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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

Piramal Enterprises Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 8(2)(1), Mumbai

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

ITA 2584/MUM/2024[2009-10]Status: DisposedITAT Mumbai21 May 2025AY 2009-10

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 Deputy Commissioner of Income Tax, Circle 8(2)(1), Mumbai

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

ITA 2582/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 May 2025AY 2010-11

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

Vardhman Special Steels Ltd., Ludhiana vs. DCIT, Circle-1, Ludhiana

ITA 79/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh20 May 2025AY 2018-19
For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 270ASection 36(1)Section 36(1)(iii)Section 57

u/s 14A of the Act after deducting suo-moto disallowance of Rs.556/- made by the assesse. Breakup of Disallowance made by the AO Disallowance u/s 14A r.w Rule 8D(2)(ii) Less – Suo-moto Disallowance by the assesse Balance Disallowance Rs.1,78,870/- Rs.556/- Rs.1

Isl Consulting Limited, Ahmedabad vs. The DCIT, Circle-2(1)(1) ( Previously DCIT, Cen. Circ. 1(3), Chennai), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 218/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad20 May 2025AY 2012-13

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri S N Divatia & Shri Samir VoraFor Respondent: Shri Ravindra, Sr. DR
Section 143(3)Section 14ASection 250

para 6.6 & 6.7 of the order of the Ld. CIT(A) as under: “6.6 During the appellate proceedings, the appellant has stated that disallowance u/s 14A is not warranted as the shares of Gujarat Alkalies and Chemicals Ltd. were part of stock-in-trade. The appellant has relied upon ... Supreme Court, in its decision in the case of Maxopp Investment Limited [2018] 91 Taxmann.com 154, has decided the issue of disallowance u/s 14A in the case of dividend income being earned from shares held as stock-in-trade. After considering the decisions of various High Courts on this issue

M/S. Howrah Forgings Ltd., Kolkata vs. ACIT, Circle 1(1), Kolkata

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

ITA 60/KOL/2025[2016-17]Status: DisposedITAT Kolkata20 May 2025AY 2016-17

Bench: Shri George Mathan & Shri Sanjay Awasthiassessment Year: 2016-17 M/S Howrah Forgings Ltd., Circle 1(1), Kolkata, 18, R.N. Mukherjee Road, Aayakar Bhawan, P-7, Vs. Kolkata - 700001 Chowringhee Square, (Pan: Aaach6139E) Kolkata - 700069 (Appellant) (Respondent)

For Appellant: Shri Sharad Joshi, ARFor Respondent: Roma Chaudhary, JCIT, Sr. DR
Section 143(3)Section 14ASection 250Section 254(1)

discussed or distinguished. 5. On perusal of the issues in the appeal it is seen that the issue is in respect of the disallowance u/s 14A read with Rule 8D of the IT Rules. The Ld. AO has admittedly, not considered those investments which have given rise to the exempt ... income. The Ld. AO has taken the entire investments while computing the disallowance u/s 14A read with Rule 8D. The assessee earned exempt income of Rs. 14,000/- which has been mentioned in the order of Ld. JCIT(A), Mumbai and in the written submissions and grounds of appeal. This

Indian Coal Agency, Kolkata vs. DCIT, Circle-35, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 868/KOL/2018[2015-16]Status: DisposedITAT Kolkata20 May 2025AY 2015-16

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

that in view of the facts and in the circumstances, Ld. PCIT was wholly unjustified in directing the AO to compute the disallowance u/s 14A in accordance with Rule 8D(2)(ii) & 8D(2)(iii) whereas the appellant himself had considered the impugned disallowance at Rs.18,94,454/- and hence ... held accordingly. 4. Without prejudice to Grounds No. 2 & 3 above, the Ld. PCIT erred in directing the AO to make disallowance u/s 14A read with Rule 8D(2)(iii) and such disallowance can only be in respect exempt from the investment out of which exempt income has been earned

Indian Coal Agency, Kolkata vs. Principal CIT, Circle - 12, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 867/KOL/2018[2013-14]Status: DisposedITAT Kolkata20 May 2025AY 2013-14

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

that in view of the facts and in the circumstances, Ld. PCIT was wholly unjustified in directing the AO to compute the disallowance u/s 14A in accordance with Rule 8D(2)(ii) & 8D(2)(iii) whereas the appellant himself had considered the impugned disallowance at Rs.18,94,454/- and hence ... held accordingly. 4. Without prejudice to Grounds No. 2 & 3 above, the Ld. PCIT erred in directing the AO to make disallowance u/s 14A read with Rule 8D(2)(iii) and such disallowance can only be in respect exempt from the investment out of which exempt income has been earned

