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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

JCIT(OSD), Cir-3(1)(2), Ahmedabad vs. Reckitt Benckiser Healthcare (India) Ltd, Haryana

In the result, appeal of the Revenue is dismissed

ITA 1225/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri V. Nand Kumar, CIT-DR
Section 115JSection 143(3)Section 2Section 250Section 391Section 45

does not arise. 6.5 The Ld. DR, placing reliance on the assessment order, contended that the Assessing Officer has rightly made the disallowance u/s 14A of the Act and relied on the order of the Tribunal in assessee’s own case in ITA No. 3098/Ahd/2013 ... expenses towards administrative expenses In the light of the above facts and circumstances we justify the decision of the Ld.CIT(A) for the disallowance u/s 14A r.w. Rule 8D to the extent of Rs. 19,491/- as computed by the assessing officer in para 8.11 of the assessment

Reckitt Benckiser Healthcare India Pvt. Ltd., ( Formerly Known As Reckitt Benckiser Healthcare India Ltd., Haryana vs. DCIT, Circle-3(1)(2), Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 1184/AHD/2018[2011-12]Status: FixedITAT Ahmedabad18 Feb 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri V. Nand Kumar, CIT-DR
Section 115JSection 143(3)Section 2Section 250Section 391Section 45

does not arise. 6.5 The Ld. DR, placing reliance on the assessment order, contended that the Assessing Officer has rightly made the disallowance u/s 14A of the Act and relied on the order of the Tribunal in assessee’s own case in ITA No. 3098/Ahd/2013 ... expenses towards administrative expenses In the light of the above facts and circumstances we justify the decision of the Ld.CIT(A) for the disallowance u/s 14A r.w. Rule 8D to the extent of Rs. 19,491/- as computed by the assessing officer in para 8.11 of the assessment

Kashish Multitrde Private Limited, Mumbai vs. Central Cirecle 4 (3), Mumbai

In the result the appeal filed by the assessee stands dismissed

ITA 6332/MUM/2024[2017-18]Status: DisposedITAT Mumbai18 Feb 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosainkashish Multi Trade Pvt Vs. Dcit, Cc- 4(3) Room No. 420, Kautilya Ltd., Bhavan, Bandra – 401-A, Pearl Arcade, 400051. Opp Pk Jwellers, Jp Road, Andheri – 400058. Pan/Gir No. Aacck7596A (Applicant) (Respondent)

Section 14ASection 250

relates to challenging 3 Kashish Multitrade Pvt Ltd, Mumbai the order of CIT(A) in upholding the action of the AO of making disallowance u/s 14A r.w.r 8D of the Act. Therefore, I have decided to take up all these grounds together and adjudicate the same through present consolidated order ... assessee has disallowed sum of Rs. 2,08,544/-, therefore the AO while not satisfied with the accounts of the assessee, made disallowance u/s 14A r.w.s 8(D)(i) of Rs. 5,10,881/- 5. The Ld. CIT(A) after considering the written submissions filed before him decided the appeal

Vodafone Idea Limited (Earlier Known As Vodafone India Ltd. Which Stands Merged With Idea Cellular Ltd. and Consequently Known As Idea Ltd.), Mumbai vs. ACIT - Circle- 5 (3)(2), Mumbai

Appeal are allowed for statistical purposes

ITA 316/MUM/2019[2014-15]Status: DisposedITAT Mumbai18 Feb 2025AY 2014-15

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan Ved; Shri Ninad PatadeFor Respondent: Date
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 194HSection 32(1)Section 40Section 92C

Income under the head business (-) 485,36,80,287/- or profession (as per computation) Add: (i) TP Adjustment 39,27,36,605 (ii) Disallowance u/s 14A 362,23,34,000 (iii) Disallowance under Section 40(a)(ia) for non deduction of 7 A.Y.2014-2015 TDS on Discount extended to prepaid distributors

Deputy Commissioner of Income Tax Central Circle-1(3), Nagpur vs. M/S. Fuelco Coal India Ltd., Nagpur

