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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

Gyan Enterprises Pvt Ltd, New Delhi vs. DCIT Circle 10(2), New Delhi

ITA 92/DEL/2024[2017-18]Status: DisposedITAT Delhi27 May 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

over and above the disallowance made by the appellant. 7.1 I have considered the assessment order and the submissions of the appellant. The disallowance u/s 14A is in 3 parts. Each of the parts is discussed in the subsequent paragraphs 7.2 Clause (i) This pertains to expenses directly related ... Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted income and hence the would qualify under clause (i) of Rule 8D for purposes of calculation the disallowance u/s 14A of the Act. 7.2.2 Legal and Professional fees of Rs 15.30 lakhs These expenses have been incurred for legal fees, legal, professional and consultancy

ACIT(OSD), Range-10, New Delhi, C.R. Building ITO vs. Gyan Enterprises Pvt. Ltd., Rouse Avenue, New Delhi

ITA 176/DEL/2024[2015-16]Status: DisposedITAT Delhi27 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

over and above the disallowance made by the appellant. 7.1 I have considered the assessment order and the submissions of the appellant. The disallowance u/s 14A is in 3 parts. Each of the parts is discussed in the subsequent paragraphs 7.2 Clause (i) This pertains to expenses directly related ... Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted income and hence the would qualify under clause (i) of Rule 8D for purposes of calculation the disallowance u/s 14A of the Act. 7.2.2 Legal and Professional fees of Rs 15.30 lakhs These expenses have been incurred for legal fees, legal, professional and consultancy

ACIT(OSD), Range-10, New Delhi, C.R. Building, ITO New Delhi vs. Gyan Enterprises Pvt. Ltd., Punjabi Bhawan, Delhi

ITA 109/DEL/2024[2014-15]Status: DisposedITAT Delhi27 May 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

over and above the disallowance made by the appellant. 7.1 I have considered the assessment order and the submissions of the appellant. The disallowance u/s 14A is in 3 parts. Each of the parts is discussed in the subsequent paragraphs 7.2 Clause (i) This pertains to expenses directly related ... Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted income and hence the would qualify under clause (i) of Rule 8D for purposes of calculation the disallowance u/s 14A of the Act. 7.2.2 Legal and Professional fees of Rs 15.30 lakhs These expenses have been incurred for legal fees, legal, professional and consultancy

E-Ally Securities (India) Pvt. Ltd., Raigad vs. DCIT Circle, Panvel

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

ITA 109/PUN/2025[2018-19]Status: DisposedITAT Pune26 May 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

For Appellant: Shri Samir ShahFor Respondent: Shri Shashank Ojha - JCIT
Section 143(2)Section 14A

earned only Rs.2,000/- as exempt income which the assessee itself has disallowed. Relying on various decisions, it was submitted that the disallowance u/s 14A cannot exceed the exempt income. 5. However, the Assessing Officer was not satisfied with the arguments advanced by the assessee. Applying the provisions of section ... Rs.20,27,023/-. However, in the submission made on 22/03/2024, the appellant has requested this office to direct the AO to restrict the disallowance u/s 14A r.w Rule 8D for the remaining amount of Rs.8,61,197/-. The submission uploaded has been carefully considered and found that since, there were

Suraj International, Kolkata vs. D.C.I.T., Circle - 34, Kolkata

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

ITA 2518/KOL/2024[2012-2013]Status: DisposedITAT Kolkata26 May 2025AY 2012-2013

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 143(2)Section 143(3)Section 14ASection 288ASection 50C

assessee as under: Total income as per return Rs. 29,18,150/- Add: i) Addition u/s 50C Rs. 28,10,344/- ii) Disallowance u/s 14A read with Rule 8D Rs. 7,92,190/ iii) Disallowances of interest on TDS and Insurance Policy Rs. 4,37,667/- iv) Disallowances of depreciation

Kailash Motors, Kanpur vs. Assistant Commissioner of Income Tax, Range- II, Kanpur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 695/LKW/2017[2013-14]Status: DisposedITAT Lucknow23 May 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

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

assessee. The Assessing Officer, in the assessment order dated 27/02/2015 passed u/s 143(3)/254 of the I. T. Act, made the aforesaid disallowance u/s 14A of the Act. Being aggrieved, the assessee preferred appeal before the learned CIT(A). The assessee’s appeal against the aforesaid disallowance of Rs.30

Kailash Motors, Kanpur vs. Astt. Commissioner of Income Tax-II, Kanpur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 16/LKW/2017[2012-13]Status: DisposedITAT Lucknow23 May 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