DCIT, Circle-35, Kolkata vs. M/S. Indian Coal Agency, Kolkata

In the result, the appeal for AY 2013-14 is partly allowed

ITA 1258/KOL/2018[2015-16]Status: DisposedITAT Kolkata20 May 2025AY 2015-16

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14A

that in view of the facts and in the circumstances, Ld. PCIT was wholly unjustified in directing the AO to compute the disallowance u/s 14A in accordance with Rule 8D(2)(ii) & 8D(2)(iii) whereas the appellant himself had considered the impugned disallowance at Rs.18,94,454/- and hence ... held accordingly. 4. Without prejudice to Grounds No. 2 & 3 above, the Ld. PCIT erred in directing the AO to make disallowance u/s 14A read with Rule 8D(2)(iii) and such disallowance can only be in respect exempt from the investment out of which exempt income has been earned

Income Tax Officer, Parwanoo vs. Kamla Oleo Private Limited, Barotiwala

The appeal stand dismissed

ITA 897/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh19 May 2025AY 2017-18

Bench: Hon’Ble Shri Laliet Kumar & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.897/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2017-18) Ito M/S Kamla Oleo Private Limited बनाम/ Parwanoo, Village Buranwala, Barotiwala Vs. Himachal Pradesh-173220. Solan, Himachal Pradesh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadck-7696-Q (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Adv.). – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 21-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 20-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2017-18 Arises Out Of An Order Of Learned Commissioner Of Income Tax [Cit(A)] Dated 25-06-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 29-12-2019. The Issues That Arise In The Appeal Are – (I) Addition Of Unexplained Cash Credit U/S 68; (Ii) Disallowance U/S 14A; (Iii) Addition Of Unexplained Credit U/S 69A. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. The Assessee Being

For Appellant: Sh. Sudhir Sehgal (Adv.). – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(3)Section 14ASection 68Section 69A

issues that arise in the appeal are – (i) Addition of unexplained cash credit u/s 68; (ii) Disallowance u/s 14A; (iii) Addition of unexplained credit u/s 69A. Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. The assessee being resident corporate assessee ... impermissible. Therefore, we find no reason to interfere in the same. The corresponding grounds as raised by the revenue stand dismissed. 3. Disallowance u/s 14A 3.1 The Ld. AO computed disallowance u/r 8D(2)(ii) for Rs.8.07 Lacs since the assessee had made investments. The Ld. CIT(A) deleted

DCIT, Range-6, Lucknow vs. M/S. U.P. State Sugar Corporation Ltd., Lucknow

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is partly allowed for statistical purposes

ITA 229/LKW/2020[2011-12]Status: DisposedITAT Lucknow16 May 2025AY 2011-12

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 14A

14A was amended with effect from 01/04/2022 whereby Explanation was inserted to Section 14A of the Act. The learned D.R. further submitted that disallowance u/s 14A of the Act is to be made; in view of the aforesaid Explanation to section 14A of the Act regardless of whether ... held by Hon'ble jurisdictional High Court that in the absence of tax free income earned by the assessee, the disallowance u/s 14A could not be made. To quote from the aforesaid order of Hon'ble Allahabad High Court, “10. As regards the second question, s. 14A

U.P. State Sugar Corporation Ltd., Lucknow vs. DCIT, Range-VI, Lucknow

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is partly allowed for statistical purposes

ITA 227/LKW/2020[2011-12]Status: DisposedITAT Lucknow16 May 2025AY 2011-12

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 14A

14A was amended with effect from 01/04/2022 whereby Explanation was inserted to Section 14A of the Act. The learned D.R. further submitted that disallowance u/s 14A of the Act is to be made; in view of the aforesaid Explanation to section 14A of the Act regardless of whether ... held by Hon'ble jurisdictional High Court that in the absence of tax free income earned by the assessee, the disallowance u/s 14A could not be made. To quote from the aforesaid order of Hon'ble Allahabad High Court, “10. As regards the second question, s. 14A

DCIT, Lucknow vs. M/S U.P. State Sugar Corporation Ltd., Lucknow

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is partly allowed for statistical purposes

ITA 588/LKW/2019[2014-15]Status: DisposedITAT Lucknow16 May 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 14A

14A was amended with effect from 01/04/2022 whereby Explanation was inserted to Section 14A of the Act. The learned D.R. further submitted that disallowance u/s 14A of the Act is to be made; in view of the aforesaid Explanation to section 14A of the Act regardless of whether ... held by Hon'ble jurisdictional High Court that in the absence of tax free income earned by the assessee, the disallowance u/s 14A could not be made. To quote from the aforesaid order of Hon'ble Allahabad High Court, “10. As regards the second question, s. 14A

DCIT, Lucknow vs. M/S U.P. State Sugar Corporation Ltd., Lucknow

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is partly allowed for statistical purposes

ITA 587/LKW/2019[2012-13]Status: DisposedITAT Lucknow16 May 2025AY 2012-13

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 14A

14A was amended with effect from 01/04/2022 whereby Explanation was inserted to Section 14A of the Act. The learned D.R. further submitted that disallowance u/s 14A of the Act is to be made; in view of the aforesaid Explanation to section 14A of the Act regardless of whether ... held by Hon'ble jurisdictional High Court that in the absence of tax free income earned by the assessee, the disallowance u/s 14A could not be made. To quote from the aforesaid order of Hon'ble Allahabad High Court, “10. As regards the second question, s. 14A