Appeal of the Revenue is dismissed

ITA 90/NAG/2022[2014-15]Status: DisposedITAT Nagpur14 Feb 2025AY 2014-15

Bench: Shri V. Durgarao & Shrik.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 143(2)Section 143(3)Section 36(1)(iii)Section 40Section 40aSection 68

entry. I) In the assessment framed u/s 143(3) for Asstt. Year 2014-15 A.O. of M/s Saphire Marketing Pvt. Ltd. has made disallowance u/s 14A of I.T. Act 1961 by taking the investment value of shares as made in the case of assessee. Investment made in the assessee company ... having been considered for making disallowance u/s 14A in the case of corporate share cannot be disputed as unexplained credit at the hands of assessee. J) Reliance on: i) ITAT order in ITA No.453/Del/2016 in the case of M/s. TRN Energy Pvt. Ltd. vide order dated 01/01/2018

DCIT, Central Circle-2(4), Ahmedabad vs. Ghanshyam Mohanbhai Patel, Ahmedabad

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

ITA 155/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad14 Feb 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kambleit(Ss)A No. 1/Ahd/2024 (Assessment Year: 2017-18) Ghanshyam Mohanbhai Patel, Dy./Asstt. Commissioner Of Vs. 901, Suryaketu Tower, Income-Tax, Nr. Sambhav Press, Judges Central Circle 2(4), Bungalow, Bodakdev, Ahmedabad Ahmedabad-380015 [Pan : Abbpp 5403 G]

For Appellant: Shri Biren Shah, ARFor Respondent: Shri A.P. Singh, CIT-DR
Section 132Section 139(1)Section 143(3)Section 14ASection 153ASection 250

there was no basis for invoking the said provisions again and passing an order to make a disallowance u/s. 14A of the Act. The Ld. Counsel for the assessee submitted that the assessee’s case for the year under consideration as well as earlier years was covered under assessment u/s ... 153A/143(3) of the Act and all the expenses claimed by the assessee were allowed as deduction, without making any disallowance u/s. 14A. Therefore, there is no reason for not accepting the said position which was accepted by the department from year to year. It was also submitted that

DCIT, Central Circle-2(4), Ahmedabad vs. Ghanshyam Mohanbhai Patel, Ahmedabad

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

ITA 154/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad14 Feb 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kambleit(Ss)A No. 1/Ahd/2024 (Assessment Year: 2017-18) Ghanshyam Mohanbhai Patel, Dy./Asstt. Commissioner Of Vs. 901, Suryaketu Tower, Income-Tax, Nr. Sambhav Press, Judges Central Circle 2(4), Bungalow, Bodakdev, Ahmedabad Ahmedabad-380015 [Pan : Abbpp 5403 G]

For Appellant: Shri Biren Shah, ARFor Respondent: Shri A.P. Singh, CIT-DR
Section 132Section 139(1)Section 143(3)Section 14ASection 153ASection 250

there was no basis for invoking the said provisions again and passing an order to make a disallowance u/s. 14A of the Act. The Ld. Counsel for the assessee submitted that the assessee’s case for the year under consideration as well as earlier years was covered under assessment u/s ... 153A/143(3) of the Act and all the expenses claimed by the assessee were allowed as deduction, without making any disallowance u/s. 14A. Therefore, there is no reason for not accepting the said position which was accepted by the department from year to year. It was also submitted that

ACIT Non Corporate Circle 8(1)-Ltu-2, Chennai vs. M/S. Ashok Leyland Limited, Chennai

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

ITA 561/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 35Section 35(1)(iv)

agreeable to the contention of the assessee and sought to invoke Rule 8D. The AO is noted to have computed disallowance u/s 14A of Rs.19,00,28,934/- being 1% of the average value of investments held by the assessee. On appeal the Ld. CIT(A) is noted to have ... held that, the disallowance u/s 14A of the Act cannot exceed the exempt income and therefore confirmed disallowance u/s 14A of the Act to the extent of dividend income viz., Rs.5,544/- and deleted the balance disallowance of Rs.19,00,23,390/-. It was brought to our notice that this

