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“rule 8D disallowance”

DisallowancesSection 14A / Rule 8DSection 14A / Rule 8D85 judgments

ORIENTAL HOTELS LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-5(1), CHENNAI

The appeal of the assessee is allowed for statistical purpose

ITA 2601/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Vikram VijayaraghavanFor Respondent: Shri. K. Ilaiyaraja, Addl. CIT
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 154Section 35D(8)(C)

merely held “…assessee has not contended that it has maintained separate accounts for the expenses incurred for earning exempt income” and calculated Rule 8D disallowance of Rs.13.57 lakhs. After reducing the assessee’s own disallowance at Rs.6,10,051/-, the Assessing Officer had arrived at a final disallowance of Rs.7

DCIT, CIRCLE- 25(1), NEW DELHI vs. TELECOM CONSULT INDIA LTD., NEW DELHI

Appeal is dismissed

ITA 28/DEL/2020[2016-17]Status: DisposedITAT Delhi12 Feb 2026AY 2016-17

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 143(3)Section 14A

Next comes the Revenue’s sole surviving former substantive ground seeking to revive the Assessing Officer’s action making section 14A read with Rule 8D disallowance amounting to Rs.49,64,692/- as deleted in the lower appellate discussion. We first of all note that the Revenue’s instant sole substantive

OUTSOURCEPARTNERS INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. DCIT CIRCLE- 19(1), DELHI

ITA 5975/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2018-19 Dcit, Vs. Outsourcepartners Circle-19(1), International Pvt. Ltd., Delhi 414, 4Th Foor, Dlf Jasola Tower-B, Plot No. 10 & 11, Dda District Centre Jasola, New Delhi Pan: Aaaco5734C (Appellant) (Respondent) With Assessment Year: 2018-19 Outsourcepartners Vs. The Assessment Unit, International Pvt. Ltd., Income Tax Department 414, 4Th Foor, Dlf Jasola [Jao-Dcit, Circle-19(1), Tower-B, Plot No. 10 & 11, Delhi] Dda District Centre Jasola, New Delhi Pan: Aaaco5734C (Appellant) (Respondent)

Section 143(3)Section 14A

during the course of hearing that its sole substantive ground seeks to revive the Assessing Officer’s action invoking section 14A read with Rule 8D disallowance of Rs.2,13,32,788/- made in assessment order dated 27.09.2021 and reversed in the lower appellate discussion as under: “7. Ground No.2 pertains ... stands rendered unapplicable here (supra). We thus find no reason to interfere with the lower appellate findings deleting section 14A read with Rule 8D disallowance in very terms. The Revenue fails in the instant sole substantive issue as well as in the main appeal ITA No.5808/Del/2024 therefore. 4. Coming

DCIT, CIRCLE- 19(1), DELHI vs. OUTSOURCEPARTNERS INTERNATIONAL PVT. LTD., DELHI

ITA 5808/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2018-19 Dcit, Vs. Outsourcepartners Circle-19(1), International Pvt. Ltd., Delhi 414, 4Th Foor, Dlf Jasola Tower-B, Plot No. 10 & 11, Dda District Centre Jasola, New Delhi Pan: Aaaco5734C (Appellant) (Respondent) With Assessment Year: 2018-19 Outsourcepartners Vs. The Assessment Unit, International Pvt. Ltd., Income Tax Department 414, 4Th Foor, Dlf Jasola [Jao-Dcit, Circle-19(1), Tower-B, Plot No. 10 & 11, Delhi] Dda District Centre Jasola, New Delhi Pan: Aaaco5734C (Appellant) (Respondent)

Section 143(3)Section 14A

during the course of hearing that its sole substantive ground seeks to revive the Assessing Officer’s action invoking section 14A read with Rule 8D disallowance of Rs.2,13,32,788/- made in assessment order dated 27.09.2021 and reversed in the lower appellate discussion as under: “7. Ground No.2 pertains ... stands rendered unapplicable here (supra). We thus find no reason to interfere with the lower appellate findings deleting section 14A read with Rule 8D disallowance in very terms. The Revenue fails in the instant sole substantive issue as well as in the main appeal ITA No.5808/Del/2024 therefore. 4. Coming

