← All Phrases

“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

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2571/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2570/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2569/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2568/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2567/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2566/DEL/2024[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

2917/Del/2024 Indian Renewable Energy Development Agency Ltd. 7.3 Issue No. 4:Whether the disallowance u/s 14A relevant in AY: 2017-18 and 2018-19 is justified. 7.4 Issue No. 5: Whether the depreciation on building, residential flat at Jungpura, New Delhi is erroneously allowed by Ld. CIT(A). Issue

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5417/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

facts and in the circumstances of the case, Ld. CIT (Appeals) was not justified and erred in law in upholding the disallowance u/s 14A read with Rule 8D without appreciating the fact that expenditure amounting to Rs. 50,00,000/ - incurred towards earning exempt income has already been suo-moto ... without appreciating the fact that the appellant had sufficient own funds out of which investments had been made and therefore, disallowance u/s 14A read with Rule 8D(2)(ii) is unwarranted. 3.0 That on the facts and in the circumstances of the case, and without prejudice to Ground

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5416/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

facts and in the circumstances of the case, Ld. CIT (Appeals) was not justified and erred in law in upholding the disallowance u/s 14A read with Rule 8D without appreciating the fact that expenditure amounting to Rs. 50,00,000/ - incurred towards earning exempt income has already been suo-moto ... without appreciating the fact that the appellant had sufficient own funds out of which investments had been made and therefore, disallowance u/s 14A read with Rule 8D(2)(ii) is unwarranted. 3.0 That on the facts and in the circumstances of the case, and without prejudice to Ground

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3158/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

facts and in the circumstances of the case, Ld. CIT (Appeals) was not justified and erred in law in upholding the disallowance u/s 14A read with Rule 8D without appreciating the fact that expenditure amounting to Rs. 50,00,000/ - incurred towards earning exempt income has already been suo-moto ... without appreciating the fact that the appellant had sufficient own funds out of which investments had been made and therefore, disallowance u/s 14A read with Rule 8D(2)(ii) is unwarranted. 3.0 That on the facts and in the circumstances of the case, and without prejudice to Ground

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3157/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

facts and in the circumstances of the case, Ld. CIT (Appeals) was not justified and erred in law in upholding the disallowance u/s 14A read with Rule 8D without appreciating the fact that expenditure amounting to Rs. 50,00,000/ - incurred towards earning exempt income has already been suo-moto ... without appreciating the fact that the appellant had sufficient own funds out of which investments had been made and therefore, disallowance u/s 14A read with Rule 8D(2)(ii) is unwarranted. 3.0 That on the facts and in the circumstances of the case, and without prejudice to Ground

Deputy Commissioner of Income Tax, Kolkata vs. Techno Electric & Engineering Company Ltd, Uttar Pradesh

Appeal of the revenue is dismissed

ITA 1982/KOL/2025[2017-18]Status: DisposedITAT Kolkata23 Dec 2025AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 14ASection 250

investment in Mutual Funds, bonds, equity shares which has yielded exempt income of Rs. 11,64,80,280/- and has not made any disallowance u/s 14A of the Act. Accordingly, the AO computed disallowance at Rs. 5,57,26,060/- by applying one of the average investments ... said case, Hon'ble ITAT held that the investments made by the assessee in its subsidiary are not to be reckoned for disallowance u/s. 14A read with Rule 8D. 6.4 Thus, considering all the above facts of the case that the appellant has not invested the funds in its subsidiaries

DCIT, CC 6(2), Mumbai vs. Tata Aig General Insurance Company Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 5394/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

Section 10(15)(iv)Section 10(34)Section 143(3)Section 14ASection 194HSection 250Section 30Section 32Section 40Section 44

u/s 10(34) of the Act and also, that related to this exempt income, the expenses related to this exempt income should be disallowed u/s 14A of the Act. We find that the fact remains that the disallowance u/s 14A is recurring issue in assessee’s case. The co-ordinate

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

In the result, appeal of the revenue is dismissed

ITA 1549/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-2014

Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri P. J. Pardiwala, Sr. Advocate and Shri C. Naresh, CAFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 10Section 115JSection 143(3)Section 14ASection 90

u/s. 14A read with Rule 8D(iii). The Appellant Bank prays that the learned ACIT be directed not to make disallowance u/s. 14A read with Rule 8D of Rs.10,87,05,359/- towards expenditure incurred in relation to income claimed exempt u/s. 10 of the Act and reduce the total ... acceptable, on the facts and in circumstances of the case and in law, the learned ACIT be directed to restrict the disallowance u/s. 14A in respect of expenses (other than interest) Treasury Division of the Bank to Rs.24,88,588/- (being proportionate expenses suo-moto disallowed in the return

Bank of India, Mumbai vs. The ACIT-2(1)(1), Mumbai

ITA 1397/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawal

Section 10Section 115JSection 143(3)Section 14ASection 90

balance amount of Rs.1,32,73,52,994/- was further 5 ITA Nos.1397 and 1549/MUM/2023 Bank of India AY 2013-14 disallowed u/s 14A r.w. Rule 8D and added to the total income of the assessee. 4.2. In the reassessment order u/s 143(3) r.w.s 254 of the Act dated ... case of PCIT vs. State Bank of Patiala [2018] 259 taxmann.Com 314, the Hon'ble High Court took a view that disallowance u/s 14A should be restricted to the maximum of exempt income only. Following this judgement, the disallowance u/s 14A r.w Rule 8D worked

