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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

Assistant Commissioner of Income Tax, Mumbai vs. Hdfc Life Insurance Company Limited, Mumbai

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

ITA 2716/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Oct 2024AY 2019-20

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailacit – 1(1)(1) 597, Aayakar Bhavan, Mk Road, Mumbai Maharashtra–400020……………. Appellant

For Appellant: Shri Ms. Aarti VissanjiFor Respondent: Shri Manoj Kumar Sinha, Sr. AR
Section 10Section 144Section 250Section 28Section 44

raised in Revenue’s appeal are dismissed. 8. The issue arising in Ground No.8 raised in Revenue’s appeal pertains to disallowance u/s 14A of the Act. 9. The brief facts of the case pertaining to this issue, as emanating from the record, are:During the year under consideration ... 2716/Mum/2023 & C.O. 22/Mum/2024 13 10. The learned CIT(A), vide impugned order, following the judicial precedent in assessee’s own case held that disallowance u/s 14A of the Act is not attracted in the case of the assessee, which is an insurance company, due to the special provision of section

DCIT-CC-5(3), Mumbai, Air India, Nariman Point vs. Aditya Birla Sun Life Insurance Company Limited, Mumbai

In the result, appeal of the assessee is partly allowed for statistical purposes and that of the revenue is dismissed

ITA 3044/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Oct 2024AY 2021-22

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2021-22 Aditya Birla Sunlife Insurance Commissioner Of Income Tax Company Ltd., (A) – 54, 16Th Floor, Tower 1, One World Mumbai Vs. Centre, 841, Senapati Bapat Marg, Elphinstone Road, Mumbai – 400013 (Pan : Aabcb4623J) (Appellant) (Respondent) Assessment Year: 2021-22 Deputy Commissioner Of Income Aditya Birla Sunlife Tax – Central Circle – 5(3), Insurance Company Ltd., Mumbai 16Th Floor, Tower 1, One Vs. World Centre, 841, Senapati Bapat Marg, Elphinstone Road, Mumbai – 400013 (Pan : Aabcb4623J) (Appellant) (Respondent) Present For: Assessee : Shri Ronak Doshi, Ca Revenue : Shri Ajay Chandra, Cit Dr

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri Ajay Chandra, CIT DR
Section 10Section 143(3)Section 14ASection 234ASection 234BSection 37(1)Section 44Section 69C

assessee had not reported any expenditure attributable to income earned on these investments. In this regard, assessee was asked to provide computation of disallowance u/s 14A r.w.r 8D. Aditya Birla Sunlife Insurance Co. Ltd., AY 2021-22 6.1. During the course of assessment proceedings, assessee vide its submissions dated ... investments in AY 2021-22 and AY 2020-21 which was Rs. 67,61,44,87,000/- and calculated the amount of disallowance u/s 14A r.w.r 8D at Rs. 67,61,44,870/- (being 1% of the difference of Rs.67,61,44,87,000/- so calculated) and added

Aditya Birla Sunlife Insurance Company Limited, Mumbai vs. CIT (A) 54, Mumbai

In the result, appeal of the assessee is partly allowed for statistical purposes and that of the revenue is dismissed

ITA 1828/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Oct 2024AY 2021-22

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2021-22 Aditya Birla Sunlife Insurance Commissioner Of Income Tax Company Ltd., (A) – 54, 16Th Floor, Tower 1, One World Mumbai Vs. Centre, 841, Senapati Bapat Marg, Elphinstone Road, Mumbai – 400013 (Pan : Aabcb4623J) (Appellant) (Respondent) Assessment Year: 2021-22 Deputy Commissioner Of Income Aditya Birla Sunlife Tax – Central Circle – 5(3), Insurance Company Ltd., Mumbai 16Th Floor, Tower 1, One Vs. World Centre, 841, Senapati Bapat Marg, Elphinstone Road, Mumbai – 400013 (Pan : Aabcb4623J) (Appellant) (Respondent) Present For: Assessee : Shri Ronak Doshi, Ca Revenue : Shri Ajay Chandra, Cit Dr

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri Ajay Chandra, CIT DR
Section 10Section 143(3)Section 14ASection 234ASection 234BSection 37(1)Section 44Section 69C

assessee had not reported any expenditure attributable to income earned on these investments. In this regard, assessee was asked to provide computation of disallowance u/s 14A r.w.r 8D. Aditya Birla Sunlife Insurance Co. Ltd., AY 2021-22 6.1. During the course of assessment proceedings, assessee vide its submissions dated ... investments in AY 2021-22 and AY 2020-21 which was Rs. 67,61,44,87,000/- and calculated the amount of disallowance u/s 14A r.w.r 8D at Rs. 67,61,44,870/- (being 1% of the difference of Rs.67,61,44,87,000/- so calculated) and added

