreciation on alleged inflated capital expenditure of Rs.68,53,590/- e) Disallowance u/s 14A of Rs.2,72,16,530/- f) Addition on account of difference in stock of Rs.10,82,560/- Adjustments to book profits under MAT provisions ... well as the additions/disallowance made on merit. However, ld. CIT(A) has decided all the issues against the assessee except for the disallowance u/s 14A against the revenue. Against the order of ld. CIT(A), assessee has filed the present appeals. Further, aggrieved by the relief provided

United Bank of India, Kolkata vs. DCIT, Ltu, Circle - 1, Kolkata

In the result, the Revenue’s appeal is dismissed (ITA No

ITA 428/KOL/2018[2013-14]Status: DisposedITAT Kolkata23 Jul 2025AY 2013-14

Bench: the ITAT. The grounds may be extracted for reference:

Section 115JSection 14ASection 15JSection 211Section 250Section 36(1)(viii)

completely arbitrary, unjustified and illegal. 3. For that on the facts of the case, the Ld. CIT(A) was wrong in restricting the disallowance u/s. 14A amounting to Rs. 1.47 crores by invoking Rule 8D(2)(iii), but shares are held as stock-in-trade to the assessee bank, therefore ... also perused the relevant material available on record. The learned counsel for the assessee has submitted that a similar issue relating to the disallowance u/s 14A of the Act read with Rule 8D was involved in assessee's own case for A.Y. 2010-11 and the coordinate bench of this

DCIT/ACIT, Ltu - 1, Kolkata vs. M/S. United Bank of India, Kolkata

In the result, the Revenue’s appeal is dismissed (ITA No

ITA 215/KOL/2018[2013-14]Status: DisposedITAT Kolkata23 Jul 2025AY 2013-14

Bench: the ITAT. The grounds may be extracted for reference:

Section 115JSection 14ASection 15JSection 211Section 250Section 36(1)(viii)

completely arbitrary, unjustified and illegal. 3. For that on the facts of the case, the Ld. CIT(A) was wrong in restricting the disallowance u/s. 14A amounting to Rs. 1.47 crores by invoking Rule 8D(2)(iii), but shares are held as stock-in-trade to the assessee bank, therefore ... also perused the relevant material available on record. The learned counsel for the assessee has submitted that a similar issue relating to the disallowance u/s 14A of the Act read with Rule 8D was involved in assessee's own case for A.Y. 2010-11 and the coordinate bench of this

Nagreeka Foils Ltd., Kolkata vs. D.C.I.T., Circle - 3, Kolkata

In the result, all the three appeals filed by the assessee for AYs

ITA 1930/KOL/2024[2011-2012]Status: DisposedITAT Kolkata22 Jul 2025AY 2011-2012

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 14ASection 250Section 36

Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A), who deleted the disallowance u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 of ₹75,58,500/- and further disallowance of 0.5% of the average value of investments ... taxmann.com 124 (Calcutta)/[2022] 287 Taxman 134 (Calcutta)/[2023] 453 ITR 547 (Calcutta)[22-02-2022] in support of the claim that the disallowance u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 should be made by taking into consideration only those shares which

Nagreeka Foils Ltd., Kolkata vs. D.C.I.T., Circle - 6(3), Kolkata

ITA 1789/KOL/2024[2013-2014]Status: DisposedITAT Kolkata22 Jul 2025AY 2013-2014
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 2(24)(x)Section 36Section 40a

Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A), who deleted the disallowance u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 of ₹75,58,500/- and further disallowance of 0.5% of the average value of investments

Nagreeka Foils Ltd., Kolkata vs. D.C.I.T., Circle - 3(1), Kolkata

In the result, all the three appeals filed by the assessee for AYs

ITA 1788/KOL/2024[2010-2011]Status: DisposedITAT Kolkata22 Jul 2025AY 2010-2011

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 14ASection 250Section 36

Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A), who deleted the disallowance u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 of ₹75,58,500/- and further disallowance of 0.5% of the average value of investments ... taxmann.com 124 (Calcutta)/[2022] 287 Taxman 134 (Calcutta)/[2023] 453 ITR 547 (Calcutta)[22-02-2022] in support of the claim that the disallowance u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962 should be made by taking into consideration only those shares which

Makson Pharmaceuticals(India) Private Limited, Surendranagar vs. Pr. CIT, Ahmedabad-3, Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 1017/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jul 2025AY 2018-19
For Appellant: Shri M J Ranpura, A.RFor Respondent: Shri Alpesh Parmar, CIT. DR
Section 143(3)Section 14ASection 263

discussed above and direct the Assessing Officer to pass a fresh assessment order and disallow the claim for excess depreciation and also make disallowance u/s 14A r.w Rule 8D of the Act.” ITA No. 1017/Ahd/2024 [Makson Pharmaceuticals (India) Private Limited vs. PCIT] A.Y. 2018-19 - 5 – 7. We have heard ... Profit & loss account and even in this scenario, no disallowance would be made as no expenditure is debited in Profit & loss account. Thus, disallowance u/s 14A of the Act is depended upon investments made by assessee and not on earning of exempt income or incurring of expenditure for earning exempt