DCIT, Circle-21(1), New Delhi vs. Religare Securities Ltd., New Delhi

In the result, appeal of the Revenue is partly allowed

ITA 7556/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Dec 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Dcit, M/S Religare Securities Ltd., Circle-21(1), 2Nd Floor, Room No. 202 B, Vs Rajlok Building, 24, 2Nd Floor, C.R. Building, I.P. Nehru Place, Estate, New Delhi-110019. New Delhi Pan- Aaacf1952D Revenue Assessee

Section 143(2)Section 143(3)Section 14A

company had declared dividend income of Rs.10,00,000/- which it claimed as exempt income. The assessee company had suo-moto offered a disallowance u/s 14A amounting Rs.7,67,24,357/- in the original return which was revised in the revised return of income to Rs.5 ... offered as business income and taxed under the head PGBP and therefore the same was not considered for the purpose of calculation of disallowance U/s 14A. 2.2. Thereafter, the AO in para no. 2.2 of its order recorded his satisfaction for making disallowance u/s 14A of the Act, in accordance

Asstt.Commissioner of Income Tax, Pune vs. Nitin Dwarkadas Nyati, Pune

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

ITA 1426/PUN/2025[2020-21]Status: DisposedITAT Pune19 Dec 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Acit, Central Circle 2(3), Nitin Dwarkadas Nyati Pune Sr. No.103/129, Nyati Unitree, Vs. Yerwada, Nagar Road, Pune – 411006 Pan: Aabpn2601F (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Vidya Ratan Kishore Date Of Hearing : 15-12-2025 Date Of Pronouncement : 19-12-2025 O R D E R

For Appellant: Shri Krishna V GujarathiFor Respondent: Shri Vidya Ratan Kishore
Section 143(1)Section 143(2)Section 143(3)Section 14A

assessing the total income at Rs.40,41,76,243/- after making addition of Rs.3,05,36,389/- on account of disallowance u/s 14A of the Act and Rs.50,79,854/- on account of education cess. 3. So far as the disallowance of Rs.3,05,36,389/- u/s 14A read with ... year under consideration. 5. In appeal, the Ld. CIT(A) relying on various decisions directed the Assessing Officer to re-compute the disallowance u/s 14A read with Rule 8D @ 1% by taking only those investments from which income not forming part of the total income has been earned

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2767/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

justified in deleting the disallowance made u/s 14A r.w. Rule 8D of the Act, by holding that no disallowance u/s 14A of the I.T. Act ignoring the clarifications issued by the CBDT vide Circular No. 5 of 2014 dated 11.02.2014 issued by the Central Board of Direct Taxes which clearly ... incorporated the adjustment proposed by Ld.TPO. In furtherance, the Ld.AO also computed; • Restricted the disallowance under section 80IA at Rs.200,22,69,287/- • disallowance u/s 14A r.w.s.8D amounting to Rs. 14,85,775/- and; • disallowed depreciation claimed on capitalisation expenses for the work done by M/s. Gremach Infrastructure Equipments & Projects

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2367/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

justified in deleting the disallowance made u/s 14A r.w. Rule 8D of the Act, by holding that no disallowance u/s 14A of the I.T. Act ignoring the clarifications issued by the CBDT vide Circular No. 5 of 2014 dated 11.02.2014 issued by the Central Board of Direct Taxes which clearly ... incorporated the adjustment proposed by Ld.TPO. In furtherance, the Ld.AO also computed; • Restricted the disallowance under section 80IA at Rs.200,22,69,287/- • disallowance u/s 14A r.w.s.8D amounting to Rs. 14,85,775/- and; • disallowed depreciation claimed on capitalisation expenses for the work done by M/s. Gremach Infrastructure Equipments & Projects

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2366/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Dec 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

justified in deleting the disallowance made u/s 14A r.w. Rule 8D of the Act, by holding that no disallowance u/s 14A of the I.T. Act ignoring the clarifications issued by the CBDT vide Circular No. 5 of 2014 dated 11.02.2014 issued by the Central Board of Direct Taxes which clearly ... incorporated the adjustment proposed by Ld.TPO. In furtherance, the Ld.AO also computed; • Restricted the disallowance under section 80IA at Rs.200,22,69,287/- • disallowance u/s 14A r.w.s.8D amounting to Rs. 14,85,775/- and; • disallowed depreciation claimed on capitalisation expenses for the work done by M/s. Gremach Infrastructure Equipments & Projects

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

ITA 2365/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Dec 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

justified in deleting the disallowance made u/s 14A r.w. Rule 8D of the Act, by holding that no disallowance u/s 14A of the I.T. Act ignoring the clarifications issued by the CBDT vide Circular No. 5 of 2014 dated 11.02.2014 issued by the Central Board of Direct Taxes which clearly ... incorporated the adjustment proposed by Ld.TPO. In furtherance, the Ld.AO also computed; • Restricted the disallowance under section 80IA at Rs.200,22,69,287/- • disallowance u/s 14A r.w.s. 8D amounting to Rs. 14,85,775/- and; • disallowed depreciation claimed on capitalisation expenses for the work done by M/s. Gremach Infrastructure Equipments