D.C.I.T., Circle 3(1), Mumbai vs. Icici Bank Ltd., Mumbai

In the result, appeal of the revenue in I

ITA 5792/MUM/2013[2006-07]Status: DisposedITAT Mumbai25 Oct 2024AY 2006-07

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Ms. Arati Vissanji, A/RFor Respondent: Mr. P.C. Chhotoray, Spl. Counsel, [D/R]
Section 10Section 115JSection 14Section 143(3)Section 14A

identical set of facts, the Co-ordinate Bench has allowed the exemption claimed u/s 10(23G) of the Act along with the disallowance u/s 14A of the Act. The relevant findings read as under:- “66. The first issue, as raised in ground no.1 by the Revenue corresponding to ground no.2 ... securities have been made only from its own funds and not from the borrowed funds. The AO went on to compute the disallowance u/s 14A of the Act treating application of Rule 8D to be retrospective and computed expenditure at Rs. 544 Crores and came to the conclusion that

Icici Bank Ltd, Mumbai vs. DCIT RG 3(1), Mumbai

In the result, appeal of the revenue in I

ITA 5396/MUM/2013[2006-07]Status: DisposedITAT Mumbai25 Oct 2024AY 2006-07

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Ms. Arati Vissanji, A/RFor Respondent: Mr. P.C. Chhotoray, Spl. Counsel, [D/R]
Section 10Section 115JSection 14Section 143(3)Section 14A

identical set of facts, the Co-ordinate Bench has allowed the exemption claimed u/s 10(23G) of the Act along with the disallowance u/s 14A of the Act. The relevant findings read as under:- “66. The first issue, as raised in ground no.1 by the Revenue corresponding to ground no.2 ... securities have been made only from its own funds and not from the borrowed funds. The AO went on to compute the disallowance u/s 14A of the Act treating application of Rule 8D to be retrospective and computed expenditure at Rs. 544 Crores and came to the conclusion that

Assistant Commissioner of Income Tax, Pune vs. Persistent Systems Limited, Pune

In the result, appeal of the Revenue in ITA

ITA 595/PUN/2024[2015-16]Status: DisposedITAT Pune24 Oct 2024AY 2015-16

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

Tribunal while remanding back the issue in its order dated 21.06.2023 has already held that the AO has recorded satisfaction while making the disallowance u/s 14A? 2. Whether in the facts and circumstances of the case and in law, Ld. C1T(A) is correct in deleting the addition u/s 14A ... Tribunal had remanded back the matter only for limited purpose of verification regarding suo-motO disallowance of the assessee and the question whether disallowance u/s 14A is applicable in this case was already decided by the tribunal in its order dated 21.06.2021? 3. Whether in the facts and circumstances

Assistant Commissioner of Income Tax, Pune vs. Persistent Systems Limited, Pune

In the result, appeal of the Revenue in ITA

ITA 590/PUN/2024[2016-17]Status: DisposedITAT Pune24 Oct 2024AY 2016-17

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

Tribunal while remanding back the issue in its order dated 21.06.2023 has already held that the AO has recorded satisfaction while making the disallowance u/s 14A? 2. Whether in the facts and circumstances of the case and in law, Ld. C1T(A) is correct in deleting the addition u/s 14A ... Tribunal had remanded back the matter only for limited purpose of verification regarding suo-motO disallowance of the assessee and the question whether disallowance u/s 14A is applicable in this case was already decided by the tribunal in its order dated 21.06.2021? 3. Whether in the facts and circumstances

Assistant Commissioner of Income-Tax, Pune vs. Persistent Systems Limited, Pune

In the result, appeal of the Revenue in ITA

ITA 1478/PUN/2024[2014-15]Status: DisposedITAT Pune24 Oct 2024AY 2014-15

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14Section 14ASection 250

Tribunal while remanding back the issue in its order dated 21.06.2023 has already held that the AO has recorded satisfaction while making the disallowance u/s 14A? 2. Whether in the facts and circumstances of the case and in law, Ld. C1T(A) is correct in deleting the addition u/s 14A ... Tribunal had remanded back the matter only for limited purpose of verification regarding suo-motO disallowance of the assessee and the question whether disallowance u/s 14A is applicable in this case was already decided by the tribunal in its order dated 21.06.2021? 3. Whether in the facts and circumstances

Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru vs. Manipal Health Enterprises Pvt Ltd, Bengaluru

In the result, the the revenue’s appeal is dismissed

ITA 1208/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Oct 2024AY 2014-15

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

For Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 14A

also stated that the case law cited by the assessee is distinguishable because here the assessee has accepted that disallowance u/s 14A of the Act 1961 r.w.r 8D of the IT Rules 1962, hence disallowance should be made: (Relevant para quoted below, Para 10(1) of the assessment order ... case law cited by the assessee is distinguishable because here the assessee itself has accepted that disallowance u/s 14A of the I T Act 1961 rwr 8D of the I T rules 1962 should be made ITA Nos.1031, 1092 & 1208/Bang/2024 Page 5 of 21 amounting

Manipal Health Systems Private Limited, Bangalore vs. DCIT, Central Circle 1(2), Bangalore

In the result, the the revenue’s appeal is dismissed

ITA 1092/BANG/2024[2018-19]Status: DisposedITAT Bangalore24 Oct 2024AY 2018-19

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

For Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 14A

also stated that the case law cited by the assessee is distinguishable because here the assessee has accepted that disallowance u/s 14A of the Act 1961 r.w.r 8D of the IT Rules 1962, hence disallowance should be made: (Relevant para quoted below, Para 10(1) of the assessment order ... case law cited by the assessee is distinguishable because here the assessee itself has accepted that disallowance u/s 14A of the I T Act 1961 rwr 8D of the I T rules 1962 should be made ITA Nos.1031, 1092 & 1208/Bang/2024 Page 5 of 21 amounting

Manipal Health Enterprises Private Limited, Bangalore vs. ACIT, Circle 2(3)(1), Bangalore

In the result, the the revenue’s appeal is dismissed

ITA 1031/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Oct 2024AY 2014-15

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

For Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 14A

also stated that the case law cited by the assessee is distinguishable because here the assessee has accepted that disallowance u/s 14A of the Act 1961 r.w.r 8D of the IT Rules 1962, hence disallowance should be made: (Relevant para quoted below, Para 10(1) of the assessment order ... case law cited by the assessee is distinguishable because here the assessee itself has accepted that disallowance u/s 14A of the I T Act 1961 rwr 8D of the I T rules 1962 should be made ITA Nos.1031, 1092 & 1208/Bang/2024 Page 5 of 21 amounting

Thedcit, Cochin vs. M.S Cochin International Airport Ltd, Cochin

ITA 304/COCH/2017[2007-08]Status: DisposedITAT Cochin23 Oct 2024AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

introduced by the Income Tax (Fifth Amendment) Rules 2008 with prospective effect from 24th March 2008 vide Notification No. 45/2008 for computation of disallowance u/s 14A of the Act by the AO subject to his/her satisfaction with the correctness of the claim (or no claim) by an assessee. Cochin International ... been shown by the AO to be incurred, towards the earning of the dividend incomes. bbb) If the AO wished to make a disallowance u/s 14A of the Act, a detailed comparison on a day-to-day basis needed to be made between the entering interest-bearing funds

The DCIT, Cochin vs. M.S Cochin International Airport Ltd, Cochin

ITA 193/COCH/2017[2012-13]Status: DisposedITAT Cochin23 Oct 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

introduced by the Income Tax (Fifth Amendment) Rules 2008 with prospective effect from 24th March 2008 vide Notification No. 45/2008 for computation of disallowance u/s 14A of the Act by the AO subject to his/her satisfaction with the correctness of the claim (or no claim) by an assessee. Cochin International ... been shown by the AO to be incurred, towards the earning of the dividend incomes. bbb) If the AO wished to make a disallowance u/s 14A of the Act, a detailed comparison on a day-to-day basis needed to be made between the entering interest-bearing funds

The DCIT, Cochin vs. M/S.Cochin International Airport Ltd, Cochin

ITA 167/COCH/2017[2011-12]Status: DisposedITAT Cochin23 Oct 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

introduced by the Income Tax (Fifth Amendment) Rules 2008 with prospective effect from 24th March 2008 vide Notification No. 45/2008 for computation of disallowance u/s 14A of the Act by the AO subject to his/her satisfaction with the correctness of the claim (or no claim) by an assessee. Cochin International ... been shown by the AO to be incurred, towards the earning of the dividend incomes. bbb) If the AO wished to make a disallowance u/s 14A of the Act, a detailed comparison on a day-to-day basis needed to be made between the entering interest-bearing funds

