“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

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

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

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

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

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

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

Rajalakshmi Reneabl;Es Private Limited, Chennai vs. ITO, Corporate Ward-5(4), Chennai

The appeal stand allowed for statistical purposes

ITA 1395/CHNY/2023[2017-18]Status: DisposedITAT Chennai13 May 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1395/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2017-18) M/S. Rajalakshmi Renewables Private Ltd. Ito बनाम/ #66, Kurunji, New Avadi Road, Kilpauk, Corporate Ward-5(4) Vs. Chennai-600 010. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcs-0503-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri N. Arjun Raj (Advocate)-Ld. Ar " थ"कीओरसे/Respondent By : Shri Ar V Sreenivasan (Addl.Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 09-05-2024 घोषणा की तारीख /Date Of Pronouncement : 13-05-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri N. Arjun Raj (Advocate)-Ld. ARFor Respondent: Shri AR V Sreenivasan (Addl.CIT)-Ld. DR

Section 143(2)Section 143(3)Section 14ASection 194ASection 271BSection 40

submissions, Ld. AO made assessment wherein Ld. AO proposed penalty u/s 271B, made disallowance u/s 40(a)(ia) as well as another disallowance u/s 14A. Upon further appeal, the assessee did not make any effective representation. 3. The Ld. CIT(A) confirmed disallowance u/s 40(a)(ia) on the ground ... that the assessee failed to furnish the copies of Form 26A. The disallowance u/s 14A was also confirmed. The ground relating to initiation of penalty u/s 271B was dismissed. Aggrieved, the assessee is in further appeal before us. 4. The Ld. AR sought another opportunity of hearing before

Asahi Songwon Colors Limited, Ahmedabad vs. Deputy Commissioner of Income Tax, Aaykar Bhavan, Ahmedabad

The appeal of the assessee is partly allowed

ITA 710/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad10 May 2024AY 2017-18

Bench: Smt.Annapurna Gupta & Ms. Suchitra R. Kambleassessment Year : 2017-18 Asahi Songwon Colors Limited, Deputy Commissioner Of Vs. 20 Block B, Times Corporate Income Tax, Park, Opp Copper Stone, Central Circle 2 (3), Thaltej, Shilaj Road, Aaykar Bhavan, Ahmedabad -380059 Ahmedabad Pan : Aaaca 9713 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sunil Talati, Ar Revenue By : Ms. Saumya Pandey Jain, Sr Dr सुनवाई की तारीख/Date Of Hearing : 13.02.2024 घोषणा की तारीख /Date Of Pronouncement: 10.05.2024 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals)-12, Ahmedabad [Hereinafter Referred To As "Cit(A)" For Short] Dated 18.08.2023 Passed Under Section 250(6) Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2017-18. 2. Ground Nos. 1 & 2, It Was Stated, Relate To The Same Issue Of Disallowance Made Of Expenses Incurred In Relation To Earning Exempt Income, In Terms Of Provisions Of Section 14A Of The Act. The Disallowance So Made By The Assessing Officer & Confirmed By The Ld. Cit(A) Amounts To Rs.23,00,575/-. Ground Nos. 1 & 2 Raised By The Assessee Read As Under:- Asahi Songwon Colors Ltd Vs. Dcit Ay : 2017-18 2

For Appellant: Shri Sunil Talati, ARFor Respondent: Ms. Saumya Pandey Jain, Sr DR

Section 10(34)Section 10(38)Section 14Section 14ASection 250(6)

read as under:- Asahi Songwon Colors Ltd Vs. DCIT AY : 2017-18 2 “1. The Ld. CIT(A) has erred in confirming the disallowance u/s. 14A of the Act amounting to Rs.23,00,575/- by invoking Rule 8D of the Income Tax Rules, 1962. The Ld. CIT(A) has erred ... therefore the disallowance so made prayed to be deleted. 2. Without prejudice to the above, the Ld. CIT(A) has erred in confirming disallowance u/s. 14A r.w.r. 8D of the Rules of Rs. 23,00,575/- which is bad in facts as well in law. On the basis of facts