ACIT Circle 10(1), New Delhi vs. Ircon International Ltd, New Delhi

In the result, both appeals of the Revenue are dismissed as above

ITA 1108/DEL/2023[2017-18]Status: DisposedITAT Delhi18 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

Ircon International Ltd. S. N. Particulars Amount (Rs.) A. Disallowance of Provision for maintenance 16,80,01,189/- B. Disallowance u/s 14A of the Act read with 13,40,49,649/- Rule 8D C. Unwinding of provisions against 1,36,65,459/- maintenance and demobilization Besides, the AO also disallowed ... Counsel submitted that the issues of (i) claim of deduction under section 80IA of the Act, (ii) disallowance of provision of maintenance, (iii) disallowance u/s 14A r.w. rule 8D, (iv) unwinding of provisions against maintenance and demobilization and (v) addition under MAT were covered by the decisions

ACIT, Circle-10(1), New Delhi vs. Ircon International Ltd, New Delhi

In the result, both appeals of the Revenue are dismissed as above

ITA 1104/DEL/2023[2018-19]Status: DisposedITAT Delhi18 Jul 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

Ircon International Ltd. S. N. Particulars Amount (Rs.) A. Disallowance of Provision for maintenance 16,80,01,189/- B. Disallowance u/s 14A of the Act read with 13,40,49,649/- Rule 8D C. Unwinding of provisions against 1,36,65,459/- maintenance and demobilization Besides, the AO also disallowed ... Counsel submitted that the issues of (i) claim of deduction under section 80IA of the Act, (ii) disallowance of provision of maintenance, (iii) disallowance u/s 14A r.w. rule 8D, (iv) unwinding of provisions against maintenance and demobilization and (v) addition under MAT were covered by the decisions

DCIT-2(3)(1), Mumbai vs. Indusind Bank Ltd., Mumbai

In the result, the Income Tax Appeal is

ITA 3675/MUM/2023[2018-19]Status: DisposedITAT Mumbai17 Jul 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Kalpexh Unadkat &For Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

exempt income. The ld. AO applied the computation mechanism provided in Rule 8D(2) of the Income Tax Rules and worked out the disallowance u/s 14A of the Act as under:- Under Rule 8D(2)(ii) Under Rule 8D(2)(iii) Rs 9.63 crores Rs 0.72 crores Rs 10.35 crores ... disallowance made under Rule 8D(2)(iii) of the Rules. With regard to yet another submission made by the assessee that the disallowance u/s 14A of the Act per se could not be made in the instant case as the investments were admittedly held as stock in trade

Indusind Bank Ltd, Mumbai vs. The DCIT-2(3)(1), Mumbai

In the result, the Income Tax Appeal is

ITA 1842/MUM/2023[2019-20]Status: DisposedITAT Mumbai17 Jul 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

exempt income. The ld. AO applied the computation mechanism provided in Rule 8D(2) of the Income Tax Rules and worked out the disallowance u/s 14A of the Act as under:- Under Rule 8D(2)(ii) Under Rule 8D(2)(iii) Rs 9.63 crores Rs 0.72 crores Rs 10.35 crores ... disallowance made under Rule 8D(2)(iii) of the Rules. With regard to yet another submission made by the assessee that the disallowance u/s 14A of the Act per se could not be made in the instant case as the investments were admittedly held as stock in trade

Sbl Private Limited, Haridwar, Uttrakhand vs. PCIT (Central), Delhi-2, New Delhi

Appeal is allowed

ITA 2231/DEL/2024[A.Y. 2018-19]Status: DisposedITAT Delhi17 Jul 2025

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2018-19

Section 143(3)Section 14ASection 263

letter dated 18.06.2021 addressed to AO. Perusal of the assessment order reflects that there is no discussion on the aspect of disallowance u/s 14A of the Act r.w. Rule 8D of IT Rules. It is apparent that the AO failed to correctly apply the provisions of section 14A r.w. rule ... revision directions. The Revenue’s first and foremost argument is that the assessee has admittedly been found not to have computed administrative expenses disallowance u/s 14A read with Rule 8D as it suo motu disallowed a sum of Rs. 20 lakhs only. That being the case the Revenue could hardly

Sky Ama Infra Private Limited, Ludhiana, Punjab vs. DCIT, CC-2, Ludhiana

The appeal stand partly allowed

ITA 396/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh15 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.396/Chandi/2023 (िनधा"रणवष" / Assessment Year: 2018-19) M/S Sky Ama Infra Private Limited Dcit 5Th Floor Grand Walk Mall बनाम/ Vs. Central Circle-2 Ferozepur Road, Ludhiana. 141012 Ludhiana. 141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aarcs-5725-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Rajesh Mehru (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 19-04-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 02-02-2021. The Sole Grievance Of The Assessee Is Confirmation Of Disallowance U/S 14A For Rs.79.21 Lacs. Having Heard Rival

For Appellant: Shri Rajesh Mehru (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 115JSection 143(3)Section 14A