M/S. Ashok Leyland Limited, Chennai vs. ACIT Non Corporate Circle 8(1)-Ltu-2, Chennai

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

ITA 554/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 35Section 35(1)(iv)

agreeable to the contention of the assessee and sought to invoke Rule 8D. The AO is noted to have computed disallowance u/s 14A of Rs.19,00,28,934/- being 1% of the average value of investments held by the assessee. On appeal the Ld. CIT(A) is noted to have ... held that, the disallowance u/s 14A of the Act cannot exceed the exempt income and therefore confirmed disallowance u/s 14A of the Act to the extent of dividend income viz., Rs.5,544/- and deleted the balance disallowance of Rs.19,00,23,390/-. It was brought to our notice that this

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata, Aayakar Bhawan vs. Ugraya Foods and Feeds Private Limited, Jalpaiguri

In the result, the appeal of the revenue is dismissed

ITA 1341/KOL/2024[2020-2021]Status: DisposedITAT Kolkata13 Feb 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1341/Kol/2024 Assessment Year: 2020-21 Acit, Circle-7(1), Kolkata……...………………...…….………....Appellant Vs. Ugraya Foods & Feeds Pvt. Ltd……............................…..…..... Respondent 12A, Dabgram Industrial Centre, Fulbari, Near Krishna Weight Bridge. [Pan: Aaacy8901B] Appearances By: Shri P. N. Barnwal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 02, 2025 Date Of Pronouncing The Order : February 13, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 26.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 111 Days In Filing The Present Appeal. The Revenue Filed Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2020-21 By Declaring Total Income Of Rs.23,48,56,350/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass With Specific Reasons Being Substantial Unexplained Loans

Section 142(1)Section 14ASection 250Section 68

received from M/s Bonn Suppliers Pvt. Ltd. alleged to be bogus company, loss of claim of sale of share and mutual funds, disallowance u/s 14A of the Act r.w.r. 8D, issue of bad debt claimed by the assessee. The Assessing Officer accepted assessee’s explanation on all issues except

A& A International Trading Pvt. Ltd, Chennai vs. ACIT, Corp. Circle 1(1), Chennai

In the result, the corresponding grounds raised by the revenue stand dismissed…

ITA 2231/CHNY/2024[2016-17]Status: DisposedITAT Chennai12 Feb 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2231/Chny/2024, निर्ाारण वर्ा /Assessment Years: 2016-17 A & A International Trading Pvt Ltd, The Asst. Commissioner Of Income No.6-5/140, Kaviarasu Kannadasan Tax, Nagar, Kodungaiyur, Corporate Circle-1(1), Chennai-600 118. Chennai. [Pan: Aaica0039J] आयकर अपील सं./Sa No.15/Chny/2025 (Ita No.2231/Chny/2024) निर्ाारण वर्ा /Assessment Years: 2016-17 (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri D.Anand, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri A.Sasikumar, Cit सुिवाई की तारीख/Date Of Hearing : 05.02.2025 घोर्णा की तारीख /Date Of Pronouncement : 12.02.2025 आदेश / O R D E R Per Amitabh Shukla, A.M : These Appeals Are Filed By The Assessee Against The Order Bearing Din & Order No.Itba/Nfac/S/250/2024-25/1065907633(1) Dated 21.06.2024 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), National Faceless Appeal Center[Nfac], Delhi, For The Assessment Years 2016-17 & Stay Petition No.15/Chny/2025 Arising Out Of Ita No.2231/Chny/2024 For The Assessment Year 2016-17. Page - 1 - Of 8

For Appellant: Shri D.Anand, AdvocateFor Respondent: Shri A.Sasikumar, CIT
Section 250Section 41(1)

deduction of Works Contract Tax (WCT). The issues in revenue’s appeal are two-fold i.e., cessation of liability u/s 41(1) and disallowance u/s 14A. 1.6 The Ld. CIT-DR advanced arguments in support of assessment order. The Ld. AR also advanced arguments and drew our attention