DCIT, Circle-8(1), Kolkata vs. Itc Limited, Kolkata

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1223/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

context of disallowance of interest attributable to funds invested towards tax free income but the same analogy is applicable for considering the disallowance u/s 14A read with Rule 8D(2)(iii). Therefore we are inclined to hold that 17 I.T.A. Nos.1068 & 1166/Kol/2017 ITA Nos. 1222 & 1223/Kol/2017 Assessment Year ... assessee which worked out the expenditure u/s 14A read with Rule 8D(2)(iii) at Rs. 45,14,500/- and is a reasonable disallowance u/s 14A read with Rule 8D(2)(iii). This is line with the decision of the Coordinate bench in the case of M/S Ultratech Cement

DCIT, Circle-8(1), Kolkata vs. Itc Limited, Kolkata

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1222/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

Itc Limited, Kolkata vs. ACIT, Range-8, Kolkata

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1166/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

Itc Limited, Kolkata vs. ACIT, Range-8, Kolkata

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1068/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

Infina Finance Private Limited, Mumbai vs. DCIT 2(2)1, Mumbai

ITA 417/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 May 2024AY 2013-14

Section 143(3)Section 14A

intention of the Legislature in bringing the explanation to Section 14A clearly reinforces the Circular No.5/2014 dated 11/02/2014 regarding the computation of disallowance u/s 14A as per Rule 8D. The question of applicability of the explanation prospectively or retrospectively will only come if there had been no circular. However

Income Tax Officer, Mumbai vs. Barindra Overseas Pvt. Ltd., Mumbai

In the result, the appeals of the revenue for AY 2010-11 and 2011-12 are dismissed

ITA 2606/MUM/2023[2011-2012]Status: DisposedITAT Mumbai10 May 2024AY 2011-2012

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Respondent: Shri Laxmi Kant , Sr. DR

Section 115Section 115JSection 143(3)Section 14ASection 263Section 48

Order under section 263 of the Act on 30.03.2015 for the reason that the AO failed to examine the issue of adding back disallowance u/s 14A of the Act while computing book profit u/s 115JB of the Act. The AO while completing the assessment under section 143(3) r.w.s.263 added ... Whether on the facts and in the circumstances of the case and in law, the Tribunal is justified in restoring the issue of disallowance u/s. 14A to the file of the Assessing to decide afresh in view of the decision of the Honorable Bombay High Court in the case

Income Tax Officer, Mumbai vs. Barindra Overseas Pvt. Ltd., Mumbai

In the result, the appeals of the revenue for AY 2010-11 and 2011-12 are dismissed

ITA 2605/MUM/2023[2010-2011]Status: DisposedITAT Mumbai10 May 2024AY 2010-2011

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Respondent: Shri Laxmi Kant , Sr. DR

Section 115Section 115JSection 143(3)Section 14ASection 263Section 48

M/S. Tourism Finance Corporation of India Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal filed by the Assessee is partly

ITA 6130/DEL/2013[2008-09]Status: DisposedITAT Delhi10 May 2024AY 2008-09

Bench: the time of hearing."

Section 143(1)Section 143(2)Section 14ASection 36(1)(viia)

earning of the dividend income as per Rule 8D should not be disallowed. In response, the assessee submitted as under: "As regards disallowance u/s 14A read with rule 8D, it is submitted that the corporation has not incurred any direct expenditure for earning the income from dividend. The interest expenditure ... since there is no interest expenditure." As regards the inclusion of average of investment made during the year for consideration for making the disallowance u/s 14A, it is submitted that the investments were bought and sold during the year only. The income in respect of the same has been offered

Assistant Commissioner of Income Tax, Mumbai vs. Essar Ports Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 406/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 May 2024AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 115JSection 143(3)Section 144C(1)Section 14ASection 4A

fact and in the circumstance of the case Land in law, the Ld. CIT(A) erred in directing the AO to restrict the disallowance u/s. 14A of the I.T. Act, 1961 at Rs. 22,08,04,470/-, when the assessee company while computing its taxable income suo-moto disallowance u/s ... circumstances of the case p and in law, the Ld. CIT(A) erred in directing the AO to delete the disallowance u/s. 14A of the I.T. Act, 1961, of Rs. 38,00,65,574/- which the assessee company suo-moto made while computing income as per the provisions of section

