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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

DCIT Cir 3(1)(1), Mumbai vs. Airmid Developers Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 7081/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Aug 2023AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri K. GopalFor Respondent: Shri Manoj Kumar
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 271(1)(c)Section 92C

erred in making disallowance of Rs.300,000/- u/s 14A of the Act. Ground No. 6: Without prejudice to Ground no 5 that disallowance u/s 14A is not at all warranted on the facts of the case, the learned AO under the directions issued by Hon'ble DRP, erred in ignoring ... settled legal proposition that the computation of disallowance u/s 14A as per Rule 8D is compulsory u/s 14A (2) if the A.O. is not satisfied with the claim of the assessee. Ground No. 7: On the facts and circumstances of the case and in law, the learned AO erred

Airmid Developers Ltd, New Delhi vs. DCIT Cir 3(1), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 6758/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Aug 2023AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri K. GopalFor Respondent: Shri Manoj Kumar
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 271(1)(c)Section 92C

erred in making disallowance of Rs.300,000/- u/s 14A of the Act. Ground No. 6: Without prejudice to Ground no 5 that disallowance u/s 14A is not at all warranted on the facts of the case, the learned AO under the directions issued by Hon'ble DRP, erred in ignoring ... settled legal proposition that the computation of disallowance u/s 14A as per Rule 8D is compulsory u/s 14A (2) if the A.O. is not satisfied with the claim of the assessee. Ground No. 7: On the facts and circumstances of the case and in law, the learned AO erred

Jt. CIT(OSD), Central Circle-4, New Delhi vs. Sudhir Power Ltd., New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 34/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Aug 2023AY 2017-18

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

DCIT, Circle-4, New Delhi vs. Sudhir Power Ltd., New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 900/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Aug 2023AY 2016-17

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

DCIT, Circle-4, New Delhi vs. Sudhir Power Ltd., New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 899/DEL/2021[2012-13]Status: DisposedITAT Delhi30 Aug 2023AY 2012-13

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

Sudhir Power Ltd., New Delhi vs. DCIT, Circle-4, New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 1043/DEL/2021[2017-18]Status: DisposedITAT Delhi30 Aug 2023AY 2017-18

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

Sudhir Power Ltd., New Delhi vs. DCIT, Circle-4, New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 1042/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Aug 2023AY 2016-17

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

Sudhir Power Ltd., New Delhi vs. ACIT, Circle-4, New Delhi

In the result, the appeal of the assessee is allowed for AY

ITA 1041/DEL/2021[2012-13]Status: DisposedITAT Delhi30 Aug 2023AY 2012-13

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Income Tax Rules treating it as sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act by applying the computation mechanism provided under second and third limb of Rule 8D(2) of the Rules. 9. We find that ... ./Del/2021 Sudhir Power Ltd. vs. DCIT sacrosanct and adopting it as the only method of computing disallowance. The Ld. AO accordingly made disallowance u/s 14A of the Act after applying the computing mechanism provided in 2nd and 3rd limb of Rule 8D(2) of the Rules. We find that

ACIT, Circle- 26(1), New Delhi vs. V C Solutions Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

ITA 1884/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Aug 2023AY 2014-15

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. V. K. Agarwal, ARFor Respondent: Sh. P. Barnwal, CIT DR
Section 14ASection 36Section 36(1)

order of the ld. CIT(A) is affirmed on this ground. 10 CO No. 41/Del/2021 V C Solutions Pvt. Ltd. CO No. 41/Del/2021 Disallowance u/s 14A: 11. Relevant facts for adjudication of the issue are that the assessee has disallowed Rs. 42,85,983/- u/s 14A read with rule ... DCIT; 2018-TIOL-461-ITAT-CHD wherein it was held that when assessee is able to show that the suo moto disallowance u/s 14A made by it was mistaken, then he has a legal right to reconcile from its return in accordance 11 CO No. 41/Del/2021 V C Solutions