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

assessee. The Assessing Officer, in the assessment order dated 27/02/2015 passed u/s 143(3)/254 of the I. T. Act, made the aforesaid disallowance u/s 14A of the Act. Being aggrieved, the assessee preferred appeal before the learned CIT(A). The assessee’s appeal against the aforesaid disallowance of Rs.30

Kailash Motors, Kanpur vs. Astt. Commissioner of Income Tax-II, Kanpur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 15/LKW/2017[2006-07]Status: DisposedITAT Lucknow23 May 2025AY 2006-07

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

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

assessee. The Assessing Officer, in the assessment order dated 27/02/2015 passed u/s 143(3)/254 of the I. T. Act, made the aforesaid disallowance u/s 14A of the Act. Being aggrieved, the assessee preferred appeal before the learned CIT(A). The assessee’s appeal against the aforesaid disallowance of Rs.30

Desai Infra Projects(I) Private Limited, Pune vs. PCIT, Central Pune, Pune

In the result, appeal of the assessee is allowed

ITA 1851/PUN/2024[2020-21]Status: DisposedITAT Pune23 May 2025AY 2020-21

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Appellant: Shri Nikhil S. Pathank, AdvocateFor Respondent: Shri Amol Khairnar, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 3Section 36(1)Section 36(1)(va)

interest of the revenue. 2. The learned Pr. CIT erred in holding that the learned A.O. had not verified the issue regarding the disallowance u/s 14A and thereby erred in setting aside the asst. order on the said issue. 3. The learned Pr. CIT failed to appreciate that ... facts of the case, no disallowance u/s 14A was warranted and hence, there was no reason to set aside the asst. order on the said issue. 2 ITA.No.1851/PUN./2024 4. The learned Pr. CIT further erred in holding that the learned A.O. had not verified the issue regarding delayed

Dlf Home Developers Limited, New Delhi vs. Principal Commissioner of Income Tax, Delhi-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2585/DEL/2024[2019-20]Status: DisposedITAT Delhi23 May 2025AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Dlf Home Developers Limited, Vs Pr.Cit, 9Th Floor, Dlf Centre, Sansad Delhi-1, Marg, New Delhi-110001. New Delhi Pan-Aaccd0037H Appellant Respondent Appellant By Shri R.S.Singhvi, Ca & Shri Satyajeet Goel, Ca Respondent By Shri Surender Pal, Cit Dr Date Of Hearing 19.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 263

brokerage and commission of INR 2,49,05,085/- (iii) Disallowance to school running expenses of INR 1,07,29,166/- and (iv) Disallowance u/s 14A of INR 27,96,33,237/-. 4. Against such order, an appeal was filed by assessee which is still pending for adjudication

ACIT Circle 3, Lucknow vs. Rajdhani Nagar Sahkari Bank Ltd, Lucknow

In the result, the appeal of the assessee in ITA

ITA 141/LKW/2024[2016-17]Status: DisposedITAT Lucknow22 May 2025AY 2016-17

Bench: Shri Kul Bharat & Before Shri Kul Bharat & Before Shri Kul Bharat & Shri Nikhil Choudharyshri Nikhil Choudharyshri Nikhil Choudharyita Nos. 112 To 114/Lkw/2024 A.Ys. 2015-16 To 2017-18 Rajdhani Nagar Sahkari Rajdhani Nagar Sahkari Vs. Dcit Bank Ltd P.K. Complex, Raja Ram Mohan P.K. Complex, Raja Ram Mohan 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Rai Marg, Lucknow-226001. 226001. Alambagh, Lucknow-226006 226006 Pan:Aaaar1269D (Appellant) (Respondent) (Respondent) A.Y.2016-17 Acit Circle-3 Vs. Rajdhani Nagar Sahkari Bank Rajdhani Nagar Sahkari Bank 57 Ram Tirath Marg Pratyaksh 57 Ram Tirath Marg Pratyaksh Ltd Kar Bhawan, Lucknow Kar Bhawan, Lucknow-226001 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Alambagh, Lucknow-226006 226006 Pan: Aaaar1269D (Appellant) (Respondent) (Respondent) Assessee By: Sh. K.R. Rastogi, C.A. Sh. Shubham Rastogi, C.A. Revenue By: Sh. Sanjeev Krishna Sharma, Addl. Addl. Cit- Dr Date Of Hearing: 28.04.2025 Date Of Pronouncement: Date Of Pronouncement: 22.05.2025 O R D E R Per Bench.: These Four Appeals Have Been Have Been Filed For The Assessment Years 2015 For The Assessment Years 2015-16, 2016- 17 & 2017-18 By The Assessee & Revenue Ssessee & Revenue Against The Respective Orders Of The Respective Orders Of The Ld. Cit(A)/Nfac, Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024. While The Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Assessee Is In Appeal In Assessment Years 2015 Assessee Is In Appeal In Assessment Years 2015-16, 2016-17 & 2017-18, The Revenue 18, The Revenue