Income Tax Officer, Ward-1(2), Hyderabad vs. Athena Global Technologies Limited (Formerly M/S Vjil Consulting Limited), Hyderabad

In the result, the ground nos

ITA 895/HYD/2018[2012-13]Status: DisposedITAT Hyderabad11 Feb 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Shri B. Balakrishna, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 40Section 43BSection 68

Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd (2010) 323 ITR 518 (P&H), no disallowance u/s 14A is called for when the assessee has not earned any dividend income during the year under consideration. Accordingly, in view of the facts as discussed above

Athena Global Technologies Limited, Hyderabad vs. Income Tax Officer, Ward-17(4), Hyderabad

In the result, the ground nos

ITA 1266/HYD/2018[2012-13]Status: DisposedITAT Hyderabad11 Feb 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Shri B. Balakrishna, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 40Section 43BSection 68

Punjab & Haryana High Court in the case of CIT vs. Hero Cycles Ltd (2010) 323 ITR 518 (P&H), no disallowance u/s 14A is called for when the assessee has not earned any dividend income during the year under consideration. Accordingly, in view of the facts as discussed above

Subramaniam Swaminathan Iyer, Bhilai, Durg vs. Deputy Commissioner of Income Tax-1(1), Bhilai, Durg

In the result, appeal of the assessee is partly allowed/partly allowed for statistical purposes in terms of our aforesaid observations

ITA 71/RPR/2023[2012-13]Status: DisposedITAT Raipur10 Feb 2025AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.71/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Subramaniam Swaminathan Iyer 12-A/7, Nehru Nagar, Bhilai (C.G.)-490 020 Pan: Anwps2381P

For Appellant: S/shri Milind Bhusari, AdvocateFor Respondent: Shri S.L Anuragi, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 2(22)(e)Section 68

companies and in agricultural assets aggregating to Rs.1,61,53,680/-. As the assessee had not disclosed on a suo-motto basis any disallowance u/s. 14A r.w.r. 8D, therefore, the A.O worked out the disallowance on the said count of Rs.55,06,957/-. 8. As the assessee ... authorities is vacated. Thus, the Ground of appeal No.4 raised by the assessee is allowed in terms of our aforesaid observations. (B). Re: Disallowance u/s. 14A r.w.Rule 8D : Rs.55,06,957/- 19. As is discernible from the assessment order, the A.O observing that the assessee had though during the subject

Deputy Commissioner of Income Tax, Cir-4(1), Kolkata vs. Sublime Agro Limited, Kolkata

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

ITA 1358/KOL/2023[2012-13]Status: DisposedITAT Kolkata10 Feb 2025AY 2012-13

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 14ASection 80I

allowed the appeal of the assessee on the disallowance of expenditure towards nursery utilization, disallowance of cess of green leaf, disallowance u/s 14A of the act, disallowance of claim of deduction u/s 80IE of the act estimated profit out of green leaf purchase, capital loss incurred on sale of Govt ... find any merit in the contentions of the Ld. D.R to interfere in the order of Ld. CIT(A) in this issue. (iii) Disallowance u/s 14A of the Act: It is pertinent to mention herein that during the assessment year under consideration the assessee earned dividend income

Hsbc Securities and Capital Markets (India) Private Limited, Mumbai vs. Principal Commissioner of Income-Tax, Mumbai-4, Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 2586/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Feb 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Ms. Krupa Gandhi, Ld. A.RFor Respondent: Shri Biswanath Das, Ld. D.R
Section 115JSection 143(3)Section 147Section 14ASection 154Section 263

r.w.s. 144B of the Act as erroneous in so far as it is prejudicial to the interest of the revenue in respect of disallowance u/s 14A r.w.s. rule 8D of the Rules and consequently set aside the same and restored it to the file of the AO with a direction ... verification in respect of closing value of investment as enumerated in para No.5.5 of the impugned order (reproduced above) and to compute the disallowance u/s 14A of the Act accordingly. 8 M/s. HSBC Securities and Capital Markets (India) Private Limited 6. The Assessee, being aggrieved, is in appeal before