M/S. Ahiliabai Sardessai, Panaji vs. Income Tax Officer, Ward 2(4), Panaji

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

ITA 8/PAN/2021[2014-15]Status: DisposedITAT Panaji29 Aug 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.08/Pan/2021 िनधा"रण वष" / Assessment Year : 2014-15 M/S. Ahiliabai Sardessai, Vs. Ito, Ward-2(4), Panaji. 301, Lotus Court, M. G. Road, St. Inez Junction, Panaji- 403001. Pan : Aagfa9044G Appellant Respondent Assessee By : Shri N. J. Prabhudesai Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 26.03.2021 For The Assessment Year 2014-15. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Partnership Firm Engaged In The Business Of Mining. The Return Of Income For The Assessment Year 2014-15 Was Filed On 30.09.2014 Declaring A Loss Of Rs.4,92,14,101/- & The Same Was Revised At Loss

For Appellant: Shri N. J. PrabhudesaiFor Respondent: Shri N. Shrikanth
Section 143(3)Section 14ASection 41(1)

Being aggrieved by the above additions, an appeal was filed before the NFAC, who vide impugned order, confirmed the disallowance u/s 14A r.w. Rule 8D(2)(iii) of the Income Tax Rules, 1962 (‘the Rules’) and deleted the addition u/s 14A r.w. Rule ... also deleted the addition on account of sundry creditors of Rs.48,45,698/-. 4. Being aggrieved by the disallowance u/s 14A r.w. Rule 8(D)(2)(iii), the appellant is in appeal before us in the present appeal. 5. Before us, it is contended that the appellant had not incurred

Fomento Karnataka Mining Company Private Limited (Now Amalgamated With Fomento Resources Private Limited, Panaji vs. Joint Commissioner of Income Tax, Margao Range, Margao

In the result, the appeal filed by the assessee stands partly allowed

ITA 26/PAN/2021[2009-10]Status: DisposedITAT Panaji29 Aug 2023AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.26/Pan/2021 िनधा"रण वष" / Assessment Year : 2009-10 Fomento Karnataka Mining Vs. Jcit, Margao Range, Company Private Limited, Margao, Goa. (Now Amalgamated With Fomento Resources Private Limited), 102, 1St Floor, Kamat Metropolis-I, Behind Caculo Mall, St. Inez, Panaji, Goa- 403001. Pan : Aaacf7487K Appellant Respondent Assessee By : Shri Nishant Thakkar Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Panaji [‘The Cit(A)’] Dated 27.08.2021 For The Assessment Year 2009-10. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Processing & Trading In The Iron Ore. The Return Of Income For The Assessment Year 2009-10 Was Filed On 30.09.2009 Declaring Total Income Of Rs.26,40,77,220/-. Against The Said Return Of Income, The Assessment Was Completed By The Joint Commissioner Of Income Tax, Margao Range, Margao (‘The Assessing Officer’) Vide Order Dated 30.12.2011 Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’) At A Total Income Of Rs.26,63,57,955/-. While Doing So, The Assessing Officer Made Disallowance U/S 14A Of Rs.15,49,787/-, Disallowance On Account Of Sundry Creditors Extracting As Fictitious Of Rs.7,30,948/-. 3. Being Aggrieved, An Appeal Was Filed Before The Ld. Cit(A) Contending That No Disallowance U/S 14A Is Required To Be Made In The Absence Of Any Expenditure Incurred To Earn The Exempt Income. It Was Also Contended That No Addition On Account Of Outstanding Creditors Is Required To Be Made, As The Credits Represent The Opening

For Appellant: Shri Nishant ThakkarFor Respondent: Shri N. Shrikanth
Section 143(3)Section 14ASection 14A(2)

Income Tax Act, 1961 (‘the Act’) at a total income of Rs.26,63,57,955/-. While doing so, the Assessing Officer made disallowance u/s 14A of Rs.15,49,787/-, disallowance on account of sundry creditors extracting as fictitious of Rs.7,30,948/-. 3. Being aggrieved, an appeal was filed before ... contending that no disallowance u/s 14A is required to be made in the absence of any expenditure incurred to earn the exempt income. It was also contended that no addition on account of outstanding creditors is required to be made, as the credits represent the opening 3 balance

