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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

Greaves Cotton Ltd, Mumbai vs. Asst CIT Cir 7(1)(1), Mumbai

In the result appeal for assessment year 2012 –

ITA 2069/MUM/2017[2012-13]Status: DisposedITAT Mumbai25 Jul 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

unutilized cenvat credit added to closing stock of assessment year 2010-11 as opening stock of assessment year 2011-12. GROUND G: DISALLOWANCE U/S. 14A r.w.r. 8D (i) Considering the free reserves and profit of the Appellant, A.O. and the DRP should not have made disallowance u/s. 14A r.w.r ... ignoring the factual details given by the Appellant explaining the arrangement with dealers and their role in the entire transactions. GROUND F: DISALLOWANCE U/S 14A R.W.R. 8D – ₹ 48,00,000/- (i) Based on the facts in the circumstances of the case, the A.O. and the DRP erred in disallowing u/s

Greaves Cotton Ltd, Mumbai vs. Asst CIT 7(1)(1), Mumbai

In the result appeal for assessment year 2012 –

ITA 1745/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Jul 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

unutilized cenvat credit added to closing stock of assessment year 2010-11 as opening stock of assessment year 2011-12. GROUND G: DISALLOWANCE U/S. 14A r.w.r. 8D (i) Considering the free reserves and profit of the Appellant, A.O. and the DRP should not have made disallowance u/s. 14A r.w.r ... ignoring the factual details given by the Appellant explaining the arrangement with dealers and their role in the entire transactions. GROUND F: DISALLOWANCE U/S 14A R.W.R. 8D – ₹ 48,00,000/- (i) Based on the facts in the circumstances of the case, the A.O. and the DRP erred in disallowing u/s

M/S Kmg International Ltd., New Delhi vs. ACIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 5591/DEL/2010[2007-08]Status: DisposedITAT Delhi21 Jul 2023AY 2007-08

Bench: Shri C.M. Garg & Shri M. Balaganeshkmg International Ltd, Vs. Acit, 375, Main Road, Gazipur, New Circle-5(1), Delhi New Delhi (Appellant) (Respondent) Pan: Aacck0590Q

For Appellant: Shri Vinod Kr. Bindal, CAFor Respondent: Shri Anuj Garg, Sr. DR
Section 14ASection 68

record. Hence the said addition must be deleted. 5. The learned CIT(A) erred in law and on facts in confirming the disallowance u/s 14A of the Act of Rs. 20,645/-on account of indirect establishment and administrative expenses ignoring the evidences placed on record. Hence the said addition

Iwi Stationary Pvt. Ltd., Mumbai vs. ACIT, Circle- 3(2)(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 1572/MUM/2023[2014-15]Status: DisposedITAT Mumbai20 Jul 2023AY 2014-15

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

Section 132Section 143(1)Section 148Section 14ASection 68

addition made u/s 14A of the Act. We noticed earlier that the assessee had earned exempt income of Rs.10,000/- and accordingly computed disallowance u/s 14A @ Rs.10,000/-, i.e., equivalent to the exempt income. We notice that the Hon’ble Bombay High Court has held in the case of Nirved ... Traders (P) Ltd (ITA No.149 of 2017 dated 23-04-2019) has held that the disallowance u/s 14A cannot be more than the exempt income. Since disallowance made by the assessee is equivalent to the exempt income, we are of the view that the AO was not justified in enhancing

Iwi Stationary Pvt. Ltd., Mumbai vs. ACIT, Circle- 3(2)(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 1571/MUM/2023[2013-14]Status: DisposedITAT Mumbai20 Jul 2023AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

Section 132Section 143(1)Section 148Section 14ASection 68

addition made u/s 14A of the Act. We noticed earlier that the assessee had earned exempt income of Rs.10,000/- and accordingly computed disallowance u/s 14A @ Rs.10,000/-, i.e., equivalent to the exempt income. We notice that the Hon’ble Bombay High Court has held in the case of Nirved ... Traders (P) Ltd (ITA No.149 of 2017 dated 23-04-2019) has held that the disallowance u/s 14A cannot be more than the exempt income. Since disallowance made by the assessee is equivalent to the exempt income, we are of the view that the AO was not justified in enhancing

ACIT, Circle Karnal, Karnal vs. Liberty Shoes Ltd., Karnal

ITA 7126/DEL/2017[2012-13]Status: DisposedITAT Delhi19 Jul 2023AY 2012-13

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 7126/Del/2017, A.Y. 2012-13 Acit, Vs. M/S. Liberty Shoes Ltd., 13Th Circle, Karnal Mile Stone, Liberty Puram G.T.Road, Bastara, Kutail, Distt. Karnal. Pan : Aaacl3146K (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 37Section 37(1)

followed the judicial pronouncements wherein it held as settled proposition of law that where no exempt income is earned no disallowance u/s 14A r.w.r 8D can be made. In fact Ld. CIT(A) relied the determination of issue in favour of assessee in assessee’s own case

Shrey Technologies Private Limited, Mumbai vs. DCIT-Central Circle-8(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 1468/MUM/2023[2015-16]Status: DisposedITAT Mumbai18 Jul 2023AY 2015-16