For Appellant: Sh. K.R. Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl
Section 36(1)(v)

loss account under the head “interest earned” and under the heading “other income”, as business income there was no question of any disallowance u/s 14A of the Act. The assessee relied upon a number of decisions made by various Courts as under: - 1 (2019) 112 taxmann.com 322 PCIT ... decision of the Hon'ble Amritsar Bench in the case of M/s. Lally Motors Pvt Ltd in ITA. No.218/Asr/2017 to hold that the disallowance u/s 14A of the Act was required to ITA. No.141/LKW/2024 be made. Since the assessee clearly had exempt income and had been making investments in bonds

Rajdhani Nagar Sahkari Bank Ltd, Lucknow vs. Dy.CIT, Lucknow

ITA 114/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 May 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Sh. K.R. Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl. CIT-DR
Section 36(1)(v)Section 43B

loss account under the head "interest earned” and under the heading "other income", as business income there was no question of any disallowance u/s 14A of the Act. The assessee relied upon a number of decisions made by various Courts as under: - 1 (2019) 112 taxmann.com 322 PCIT ... decision of the Hon'ble Amritsar Bench in the case of M/s. Lally Motors Pvt Ltd in ITA. No.218/Asr/2017 to hold that the disallowance u/s 14A of the Act was required to be made. Since the assessee clearly had exempt income and had been making investments in bonds that would

Rajdhani Nagar Sahkari Bank Ltd, Lucknow vs. Dy. CIT, Lucknow

ITA 113/LKW/2024[2016-17]Status: DisposedITAT Lucknow22 May 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Sh. K.R. Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl. CIT-
Section 36(1)(v)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI KUL BHARAT, VICE PRESIDENT AND SHRI NIKHIL CHOUDHARY

Rajdhani Nagar Sahkari Bank Ltd, Lucknow vs. Dy.CIT, Lucknow

ITA 112/LKW/2024[2015-16]Status: DisposedITAT Lucknow22 May 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 36(1)(v)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI KUL BHARAT, VICE PRESIDENT AND SHRI NIKHIL CHOUDHARY

M/S Punjab Chemicals & Crop. Protection Ltd., Chandigarh vs. Addl. CIT, Neac Delhi

The appeal stand partly allowed

ITA 128/CHANDI/2021[2009-10]Status: DisposedITAT Chandigarh22 May 2025AY 2009-10

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

For Appellant: Shri Anil Khanna (CA) – Ld. ARFor Respondent: Ms. Kusum Bansal (CIT) – Ld. DR
Section 14ASection 154Section 36(1)(iii)

Disallowance of Commission Paid to Directors for Rs.35 Lacs; (ii) Disallowance of interest u/s 36(1)(iii) for Rs.201.60 Lacs; (iii) Disallowance u/s 14A for Rs.34.60 Lacs; (iv) Transfer Pricing (TP) adjustment on reimbursement of expenses; (v) Transfer Pricing Adjustment on Corporate Guarantee charges. Having heard rival submissions and upon ... delete the same and allow the corresponding grounds as raised by the assessee. The depreciation as allowed by Ld. AO stand reversed. 4. Disallowance u/s 14A for Rs.34.60 Lacs 4.1 This issue was restored back by Tribunal for fresh consideration in the light of various decisions of Hon’ble Apex

M/S Punjab Chemicals & Crop. Protection Ltd., Chandigarh vs. Addl. CIT, Neac Delhi

The appeal stand partly allowed

ITA 127/CHANDI/2021[2008-09]Status: DisposedITAT Chandigarh22 May 2025AY 2008-09

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

For Appellant: Shri Anil Khanna (CA) – Ld. ARFor Respondent: Ms. Kusum Bansal (CIT) – Ld. DR
Section 14ASection 154Section 36(1)(iii)