DCIT-6(1)(1), Mumbai vs. M/S. Essar House Pvt Ltd., Mumbai

In the result, the appeal on this ground is Allowed

ITA 1924/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Aug 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2015-16 Dy. Cit-6(1)(1), M/S Essar House Pvt. Ltd., Room No. 504, 5Th Floor, 11, Essar House, K.K. Vs. Aayakar Bhavan, M.K. Road, Marg, Mahalaxmi, Mumbai-400020. Mumbai-400034. Pan No. Aaacj 2883 P Appellant Respondent

For Appellant: NoneFor Respondent: Mr. Biswanath Das, CIT-DR
Section 14Section 14A

provisions of 23/2022 (Explanatory notes to the provisions of the bai Finance Act, the bai Finance Act, 2022) dt. 03.11.2022 that disallowance u/s 14A has to be made 2022) dt. 03.11.2022 that disallowance u/s 14A has to be made 2022) dt. 03.11.2022 that disallowance u/s 14A has to be made ... u/s 143(3) of the Act with. In the assessment completed u/s 143(3) of the Act on 23.11.2017, the Assessing Officer made disallowance u/s 14A of on 23.11.2017, the Assessing Officer made disallowance u/s 14A of on 23.11.2017, the Assessing Officer made disallowance u/s 14A of the Act amounting

Girnar Software Private Limited, 6Th Floor, Jaipur Textile Market, B-2, Near Model Town, Malviya Nagar, Jaipur vs. PCIT – 2, Jaipur, New Central Revenue Building

In the result, the appeal of the assessee is allowed

ITA 330/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri PC Parwal, CAFor Respondent: Shri Arvind Kumar (CIT)
Section 142(1)Section 143(2)Section 14ASection 263

assessee did not earn any exempt income during the year under consideration. When there is no exempt income, the question of making any disallowance u/s 14A shall not arise, as held by Hon’ble Delhi High Court in the case of Era Infrastructure (India) Ltd (2022)(141 taxmann.com 289)(Delhi ... Hence, the question as to whether any disallowance u/s 14A could be made when there is no exempt income, becomes a debatable issue. It is well settled proposition of law that the revision proceedings u/s 263 could not be initiated on debatable issues. Accordingly, we set aside the order passed

Central Bank of India, Mumbai vs. The National Faceless Appeal Centre, Delhi

In the result, the appeal by the assessee is partly allowed

ITA 235/MUM/2023[2019-20]Status: DisposedITAT Mumbai25 Aug 2023AY 2019-20

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani
Section 10Section 14ASection 250Section 270A

Income- tax Rules, 1962 ("the Rules") towards expenditure incurred in relation to income claimed exempt u/s. 10 of the Act without appreciating that disallowance u/s. 14A is not warranted in the Bank's case where securities are held as stock-in-trade and dividend/interest income is Central Bank of India ... sufficient owned fund to make investment in Tax- free securities and hence 14A disallowance is not warranted. The NFAC be directed to delete disallowance u/s. 14A read with Rule 8D of Rs. 1911,07,68,683 towards expenditure incurred in relation to income claimed exempt u/s

Nikhil J. Shah HUF, Mumbai vs. ACIT 17(2), Mumbai

In the result the appeal of the assessee is allowed for the statistical purpose

ITA 1708/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Aug 2023AY 2014-15
For Appellant: Shri. Surendra Nijsure, ARFor Respondent: Shri. Ashok Kumar Ambastha, DR
Section 143(2)Section 14ASection 250

mutual funds at ₹18,83,413/- and interest on tax free bonds at ₹11,89,296/-. However, the assessee has not made any disallowance u/s 14A r.w.r. 8D of the IT Rule. On query the assessee explained that no expenses were incurred on investment from which exempt income was earned ... required to verify by the Ld. CIT(A). 8. Heard both the sides and perused the materials on record. The AO has computed disallowance u/s 14A r.w.r. 8D to the amount of ₹7,20,683/- considering that assessee has earned exempt income of ₹18,83,413/- from shares and mutual