Cera Sanitaryware Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1333/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad07 Feb 2025AY 2020-21

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2020-21 Cera Sanitaryware Ltd The Dcit, Cir.1(1)(1) 7Th & 8Th Floor, “B” Wing Vs Ahmedabad. Privilon, Ambli Brts Road Iskcon Cross Roads Shilaj Bo, Taluka : Daskroi Dist: Ahmedabad. Pan : Aabcm 9244 N (Applicant) (Responent) : Assessee By Shri Dinal Shah, Ar Revenue By : Smt.Malarkodi R., Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 03/02/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/02/2025 आदेश/O R D E R आदेश आदेश आदेश

For Respondent: Smt.Malarkodi R., Sr.DR
Section 14ASection 250

Assessing Officer noted his alleged dissatisfaction with the claim of the appellant and thus invoked Rule 8D of the Rules for computing expenses disallowable u/s 14A of the Act. The contents of the paras 5.1 is reproduced hereunder- 5.1 The assessee arguments for the disallowance u/s 14A cannot be considered

Metropolitan Commercial Pvt. Ltd, Kolkata vs. I.T.O., Ward - 4(2), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1943/KOL/2024[2017-2018]Status: DisposedITAT Kolkata07 Feb 2025AY 2017-2018

Bench: SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 14ASection 250

account of lease rent was unjustifiably made and lastly, the assessee claimed that there was no exempt income earned to make any disallowance u/s 14A of the Act. However, the Ld. CIT(A) has mentioned in detail that the assessee did not make any worthwhile compliance to the notices fixing

ACIT Cir 2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2777/MUM/2019[2016-17]Status: DisposedITAT Mumbai06 Feb 2025AY 2016-17

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailbank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra Kurla Complex, Bandra (East), Mumbai-400051. ……………. Appellant Pan: Aaacb 1534 F V/S Acit, 2(1)(1), ……………. Respondent Mumbai-400051. Acit, Circle - 2(1)(1), Room No. 561, 5Th Floor, Aayakar Bhavan, M.K. Road, ……………. Appellant Mumbai-400020. V/S Bank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra ……………. Respondent Kurla Complex, Bandra (East), Mumbai-400051. Pan: Aaacb 1534 F

For Appellant: Mr. C. NareshFor Respondent: Mr. Kailash C. Kanojiya, CIT-DR
Section 115JSection 143(3)Section 14ASection 250

earning tax free income and that in the absence of any expenditure incurred in relation to earning tax free income no disallowance u/s 14A is warranted. 1.1 The CIT(A) ought to have followed the decision of hon'ble Supreme Court in the case of State Bank of Patiala ... computing book profit which were agitated in appeal.” 4. The issue arising in ground no. 1 raised in assessee’s appeal pertains to disallowance u/s 14A of the Act. 5. The brief facts of the case pertaining to this issue, as emanating from the record, are: During the year under

Bank of Baroda, Mumbai vs. ACIT 2 (1)(1), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1649/MUM/2019[2016-17]Status: DisposedITAT Mumbai06 Feb 2025AY 2016-17

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Mr. C. NareshFor Respondent: Mr. Kailash C. Kanojiya, CIT-DR
Section 115JSection 143(3)Section 14ASection 250

earning tax free income and that in the absence of any expenditure incurred in relation to earning tax free income no disallowance u/s 14A is warranted. 1.1 The CIT(A) ought to have followed the decision of hon'ble Supreme Court in the case of State Bank of Patiala ... computing book profit which were agitated in appeal.” 4. The issue arising in ground no. 1 raised in assessee's appeal pertains to disallowance u/s 14A of the Act. 5. The brief facts of the case pertaining to this issue, as emanating from the record, are: During the year under