The DCIT, Cochin vs. M/S.Cochin International Airport Ltd, Cochin

ITA 166/COCH/2017[2010-11]Status: DisposedITAT Cochin23 Oct 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: 22.08.2024
Section 115JSection 143(3)Section 80I

introduced by the Income Tax (Fifth Amendment) Rules 2008 with prospective effect from 24th March 2008 vide Notification No. 45/2008 for computation of disallowance u/s 14A of the Act by the AO subject to his/her satisfaction with the correctness of the claim (or no claim) by an assessee. Cochin International ... been shown by the AO to be incurred, towards the earning of the dividend incomes. bbb) If the AO wished to make a disallowance u/s 14A of the Act, a detailed comparison on a day-to-day basis needed to be made between the entering interest-bearing funds

Kesar Terminals and Infrastructure Limited, Churchgate, Mumbai vs. Assistant Commissioner of Income Tax - 1(2)(1), Aayakar Bhavan, Mumbai

ITA 3995/MUM/2024[AY 2014-15]Status: DisposedITAT Mumbai23 Oct 2024

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidara

Section 14ASection 14A(2)Section 250Section 80I

addition made by the AO and affirmed by the Ld. Commissioner to the tune of Rs.69,22,693/- on account of disallowance u/s 14A r.w.s. 8D of the Income Tax Rules, 1962 (in short “Rules”) we observe that the Assessee has not earned any exempt income/dividend during the assessment year

Kesar Terminals and Infrastructure Limited, Churchgate, Mumbai vs. Deputy Commissioner of Income Tax - 1(2)(1), Aayakar Bhavan, Mumbai

ITA 3994/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai23 Oct 2024

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidara

Section 14ASection 14A(2)Section 250Section 80I

addition made by the AO and affirmed by the Ld. Commissioner to the tune of Rs.69,22,693/- on account of disallowance u/s 14A r.w.s. 8D of the Income Tax Rules, 1962 (in short “Rules”) we observe that the Assessee has not earned any exempt income/dividend during the assessment year

Sapphire Foods India Limited, Mumbai vs. DCIT, Circle 3(3)(1), Mumbai, Maharashtra

In the result, the Assessee’s appeal is allowed

ITA 3476/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai23 Oct 2024

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

For Appellant: Ms. Aarti Sathe, A.R. a/wFor Respondent: Smt Sujatha P. Iyangar, Sr. AR
Section 14A

held “that if the Assessee’s own funds and non interest bearing funds exceeds investment in the tax free securities then no disallowance u/s 14A of the Act can be made qua interest paid on borrowing. Further, if there are funds available both interest free and overdraft and/or loans taken

Jagat Pal Gupta, Delhi vs. ACIT, New Delhi

In the result, the appeal of the Assessee in ITA No

ITA 2079/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Oct 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 14ASection 154Section 80G

statutory allowance therefore, no amount u/s 14A of the Act disallowed for depreciation allowance claimed u/s 32 of the Act. Further submitted the disallowance u/s 14A of the Act cannot exceed the total expenditure of the Assessee. Following the plethora of Judgments sought for allowing the Ground ... HOSHANG D. NANAVATI vs. ASSISTANT COMMISSIONER OF INCOME TAX (2012) 31 CCH 0302 Mum Trib 18. Further the disallowance u/s 14A of the Act cannot exceed the total expenditure as held in following Judgments:- a. JOINT INVESTMENTS PVT LTD. vs. COMMISSIONER OF INCOME

Jagatpal Gupta, Delhi vs. ACIT, New Delhi

In the result, the appeal of the Assessee in ITA No

ITA 1688/DEL/2016[2010-11]Status: DisposedITAT Delhi23 Oct 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 14ASection 154Section 80G

statutory allowance therefore, no amount u/s 14A of the Act disallowed for depreciation allowance claimed u/s 32 of the Act. Further submitted the disallowance u/s 14A of the Act cannot exceed the total expenditure of the Assessee. Following the plethora of Judgments sought for allowing the Ground ... HOSHANG D. NANAVATI vs. ASSISTANT COMMISSIONER OF INCOME TAX (2012) 31 CCH 0302 Mum Trib 18. Further the disallowance u/s 14A of the Act cannot exceed the total expenditure as held in following Judgments:- a. JOINT INVESTMENTS PVT LTD. vs. COMMISSIONER OF INCOME