M/S Jayant Tradelink Pvt. Ltd., Kolkata vs. ITO, Ward-7(4), Kolkata

In the result, appeal of the assessee is allowed

ITA 21/KOL/2024[2013-14]Status: DisposedITAT Kolkata08 May 2024AY 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Pradip Kumar Choubey, Hon’Blei.T.A. No. 21/Kol/2024 Assessment Year: 2013-14 M/S. Jayant Tradelink Private Ltd. Income Tax Officer, Ward – 7(4), C/O. M/S. Salarpuria Jajodia & Co. Vs Kolkata 7, C.R. Avenue 3Rd Floor Kolkata - 700072 [Pan : Aaacj6483H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Siddharth Jhajharia, Fca Revenue By : Shri Nicholash Murud, Addl. Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 29/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”) Dt. 19/12/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2013-14. 2. Though The Assessee Has Raised Several Grounds Of Appeal, But Its Sole Grievance Is In Respect Of The Disallowance Confirmed By The Ld. Cit(A) Amounting To Rs.27,59,132/- Made By The Ld. Assessing Officer U/S 14A Of The Act. 3. At The Outset, The Ld. Counsel For The Assessee Has Submitted That No Exempt Income Was Earned During The Year And, Therefore, In View

For Appellant: Shri Siddharth Jhajharia, FCAFor Respondent: Shri Nicholash Murud, Addl. CIT, D/R

Section 14ASection 250

earned during the year and, therefore, in view 2 I.T.A. No. 214/Kol/2024 Assessment Year: 2014-15 Mamta Choraria of the settled judicial precedents, disallowance u/s 14A of the Act, is uncalled for. The ld. D/R failed to revert the contentions made by the assessee. 4. We, therefore, considering the admitted ... been held that the amendment made in Section 14A of the Act by Finance Act, 2022, will be applicable prospectively and also that disallowance u/s 14A of the Act should not exceed the exempt income earned by the assessee during the year, delete the alleged disallowance

Tirumala Irons (P) Ltd, Kolkata vs. ITO, Ward-4(1), Kolkata

In the result, appeal of the assessee is partly allowed

ITA 993/KOL/2023[2012-13]Status: DisposedITAT Kolkata08 May 2024AY 2012-13

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 993/Kol/2023 Assessment Year: 2012-13 Tirumala Irons (P) Ltd. Income Tax Officer, Ward – 4(1), Subash Agarwal & Associates, Vs Kolkata /Assessing Officer, Nfac, Delhi Advocates Siddha Gibson 1, Gibson Lane Suite 213, 2Nd Floor Kolkata - 700069 [Pan : Aaact9984H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Siddharth Agarwal, Advocate Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals) (Hereinafter The “Ld. First Appellate Authority”) Dt. 27/07/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Ld. Cit(A) Was Not Justified In Passing The Order Exparte Without Affording Reasonable Opportunity Of Hearing. 2. For That The Ld. Cit (A) Was Not Justified In Confirming The Addition Of Rs. 4,81,00,000/- Made By The A.O. On Account Of Share Capital Including Share Premium By Wrongly Applying The Decision Of Hon'Ble Supreme Court In The Case Of Cit Vs. T.V. Sundaram Iyenger & Sons Ltd. 222 Itr 344. 2

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Rakesh Kumar Das, CIT, D/R

Section 131Section 143(2)Section 14ASection 250Section 68

Assessing Officer is hereby deleted and Ground Nos. 2 & 3 raised by the assessee are allowed. 9. As far as the disallowance u/s 14A of the Act is concerned, we notice that the assessee has earned dividend income of Rs.9,33,018/-. The assessee has also made investment in quoted ... equity shares. No suo moto disallowance u/s 14A of the Act has been offered by the assessee. The ld. Assessing Officer has invoked Section 14A of the Act and calculated the disallowance applying Rule 8D of the Income Tax Rules, 1962 (in short ‘the Rules’). Now, going through the bifurcation

Piem Hotels Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Circle 3(2)(2), Mumbai

In the result, the appeal for A

ITA 4339/MUM/2023[2014-2015]Status: DisposedITAT Mumbai08 May 2024AY 2014-2015

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri H.M. Bhatt, DR

Section 143(3)Section 14A

rightly deleted the disallowance made by the AO u/s 14A r.w Rule 8D. Consequently we hold that, the interest expenditure cannot be disallowed u/s 14A r.w. Rule 8D(2) (ii) under any circumstances." 10. Now let us examine the assessment order to see whether this mandatory conclusion that the Assessing ... said submission has been considered. In the assessment order passed u/s 143(3) dated 20.10.2010, the AO has worked out the disallowance u/s 14A as per Rule 8D at Rs.29,66,81,836/-. The assessee has also furnished working u/Rule 8D (though under protest) which amounts to Rs.44