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.1461, 1463, 1465 & 1468/Mum/2023 (A.Ys. 2012-13 To 2015-16)

For Appellant: Vimal PunmiyaFor Respondent: Dr. Kishore Dhule
Section 14ASection 153ASection 250

submission of the appellant that it has not incurred any expenditure on invested amount in the subsidiary company as promoters nothing can be disallowed u/s 14A. 3. Appellant therefore pray that assessing officer may be directed to delete disallowances expenses of Rs.2,01,077 u/s 14A. Even state bank ... Rs.15,30,360/- and no disallowance has been made u/s 14A r.w.Rule 8D of the I.T Rule. On query, the assessee explained that disallowance u/s 14A r.w.Rule 8D should not be made since, the exempt income of Rs.15,30,360/- entirely was dividend income and there was no expenditure incurred

Shrey Technologies Private Limited, Mumbai vs. DCIT-Central Circle-8(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 1463/MUM/2023[2013-14]Status: DisposedITAT Mumbai18 Jul 2023AY 2013-14

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.1461, 1463, 1465 & 1468/Mum/2023 (A.Ys. 2012-13 To 2015-16)

For Appellant: Vimal PunmiyaFor Respondent: Dr. Kishore Dhule
Section 14ASection 153ASection 250

submission of the appellant that it has not incurred any expenditure on invested amount in the subsidiary company as promoters nothing can be disallowed u/s 14A. 3. Appellant therefore pray that assessing officer may be directed to delete disallowances expenses of Rs.2,01,077 u/s 14A. Even state bank ... Rs.15,30,360/- and no disallowance has been made u/s 14A r.w.Rule 8D of the I.T Rule. On query, the assessee explained that disallowance u/s 14A r.w.Rule 8D should not be made since, the exempt income of Rs.15,30,360/- entirely was dividend income and there was no expenditure incurred

Shrey Technologies Pvt Ltd., Mumbai vs. DCIT, CC-8(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 1461/MUM/2023[2012-13]Status: DisposedITAT Mumbai18 Jul 2023AY 2012-13

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.1461, 1463, 1465 & 1468/Mum/2023 (A.Ys. 2012-13 To 2015-16)

For Appellant: Vimal PunmiyaFor Respondent: Dr. Kishore Dhule
Section 14ASection 153ASection 250

submission of the appellant that it has not incurred any expenditure on invested amount in the subsidiary company as promoters nothing can be disallowed u/s 14A. 3. Appellant therefore pray that assessing officer may be directed to delete disallowances expenses of Rs.2,01,077 u/s 14A. Even state bank ... Rs.15,30,360/- and no disallowance has been made u/s 14A r.w.Rule 8D of the I.T Rule. On query, the assessee explained that disallowance u/s 14A r.w.Rule 8D should not be made since, the exempt income of Rs.15,30,360/- entirely was dividend income and there was no expenditure incurred

Samco Securities Limited, Mumbai vs. CIT (A) NFAC, Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1328/MUM/2023[2016-17]Status: DisposedITAT Mumbai18 Jul 2023AY 2016-17

Bench: Shri Aby T Varkey & Shri Amarjit Singhsamco Securities Ltd. Vs. National Faceless Appeal A/1004, Naman Midtown, Centre (Nfac) Senapati Bapat Road, Prabhadevi Mumbai – 400013 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics2455A Appellant .. Respondent [ Appellant By : None Respondent By : Ram Krishna Kedia Date Of Hearing 06.07.2023 Date Of Pronouncement 18.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Nfac, Delhi, Dated 20.02.2023 For A.Y. 2016-17. The Assessee Has Raised The Following Grounds Before Us: “1. On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Confirming Disallowance U/S. 14A Of Rs. 1,51,214/- Made By The Ld Ao, Without Appreciating Facts, Submissions & Evidences In Proper Perspective & Without Assigning Any Proper Reasons 2. On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Passing Order Which Is Bad In Law & Violating The Principle Of Natural Justice As Ld Cit(A) Passed Order Without Giving Opportunity Of Virtual Online Hearing & Also Without Disposing Ground No. 3 Of Appeal Regarding "Assessment Order Contrary To The Principle Of Natural Justice".

For Appellant: NoneFor Respondent: Ram Krishna Kedia
Section 10(34)Section 143(3)Section 14A

following grounds before us: “1. On facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming disallowance u/s. 14A of Rs. 1,51,214/- made by the Ld AO, without appreciating facts, submissions and evidences in proper perspective and without assigning any proper ... foregoing grounds of appeal.” 2. The solitary issue in the grounds of appeal filed by the assessee is related to confirming disallowance u/s 14A of the Act of Rs.1,51,214/- . 3. The fact in brief is that the assessing officer completed the assessment u/s 143(3) by assessing

Assistant Commissioner of Income Tax, (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 92/RPR/2020[2013-14]Status: DisposedITAT Raipur18 Jul 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

offered for disallowance any part of its claim for deduction of interest expenses, therefore, the A.O had rightly worked out the disallowance u/s 14A as per the mechanism provided in Rule 8D of the Income-tax Rules, 1963. 16. Per contra, the Ld. AR submitted that the assessee company ... funds. The Hon'ble Bombay High court in the case of CIT v HDFC Bank in ITA 330 of 2012 held that no disallowance u/s. 14A can be made in respect of interest paid on borrowings if assessee's own funds and non interest bearing funds exceeds investments