L & T Finance Holdings Limited, Mumbai vs. Deputy Commissioner of Income Tax-2(2)(1), Mumbai

In the result, the appeal filed by the assessee is In the result, the appeal filed by the assessee is In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2633/MUM/2022[2014-15]Status: DisposedITAT Mumbai24 Aug 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2014-15 L & T Finance Holdings Ltd., Dcit-2(2)(1), Brindavan Plot No. 177 Cst M.K. Road, New Marine Vs. Road, Kalina Santacruz Lines (East), Mumbai-400020. Mumbai-400098. Pan No. Aabcl 5046 R Appellant Respondent

For Appellant: Mr. Jeet KamdarFor Respondent: Ms. Sanyogita Nagpal, (CIT-DR)
Section 14A

facts and in the circumstances of the case, the Ld. CIT(A) was not justified and grossly erred in confirming the disallowance u/s 14A. L & T Finance Holdings Ltd.. 2 L & T Finance Holdings Ltd.. ITA No. 2. Briefly stated, facts of the case are Briefly stated, facts ... average value of investment of (‘B’ above 3. 05.% of the average value of investment of (‘B’ above Rs.29175381410/- - x 0.5% = Total disallowance u/s 14A Total disallowance u/s 14A 3. On further appeal, the Ld. CIT(A) upheld the disallowance On further appeal, the Ld. CIT(A) upheld the disallowance

M/S Mafatlal Industries Limited, Mumbai vs. Dy Commissioner of Income Tax-Central Circle-8(2), Mumbai

In the result, appeal is partly allowed

ITA 881/MUM/2023[2011-12]Status: DisposedITAT Mumbai22 Aug 2023AY 2011-12

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

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

grounds of appeal:- 2 ITA 881/Mum/2023 Mafatlal Industries Limited “1. (a) The Ld. CIT (Appeals) erred in law and facts in restricting the disallowance u/s. 14A of the Income Tax Act, 1961 (hereinafter referred to as "the Act") merely to the tune of Rs.24,89,968/- without appreciating the fact ... cannot be accepted. 11.18 In view of above discussion, the matter is restored back to the file of AO for recomputing the disallowance u/s 14A in terms of above observations. Thus, revenue's appeal is dismissed and assessee's cross-objection, on the issue in question, stand allowed for statistical

Aditya Birla Nuvo Ltd, Mumbai vs. Addl CIT Ltu, Mumbai

In the result, additional grounds raised by the assessee are allowed

ITA 4220/MUM/2015[2010-11]Status: DisposedITAT Mumbai22 Aug 2023AY 2010-11
Section 14ASection 80(2)(ii)

14A, treating the same as Interest attributable towards expenditure incurred in relation to the Investment. The AO may be directed to reduce the disallowance u/s 14A accordingly," 5. In the result, Miscellaneous Application by the assessee is allowed in the terms aforesaid. 2. The brief facts are that assessee

Aditya Birla Nuvo Ltd, Mumbai vs. Addl CIT Ltu, Mumbai

In the result, appeal of the assessee is allowed

ITA 2525/MUM/2014[2009-10]Status: DisposedITAT Mumbai22 Aug 2023AY 2009-10
Section 14ASection 254(2)Section 438Section 43B

leave salary. 2. We have heard the rival submissions and perused the relevant materials available on record. With regard to the issue of disallowance u/s 14A of the Act, we find that the assessee had raised original ground before us with regard to disallowance of administrative expenses made under third

Career Point Limited, Kota, Rajasthan vs. Principal Commissioner of Income Tax, Udaipur, Rajasthan

In the result, the appeal of the assessee is allowed

ITA 242/JPR/2023[2018-19]Status: DisposedITAT Jaipur22 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri Ajey Malik (CIT)
Section 143(2)Section 143(3)Section 14ASection 263

sustained by the Tribunal. 23 Career Point Limited, Kota. The revenue's appeal therefore, requires no further entertainment and hence dismissed.” 2.10 No disallowance u/s 14A can be made where there is no exempt income from the impugned investments. Assessee’s own funds i.e. equity and reserves amount