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, JHANDEWLAN EXTN. vs. LOTUS HERBALS PRIVATE LIMITED , DELHI

Appeal is dismissed

ITA 5143/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5143/Del/2025 : Asstt. Year : 2017-18 Dcit, Vs Lotus Herbals Pvt. Ltd., Central Circle-20, No. 2, Forest Lane, Near New Delhi-110055 Ghitorni Metro Station, South West Delhi, Delhi-110030 (Appellant) (Respondent) Pan No. Aaacl0198F Assessee By : Sh. Rohit Jain, Adv. & Ms. Deepashree Rao, Adv. Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2025–26/1076443794(1) Dated 22.05.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rohit Jain, Adv. &For Respondent: Ms. Amish S. Gupt, CIT-DR
Section 147Section 14A

detailed discussion deleting the impugned expenditure. Rejected accordingly. 5. Next comes the second substantive issue between the parties regarding section 14A r.w.s. Rule 8D disallowance of Rs.42,49,228/- made in the assessment order as reversed in the CIT(A)’s detailed discussion. Suffice to say, the earlier learned

MAHABHADRA CONSTRUCTIONS LTD,GAUTAM BUDH NAGAR vs. DCIT, CIRCLE-13(2), DELHI

Appeal is allowed for statistical purposes

ITA 5902/DEL/2024[2014-15]Status: DisposedITAT Delhi08 Jan 2026AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 5902/Del/2024 : Asstt. Year : 2014-15 M/S Mahabhadra Constructions Ltd., Vs Dcit, (Erstwhile Jaypee Development Circle-13(2), Corporation Ltd.), Sector-128, New Delhi-110002 Sultanpur, Gautam Buddha Nagar, Uttar Pradesh-201304 (Appellant) (Respondent) Pan No. Aabcj9515H Assessee By : Sh. V. K. Garg, Adv. Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 08.01.2026 Date Of Pronouncement: 08.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023–24/10552668445(1) Dated 21.08.2023, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. V. K. Garg, AdvFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 143(3)Section 14A

transpires during the course of hearing that the assessee/appellant herein is aggrieved against both the learned lower authorities’ action invoking section 14A r.w. Rule 8D disallowance amounting to Rs.2,21,36,173; in assessment 2 Mahabhadra Constructions Ltd. order dated 29.12.2016 as upheld in the lower appellate discussion

DCIT, DELHI vs. PTC INDIA LIMITED, DELHI

ITA 2858/DEL/2024[2020-21]Status: HeardITAT Delhi07 Jan 2026AY 2020-21
Section 143(3)Section 14ASection 250

taxmann.com 415 (Delhi) (SB). We accordingly\nreiterate our past remand directions to restore the instant section\n14A read with Rule 8D disallowance back to the learned Assessing\nOfficer in very terms.\n4. Learned counsel next invites our attention to page 109 in the\npaper-book raising the assessee's additional

PTC INDIA LIMITED,NEW DELHI vs. DCIT, CIRCLE- 19 (1), DELHI

In the result, appeal of the Revenue is dismissed

ITA 1186/DEL/2024[2020-21]Status: HeardITAT Delhi07 Jan 2026AY 2020-21
Section 143(3)Section 14ASection 250

taxmann.com 415 (Delhi) (SB). We accordingly\nreiterate our past remand directions to restore the instant section\n14A read with Rule 8D disallowance back to the learned Assessing\nOfficer in very terms.\n4. Learned counsel next invites our attention to page 109 in the\npaper-book raising the assessee's additional

KU POWER PROJECTS LIMITED,HYDERABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE

Appeal is allowed

ITA 7096/DEL/2025[2017-18]Status: DisposedITAT Delhi29 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18