Assistant Commissioner of Income Tax (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 91/RPR/2020[2012-13]Status: DisposedITAT Raipur18 Jul 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

offered for disallowance any part of its claim for deduction of interest expenses, therefore, the A.O had rightly worked out the disallowance u/s 14A as per the mechanism provided in Rule 8D of the Income-tax Rules, 1963. 16. Per contra, the Ld. AR submitted that the assessee company ... funds. The Hon'ble Bombay High court in the case of CIT v HDFC Bank in ITA 330 of 2012 held that no disallowance u/s. 14A can be made in respect of interest paid on borrowings if assessee's own funds and non interest bearing funds exceeds investments

Macro Proprieties Private Limited, M 28 Income Tax Colony Tonk Road Jaipur vs. DCIT Central Circle 2, Lic Building Jaipur

In the result, the appeals of the assessee are allowed

ITA 174/JPR/2023[2013-2014]Status: DisposedITAT Jaipur17 Jul 2023AY 2013-2014

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.174 TO 177/JP/2023 fu/kZkj.ko"kZ@AssessmentYear : 2013-14 TO 2016-17 M/s. Macro Properties Pvt. Ltd.M-28, Income Tax Colony, Tonk Road Jaipur cuke Vs. The DCIT Central Circle-2 LIC Building, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCM 3633 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.M. Agarwal, CA jktLo dh vksjls@Revenue by: Shri JameshKurian, CI

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Shri JameshKurian, CIT
Section 153CSection 50C(1)Section 69

further erred in law as well as on facts and circumstances of the case in confirming the disallowance u/s 14A of the Income Tax Act made by the AO without recording proper satisfaction and without considering the submissions that no expenditure was incurred by the appellant.’’ Assessment Year ... further erred in law as well as on facts and circumstances of the case in confirming the disallowance u/s 14A of the Income Tax Act made by the AO without recording proper satisfaction and without considering the submissions that no expenditure was incurred by the appellant.’’ Assessment Year

Ina Hasmukh Satra, Mumbai vs. ITO, Ward-27(1)(4), Mumbai

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

ITA 1038/MUM/2023[2013-14]Status: DisposedITAT Mumbai13 Jul 2023AY 2013-14

Bench: Shri Pavan Kumar Gadale & Shri Rifaur Rahmanina Hasmukh Satra, Ito, Ward 27(1)(4), B3, Hermitage 4Th Floor, 6Th Tower, बनाम/ Parimal Chs Ltd., Complex Vashi, Vs. Rb Mehta Road, Navi Mumbai, Ghatkopar (E), Mumbai-400703. Mumbai-400077. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aapps8952C (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr. Bhupendra Shah.ARFor Respondent: Ms. Kavita kaushik.DR
Section 143(2)Section 234Section 250Section 57

share of profit from the firm and claimed exempt U/sec10(2A) of the Act. Since the assessee has not made the disallowance u/s 14A r.w.r 8D of IT Rules, the AO has issued notice for invoking the provisions.The assessee vide letter dated 7-3-2016 submitted details and working ... disallowance. Whereas, the A.O was not satisfied with the explanations and dealt on the provisions and computed disallowance u/s 14A r.w.r. 8D(2)(ii) &(iii) of the I T rules of Rs.60,153/- and assessed the total income of Rs.13,22,920/- and passed the order u/s

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

In the result, -Appeal in ITA No

ITA 7553/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jul 2023AY 2015-16

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka

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

In the result, -Appeal in ITA No

ITA 6116/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jul 2023AY 2015-16

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka

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

In the result, -Appeal in ITA No

ITA 547/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Jul 2023AY 2013-14

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka

ACIT (OSD), Circle- 21(1), New Delhi vs. Religare Finvest Ltd., New Delhi

In the result, -Appeal in ITA No

ITA 133/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Jul 2023AY 2014-15

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka

Religare Finvest Ltd., New Delhi vs. ACIT, Circle- 21(1), New Delhi

In the result, -Appeal in ITA No

ITA 7856/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Jul 2023AY 2014-15

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka

ACIT, Circle- 21(1), New Delhi vs. Religare Finvest Ltd., New Delhi

In the result, -Appeal in ITA No

ITA 5202/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Jul 2023AY 2012-13

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A

above said sustaining of the disallowance the assessee preferred the Appeal in ITA No. 4796/Del/2017 and as against the restriction of the disallowance u/s 14A, deletion of disallowance of bad debts written off and deletion of disallowance of interest on Compulsory Convertible Debentures, the department has preferred Appeal ... 4796/Del/2017 and Ground No. 1 of Departments Appeal in ITA No. 5202/Del/2017 for A.Y 2012- 13 are in respect of disallowance u/s 14A of the Act. The assessee earned dividend income during the year under consideration of Rs. 6,40,98,834/- earned from investment made in shares of Karnataka