Tag: disallowance 14A
Merely because assessee accepted disallowance made by Assessing Officer, it cannot automatically lead to conclusion that assessee under reported income under Section 270A – ITAT ABCAUS Case Law Citation:ABCAUS 3746 (2023) (05) ITAT In the instant case, the assessee had challenged the order passed by the CIT(A) in …
Disallowance u/s 14A can not exceed exempt income – Supreme Court dismisses SLP of the Department against the judgment of Delhi High Court ABCAUS Case Law Citation: ABCAUS 2639 (2018) (11) SC Important Case Laws Cited/relied upon: Commissioner of Income Tax v. Joint Investment Pvt. Ltd. 372 ITR …
Satisfaction of AO as to incorrectness of claim of the assessee is an essential prerequisite for invoking the provisions of section 14A – ITAT ABCAUS Case Law Citation: ABCAUS 2622 (2018) (11) HC Important Case Laws Cited/relied upon: ACIT Vs. M/s Avon Cycles Ltd. CIT Vs. Abhishek Industries …
Non Satisfaction of AO to suo moto disallowance by assessee u/s 14A has to be an objective satisfaction with notice and opportunity to assessee-Supreme Court dismisses Revenue’s SLP ABCAUS Case Law Citation: ABCAUS 2404 (2018) 07 SC The assessee was a limited company. In its Return of Income for the relevant Assessment Year it had on its …
Disallowance u/s 14A read with Rule 8D beyond scope of rectification u/s 154 as the issue relating to applicability of section 14A is debatable – ITAT ABCAUS Case Law Citation: ABCAUS 2055 (2017) (08) ITAT The Grievance: The appeal filed by the assessee was directed against the order …
Recording AO satisfaction must for exempt income disallowance u/s 14A(2) and Rule 8(D) of the Income Tax Rules, 1962. High Court reverses ITAT judgment ABCAUS Case Law Citation: ABCAUS 2042 (2017) (08) HC Important Case Laws Cited/relied upon by the parties: Godrej and Boyce Mfg. Co. Ltd. v. …
Disallowance us 14A for practicing Senior Advocate of Supreme Court deleted as AO was not dissatisfied with correctness of the claim made by assessee-ITAT ABCAUS Case Law Citation: ABCAUS 1087 (2016) (12) ITAT Important Case Laws cited: CIT vs. Taikisha Engineering Ltd. Brief Facts of the Case: The …
No disallowance us 14A on presumption only-If the assessee has not claimed any expenditure on exempt income and there can not be any disallowance under section 14A on mere presumption. This was held by ITAT Kolkata in a recent judgment as under: Case Law Details: I.T.A No. 1336/Kol/2013 …
Disallowance u/s 14A Rule 8D3-Computation of total Assets include current liabilities also ITAT Delhi in a recent judgment has remanded the case to the Assessing Officer noticing that the AO for the purpose of disallowance u/s 14A computed incorrect value of “total assets” as per Rule 8D by excluding …
Computation of disallowance u/s 14A , Rule 8D-Bank Charges for Export Service not includible ITAT Delhi in a recent judgment has held that bank charges pertaining to exports services have no relation with the investments made yielding exempt income and hence not includible for calculation of disallowance u/s …