Section 144Section 14ASection 68

before the tribunal. Deleted in very terms therefore. 5. Next comes the second substantive issue between the parties regard section 14A read with Rule 8D disallowance of Rs. 28,78,991/- made by both the learned lower authorities despite the fact that the assessee is stated to have not derived

DCIT CENTRAL CIRCLE-1(1), MUMBAI, MUMBAI vs. DENTSU AEGIS NETWORK INDIA PRVIATE LIMITED, MUMBAI

In the result, the appeal of the revenue is dismissed

ITA 6123/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Dec 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri A.K. JawadwalaFor Respondent: Shri Umashankar Prasad (CIT DR)
Section 115JSection 143(3)Section 14ASection 250

following several Tribunal decisions, held that only those investments which yielded exempt income should be considered for Rule 8D disallowance, and accordingly deleted the addition. Aggrieved, the revenue has preferred the present appeal before us. 4. The Ld. DR, in his argument stated that the assessee’s case is squarely

CAPRICON REALTY PRIVATE LIMITED ,MUMBAI vs. INCOME TAX OFFICER, CENTRAL CIRCLE MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5696/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Nov 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2018-19

For Appellant: Ms. Neha ParanjpeFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 143(3)Section 14A

assessee in the computation of income was not computed as per Rule 8D. As per the provisions of Section 14A r/w Rule 8D disallowances of expenditure in earning exempt income has to be made if the AO is satisfied that such expenditure was incurred but not disallowed by the assessee

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6 4 MUMBAI, MUMBAI vs. INDIABULLS REAL ESTATE LIMITED, NEW DELHI

Appeal is dismissed

ITA 3108/DEL/2024[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Ankit Kumar, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(3)Section 14ASection 14A(2)

Employees Stock Option Scheme compensation (ESOP expenses) amounting to Rs.96,248/-?” 4. Coming to the first and foremost islsue of section 14A r.w. Rule 8D disallowance which has been partly confirmed in the learned CIT(A)’s order, it emerges during the course of hearing this tribunal’s learned

RISHIKESH BARTER PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, DELHI

Appeal is allowed

ITA 5837/DEL/2025[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Rishikesh Barter Pvt. Ltd., A-8, Jyoti Colony, Ward-21(3), Main Loni Road, New Delhi New Delhi Pan: Aaecr6571N (Appellant) (Respondent) Assessee By Sh. Mukesh Kohli, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 143(3)Section 14A

course of hearing with the able assistance coming from both the parties that the learned lower authorities have invoked section 14A read with Rule 8D disallowance of Rs.7,95,853/- in the assessee’s case despite the fact that it has not derived any actual exempt income in the relevant

DCIT, CIRCLE - 19(1), DELHI vs. PUNJAB NATIONAL BANK (EARLIER KNOWN AS ORIENTAL BANK OF COMMERCE), DELHI

Appeal is dismissed in above terms

ITA 3161/DEL/2024[2017-18]Status: DisposedITAT Delhi24 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraassessment Year: 2017-18 Dcit, Vs. Punjab National Bank (Earlier Circle-19(1), Know As Oriental Bank Of Delhi Commerce), Harsha Bhawan, E Block, Connaught Place, Delhi Pan: Aaaco0191M (Appellant) (Respondent) Assessee By Sh. K.V.S.R. Krishana, Ca Department By Sh. Dayainder Singh Sidhu, Cit(Dr)

Section 143(3)Section 14ASection 36(1)Section 36(2)(v)

first and foremost substantive ground therefore. 6. The second substantive issue between the parties is that of section 14A read with Rule 8D disallowance of Rs.22,45,66,323/- made in assessment order, and deleted in the lower appellate discussion. This is for the precise reason that the impugned investments

PHOTON ULTRAWAVE PRIVATE LIMITED,DELHI vs. DCIT,CIRCLE-19(2), DELHI

Appeal is allowed in above terms

ITA 2638/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18
Section 142(1)Section 143(3)Section 14ASection 68

perused. 2. Coming to the first and foremost issue of correctness of both the learned lower authorities’ action invoking section 14A read with Rule 8D disallowance amounting to Rs.1,24,57,350/-; in assessment order dated 26.11.2019 and upheld in the lower appellate discussion, we note at the outset that