Assessing Officer [AO] u/s. 143(3) of the Act on 02-02-2021. The sole grievance of the assessee is confirmation of disallowance u/s 14A for Rs.79.21 Lacs. Having heard rival submissions and upon perusal of case records, the appeal is disposed- off as under. 2. The assessee received exempt ... Rs.863.10 Lacs on equity investment made in an entity M/s Fastway Transmissions Pvt. Ltd. (FTPL). However, the assessee did not offer any disallowance u/s 14A on the plea that no expense was incurred to earn the dividend income. However, rejecting the same, Ld. AO computed indirect expense disallowance

DCIT-2(1)(1), Mumbai vs. Dsp Adiko Holdings Pvt. Ltd., Mumbai

In the result, the appeal of revenue is dismissed

ITA 1694/MUM/2025[2017-18]Status: DisposedITAT Mumbai15 Jul 2025AY 2017-18

Bench: Shri Pawan Singh& Shri Ms. Padmavathy S (Physical Hearing) Dcit, Circle – 2(1)(1), Mumbai Dsp Adiko Holdings Pvt. Ltd. Room No. 575, 5Th Floor, 24-26, 1St Floor, Cama Building, Vs Aayakar Bhavan, M.K. Road, Dalal Street, Fort, Mumbai – 400023. Mumbai – 400020. [Pan: Aaaca3438M] Appellant / Revenue Respondent / Assessee

Section 14ASection 254(1)

appeal: “1. Whether, on the facts and circumstances of the case and in law, the Ld CIT(A) erred in restricting the disallowance u/s 14A of the IT Act 1961 to the extent of suo-moto disallowance made by the assessee as against the disallowance made

Netplast Pvt.Ltd., Kanpur vs. ACIT Circle 2(3)(1), Kanpur

In the result, the appeal of the assessee is partly allowed

ITA 320/LKW/2024[2017-18]Status: DisposedITAT Lucknow10 Jul 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 133(6)Section 142(1)Section 143(3)Section 14ASection 69C

against returned income of Rs.4,39,90,420/-. In the aforesaid assessment order, an addition of Rs.34,518/- was made by making disallowance u/s 14A of the Act. Further an addition of Rs.84,00,000/- was made u/s 69C of the Act. Aggrieved, the assessee filed appeal in the office ... filed appeal in the office of learned CIT(A) and vide impugned appellate order dated 18/03/2024, the learned CIT(A) confirmed the aforesaid disallowance u/s 14A of the Act. The relevant portion of the order of the learned CIT(A) is reproduced below: 6.ISSUE 2-DISALLOWANCE U/S 14A.GROUND NO.6 COVERED

Precision Camshafts Ltd., Solapur vs. Assessment Unit, Income Tax Department (NFAC), Solapur

In the result, appeal of the assessee is allowed

ITA 1962/PUN/2024[2020-21]Status: DisposedITAT Pune10 Jul 2025AY 2020-21

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

Section 143(3)Section 144BSection 144C(5)Section 92(3)Section 928Section 92C

earned by the Assessee. 6. On the facts and circumstances of the case and in law, the Ld.AO has erred by enhancing the disallowance u/s 14A by Rs.46,40,245 ignoring ITA No.1962/PUN/2024 [A] the fact that the Assessee had already disallowed Rs. 450,000 in the return of income ... Ld.AR ITA No.1962/PUN/2024 [A] submitted that the disallowance made by the AO u/s.14A may be deleted. Ld.AR submitted that there cannot be disallowance u/s 14A more than the exempt income earned. Assessee had already made disallowance u/s14A to the extent of exempt income earned. Submission of ld.DR : 3. Ld.DR

R.D.Enterprises, Mumbai vs. DCIT, Circle 17(3), Mumbai

In the result, ground no. 1, 2 & 3 of the appeal are allowed

ITA 2980/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Jul 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) R.D. Enterprises Dcit, Circle – 17(3), Mumbai. C-65, Mittal Court, Nariman Point, Vs Kautilya Bhavan, G Block, Mumbai – 400001. Bandra (East), [Pan No. Aaafr1977R] Mumbai – 400051. Appellant / Assessee Respondent / Revenue

Section 115BSection 14ASection 153(3)Section 254(1)Section 68

consideration of appellant’s written submissions, remand proceedings and remand report thereby violating the principle of natural justice. 2. Confirmation of disallowance u/s 14A r.w.r. 8D of the IT Act of Rs. 17,60,725/-. 3. Addition of Rs. 8,95,72,000/- as unexplained cash credit u/s

Income Tax Officer, Delhi vs. Mahak Industries Private Limited, Delhi

In the result the cross objection of the assessee is allowed

ITA 661/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jul 2025AY 2015-16

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 142(1)Section 143(3)Section 14ASection 250Section 36(1)(iii)

total income of Rs.3,05,48,790/- by making following additions/disallowances: (i) Rs.74,55,681/- as interest on loans (ii) Rs.23,76,398/- disallowance u/s 14A (iii) Rs.2,07,10,000/- Unexplained & Unverified Sundry Creditors. 4. Against such order, the assessee filed an appeal before