DCIT, Lucknow vs. M/S U.P. State Sugar Corporation Ltd., Lucknow

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is partly allowed for statistical purposes

ITA 485/LKW/2019[2013-14]Status: DisposedITAT Lucknow16 May 2025AY 2013-14

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 14A

14A was amended with effect from 01/04/2022 whereby Explanation was inserted to Section 14A of the Act. The learned D.R. further submitted that disallowance u/s 14A of the Act is to be made; in view of the aforesaid Explanation to section 14A of the Act regardless of whether ... held by Hon'ble jurisdictional High Court that in the absence of tax free income earned by the assessee, the disallowance u/s 14A could not be made. To quote from the aforesaid order of Hon'ble Allahabad High Court, “10. As regards the second question, s. 14A

Assistant Commissioner of Income Tax, Chennai vs. Cognizant Technology Solutions India Private Limited, Chennai

ITA 1266/CHNY/2024[2014-15]Status: DisposedITAT Chennai16 May 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 144ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO’s act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. 4.4 Aggrieved by the aforesaid action ... Tribunal in the case of ACIT vs. Vireet Investments (P.) Ltd. [2017] 82 taxmann.com 415 (Delhi-Trib.)(SB), wherein it is held that disallowance u/s. 14A of the Act r/w Rule 8D of the Rules cannot be added back while computing the book profit u/s. 115JB of the Act. This

Assistant Commissioner of Income Tax, Chennai vs. Cognizant Technology Solutions India Private Limited, Chennai

ITA 1264/CHNY/2024[2012-13]Status: DisposedITAT Chennai16 May 2025AY 2012-13

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 144ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO’s act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. 4.4 Aggrieved by the aforesaid action ... Tribunal in the case of ACIT vs. Vireet Investments (P.) Ltd. [2017] 82 taxmann.com 415 (Delhi-Trib.)(SB), wherein it is held that disallowance u/s. 14A of the Act r/w Rule 8D of the Rules cannot be added back while computing the book profit u/s. 115JB of the Act. This

Assistant Commissioner of Income Tax, Chennai vs. Cognizant Technology Solutions India Private Limited, Chennai

ITA 1263/CHNY/2024[2011-12]Status: DisposedITAT Chennai16 May 2025AY 2011-12

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 144ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO’s act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. 4.4 Aggrieved by the aforesaid action ... Tribunal in the case of ACIT vs. Vireet Investments (P.) Ltd. [2017] 82 taxmann.com 415 (Delhi-Trib.)(SB), wherein it is held that disallowance u/s. 14A of the Act r/w Rule 8D of the Rules cannot be added back while computing the book profit u/s. 115JB of the Act. This

Assistant Commissioner of Income Tax, Chennai vs. Cognizant Technology Solutions India Private Limited, Chennai

ITA 1262/CHNY/2024[2010-11]Status: DisposedITAT Chennai16 May 2025AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Cognizant Technology Solutions Vs The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai - 600 096. (प्रत्यर्थी/Respondent) Pan: Aaacd 3312M (अपीलार्थी/Appellant) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) The Asst. Commissioner Of Vs Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai - 600 096. Pan: Aaacd 3312M (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निधारिती की ओर से/Assessee By राजस्व की ओर से /Revenue By : Shri N.V. Balaji, Advocate : Shri R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 11.03.2025 घोषणा की तारीख/Date Of Pronouncement : 16.05.2025 - 2 -

For Respondent: Shri N.V. Balaji, Advocate
Section 10ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO's act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. 4.4 Aggrieved by the aforesaid action

Cognizant Technology Solutions India Private Limited, Chennai vs. The Assistant Commissioner of Income-Tax, Central Circle 1(1), Chennai

ITA 1207/CHNY/2024[2014-15]Status: DisposedITAT Chennai16 May 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO’s act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. ………..” 4.4 Aggrieved by the aforesaid action

Cognizant Technology Solutions India Private Limited, Chennai vs. The Assistant Commissioner of Income-Tax, Central Circle 1(1), Chennai

ITA 1206/CHNY/2024[2013-14]Status: DisposedITAT Chennai16 May 2025AY 2013-14

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 144ASection 14ASection 40Section 9(1)

segments cannot be ruled out and therefore, there is no error in the AO’s act of invoking rule 8D to compute the disallowance u/s 14A for the purpose of earning dividend and therefore the grounds of appeal nos 8 and 9 stand dismissed. 4.4 Aggrieved by the aforesaid action ... Tribunal in the case of ACIT vs. Vireet Investments (P.) Ltd. [2017] 82 taxmann.com 415 (Delhi-Trib.)(SB), wherein it is held that disallowance u/s. 14A of the Act r/w Rule 8D of the Rules cannot be added back while computing the book profit u/s. 115JB of the Act. This