DCIT, CIRCLE - 10(1), NEW DELHI vs. INDIAN SUGAR EXIM CORPORATION LIMITED, SOUTH EAST DELHI

ITA 5033/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Oct 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 4744/Del/2024 : Asstt. Year : 2016-17 Indian Sugar Exim Corporation Ltd. Vs Acit, C-Block, 2Nd Floor, Ansal Plaza, Circle-12(1), August Kranti Marg, Andrews Ganj, New Delhi-110002 New Delhi-110049 (Appellant) (Respondent) Pan No. Aaaci1163M

For Appellant: Sh. Sumit Jain, CAFor Respondent: Sh. Manish Gupta, Sr. DR
Section 143(3)Section 14ASection 37

4744/Del/2024 first of all raising it’s three substantive grounds of foreign travelling expenditure, employer’s contribution to PF and section 14A r.w. Rule 8D disallowance(s) amounting to Rs.14,27,239/-, Rs.3,87,364/- and Rs.46,01,527/-; respectively, made in assessment order dated 23.12.2018 as upheld ... judicial consistency to accept the instant second substantive ground in the assessee’s favour in very terms. 6. Lastly comes section 14A r.w. Rule 8D disallowance of Rs.46,01,527/-. There is hardly any dispute between the parties that the assessee had indeed derived exempt income of Rs.4

INDIAN SUGAR EXIM CORPORATION LTD,NEW DELHI vs. ACIT CIRCLE 12(1), C R BUILDING, NEW DELHI

ITA 4744/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Oct 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 4744/Del/2024 : Asstt. Year : 2016-17 Indian Sugar Exim Corporation Ltd. Vs Acit, C-Block, 2Nd Floor, Ansal Plaza, Circle-12(1), August Kranti Marg, Andrews Ganj, New Delhi-110002 New Delhi-110049 (Appellant) (Respondent) Pan No. Aaaci1163M

For Appellant: Sh. Sumit Jain, CAFor Respondent: Sh. Manish Gupta, Sr. DR
Section 143(3)Section 14ASection 37

4744/Del/2024 first of all raising it’s three substantive grounds of foreign travelling expenditure, employer’s contribution to PF and section 14A r.w. Rule 8D disallowance(s) amounting to Rs.14,27,239/-, Rs.3,87,364/- and Rs.46,01,527/-; respectively, made in assessment order dated 23.12.2018 as upheld ... judicial consistency to accept the instant second substantive ground in the assessee’s favour in very terms. 6. Lastly comes section 14A r.w. Rule 8D disallowance of Rs.46,01,527/-. There is hardly any dispute between the parties that the assessee had indeed derived exempt income of Rs.4

JCIT OSD CIRCLE 2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

ITA 2260/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22
Section 143(3)Section 144Section 14A

stock-in-trade, no\ndisallowance u/s 14A r.w.r. 8D is warranted.According to the AO, as per\nthe provisions of section 14A r/w Rule 8D disallowance of expenditure\nin earning exempt income requires to be made if the AO is satisfied that\nsuch expenditure was incurred but not disallowed

JCIT(OSD) CIRCLE 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

ITA 2259/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-20
Section 143(3)Section 144Section 14A

stock-in-trade, no\ndisallowance u/s 14A r.w.r. 8D is warranted.According to the AO, as per\nthe provisions of section 14A r/w Rule 8D disallowance of expenditure\nin earning exempt income requires to be made if the AO is satisfied that\nsuch expenditure was incurred but not disallowed

JCIT(OSD) CIRCLE 2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

ITA 2258/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21
Section 143(3)Section 144Section 14A

stock-in-trade, no\ndisallowance u/s 14A r.w.r. 8D is warranted.According to the AO, as per\nthe provisions of section 14A r/w Rule 8D disallowance of expenditure\nin earning exempt income requires to be made if the AO is satisfied that\nsuch expenditure was incurred but not disallowed

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