Piem Hotels Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 3(2)(2), Mumbai

In the result, the appeal for A

ITA 4338/MUM/2023[2016-17]Status: DisposedITAT Mumbai08 May 2024AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri H.M. Bhatt, DR

Section 143(3)Section 14A

Express Publications (Madurai)Private Ltd., Chennai vs. DCIT, Company Circle-II(1), Chennai

In the result, the appeal stands partly allowed

ITA 805/CHNY/2023[2014-15]Status: DisposedITAT Chennai07 May 2024AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.805/Chny/2023 (िनधा"रणवष" / Assessment Year: 2014-15) Express Publications (Madurai) P. Ltd, Vs. Dcit No.29, Express Garden, Company Circle Ii (1) Second Main Road Industrial Estate, Now Corporate Circle 2 (1) Ambattur, Chennai 600 058. Chennai 600 034. [Pan: Aaaci 0842D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. Abirami Narendranath, Advocate ""यथ" क" ओर से /Respondent By : Shri Saujanya Ranjan, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 22.04.2024 घोषणा क" तार"ख /Date Of Pronouncement : 07.05.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Ms. Abirami Narendranath, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS, JCIT

Section 143(3)Section 14ASection 36(1)(iii)Section 40Section 40a

vide order dated 31.12.2016. 2. The Assessee has filed 17 grounds of appeal. Ground Nos. 1 to 5 is in relation to the disallowance u/s 14A of the Act read with Rule 8D. Ground No. 6 pertains to the Employee’s contribution to PF/ESI. Ground No. 7 is in respect

Himalaya Food International Limited, New Delhi vs. ACIT, Circle 11(2), New Delhi

Appeal is allowed for statistical purposes

ITA 2008/DEL/2023[2012-13]Status: DisposedITAT Delhi06 May 2024AY 2012-13

Bench: Shri C. N.Prasad & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 14ASection 263Section 80I

determining the income at Rs. 23,75,422/-after disallowing part of deduction u/s 80IC of the Act and making disallowance u/s 14A of the Act under normal provision of the Act and book profit of Rs. 4,78,13,000/- in accordance with the provisions of Section 115JB

National Commodity & Derivatives Exchange Limited, Mumbai vs. The Assistant/Deputy Commissioner of Income Tax-15(2)(1) Mumbai Circle 15(1)(2), Mumbai

In the result, the appeals are dismissed

ITA 3808/MUM/2023[2014-15]Status: DisposedITAT Mumbai03 May 2024AY 2014-15

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Ketan VedFor Respondent: Shri Ashok Kumar Ambastha

Section 14A

account of disallowance of penalty income transferred to Investor Protection Fund and ₹ 18,03,402/- on account of disallowance u/s 14A of the Act r/w Rule 8D of the Rules. Before the Assessing Officer, it was contended on behalf of the appellant that the penalty income is statutorily required ... Assessing Officer refused to accept the said contention and proceeded to make the said addition. 6. Insofar as disallowance u/s 14A r/w Rule 8D for A.Y 2013-14 is concerned, the assessee had shown an income of ₹8,27,21,363/- as exempt dividend income. The Assessing Officer found that

National Commodity & Derivatives Exchange Limited, Mumbai vs. The Assistant/Deputy Commissioner of Income Tax, 15(2)(1), Mumbai(Now Circle 15(1)(2), Mumbai

In the result, the appeals are dismissed

ITA 3807/MUM/2023[2013-14]Status: DisposedITAT Mumbai03 May 2024AY 2013-14

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Ketan VedFor Respondent: Shri Ashok Kumar Ambastha

Section 14A

ITO, New Delhi vs. M/S Apple Iron Enterprises Pvt. Ltd., New Delhi

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

ITA 4353/DEL/2015[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Or During The Hearing Of This Appeal.”

Section 132Section 143(3)Section 14ASection 153CSection 68

under: “1. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting the disallowance u/s 14A of expenditure of Rs.17,604/- by ignoring the fact that there was material to establish the direct nexus ITO vs. Apple Iron Enterprises Pvt. Ltd. between ... hearing of this appeal.” 3. At the time of hearing, the Ld. DR brought to our notice the facts of the case involving disallowance u/s 14A and addition of share application money and share premium received by the assessee u/s 68 of the Income