Disallowance of Commission Paid to Directors for Rs.35 Lacs; (ii) Disallowance of interest u/s 36(1)(iii) for Rs.201.60 Lacs; (iii) Disallowance u/s 14A for Rs.34.60 Lacs; (iv) Transfer Pricing (TP) adjustment on reimbursement of expenses; (v) Transfer Pricing Adjustment on Corporate Guarantee charges. Having heard rival submissions and upon ... delete the same and allow the corresponding grounds as raised by the assessee. The depreciation as allowed by Ld. AO stand reversed. 4. Disallowance u/s 14A for Rs.34.60 Lacs 4.1 This issue was restored back by Tribunal for fresh consideration in the light of various decisions of Hon’ble Apex

Compact Agencies Pvt. Ltd., Kolkata vs. DCIT/ACIT, Circle 3(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 200/KOL/2025[2017-18]Status: DisposedITAT Kolkata21 May 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.200/Kol/2025 Assessment Year: 2017-18 Compact Agencies Pvt. Ltd……………………………………...….……….Appellant Room No.1A, 20B, West Bengal, East India House, Bbd Bag, West Bengal-700069. [Pan: Aadcc6607K] Vs. Dcit/Acit, Circle-3(1), Kolkata.….....................……........……...…..…..Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Assessee. Shri Raja Sengupta, Cit, Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 15, 2025 Date Of Pronouncing The Order : May 21, 2025 Order Per Sonjoy Sarma: This Appeal Of The Assessee For The Assessment Year 2017-18 Is Directed Against The Order Dated 19.08.2024 Passed By The National Faceless Appeal Centre [Hereinafter Referred To As ‘The ‘Ld. Cit(A)’]. 2. At The Outset, It Is Noted That There Is A Delay Of 88 Days In Filing The Instant Appeal Before The Tribunal. The Assessee Has Submitted An Application For Condonation Of Such Delay Explaining Reasons For The Delay. We, After Perusing The Petition Made In The Application, Satisfy That There Were Bona Fide & Sufficient Reasons For Such Delay. We, Therefore, Condone The Delay & Admit This Appeal For Adjudication. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2017-18 By Declaring Total Income As Nil. Subsequently, The Case Of The Assessee Was Selected For

Section 142(1)Section 143(3)Section 14ASection 251(2)Section 69Section 69C

partially complied with the notices issued by the ld. CIT(A) but could not effectively explain the source of the investment. Regarding the disallowance u/s 14A, the ld. CIT(A) sustained the addition so made by the Assessing Officer and while doing so, the ld. CIT(A) without issuing show ... claim and the ld. CIT(A) confirmed the addition without considering the documents furnished by the assessee . The ld. AR stated that the disallowance u/s 14A amounting to Rs.1,88,254/- is 2 I.T.A. No.200/Kol/2025 Assessment Year: 2017-18 Compact Agencies Pvt. Ltd also

Aasan Corporate Solutions Private Limited, Mumbai vs. DCIT(6)(1)(1), Mumbai

In the result, the appeal is partly allowed

ITA 5524/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 May 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Ronak Doshi, ARFor Respondent: Dr. K. R. Subhash (CIT - DR)
Section 143(3)Section 14ASection 36(1)(iii)

thereby leading to double disallowance of the same expense. 4. Both the above grounds are related to the issue of disallowance u/s 14A of the Act. According to the assessment order, the assessee was found to have made investments in various investments in equity shares and mutual funds ... make any suo motu disallowance u/s 14A of the Act on the ground that it did not earn any exempt income during the year. The AO worked out disallowance by referring to CBDT Circular no. 5 of 2024 providing for disallowance irrespective of exempt income. Accordingly, he disallowed Rs.76

Asst. Commissioner of Income Tax 8(2)(1) Mumbai, Mumbai vs. Ms. Piramal Enterprises Limited, Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2589/MUM/2024[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

could not happen without managerial and administrative expenses incurred by the assessee. Ld. CIT(A) upheld the decision of ld. Assessing Officer regarding disallowance u/s 14A of the Act. Tribunal had set aside the issue of disallowance u/s 14A r.w.r. 8D(2)(ii) with a direction to ld. Assessing Officer ... Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient

Piramal Enterprises Limited, Mumbai vs. The Assistant Commissioner of Income Tax Circle 7(3)(2), Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2588/MUM/2024[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

could not happen without managerial and administrative expenses incurred by the assessee. Ld. CIT(A) upheld the decision of ld. Assessing Officer regarding disallowance u/s 14A of the Act. Tribunal had set aside the issue of disallowance u/s 14A r.w.r. 8D(2)(ii) with a direction to ld. Assessing Officer ... Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient