Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2024 Year 2024 This

Exemption u/s 14A read with Rule 8D - disallowance of ...


Expenditure disallowance on exempt income from partnership profits upheld. AO's computation valid under amended rules. CIT(A) erred in deleting disallowance. MAT adjustment partly allowed.

Case Laws     Income Tax

July 6, 2024

Exemption u/s 14A read with Rule 8D - disallowance of expenditure attributable to exempt income from partnership firm profits - correctly invoked by AO after recording dissatisfaction, as per Supreme Court ruling in Maxopp Investment Ltd. AO's computation u/r 8D(2) based on assessee's accounts is consonant with IT (14th Amendment) Rules, 2016, applicable from 02.06.2016 for AY 2017-18. CIT(A) erred in deleting disallowance. MAT adjustment u/s 115JB for disallowance u/s 14A - CIT(A) partly correct in not requiring adjustment in book profit for MAT liability, following ITAT Special Bench decisions in Vireet and Radha Madhav cases.

View Source

 


 

You may also like:

  1. This case deals with the disallowance of expenditure u/s 14A of the Income Tax Act, which pertains to expenditure incurred in relation to exempt income. The key points...

  2. Disallowance u/s 14A read with Rule 8D - In any case, as per section 14A(3) whether or not the assessee has incurred any expenditure for earning exempt income, a part of...

  3. The ITAT Raipur ruled on disallowance u/s 14A r.w.r. 8D regarding expenditure on exempt income. The assessee argued that no disallowance of interest expenditure claimed...

  4. In the present case, the Assessing Officer (AO) disallowed the expenditure claimed u/s 57(iii) of the Income Tax Act on an ad-hoc basis. The AO did not challenge the...

  5. Disallowance u/s 14A r.w.r. 8D - since AO has mechanically applied the provisions of Rule 8D while making the aforesaid disallowance without establishing any nexus of...

  6. Addition u/s 14A read with rule 8D - categorical finding and satisfaction of the A.O. that expenditure has been incurred to earn the exempt income - Disallowance upheld

  7. The ITAT addressed various issues including disallowance u/s 14A r.w.r.8D, where Revenue challenged deletion of disallowance made by AO. ITAT upheld CIT(A)'s decision,...

  8. Rental income correctly classified as "income from house property" rather than "income from business" despite composite rent including amenities charges. TDS deducted...

  9. The case concerns disallowance u/s 14A r.w.r. 8D without exempt income for A.Y. Issue of retrospective/prospective application of Section 14A explanation post Finance...

  10. The Appellate Tribunal addressed issues u/s 40(a)(ia)/43B regarding disallowance for provisions made for unfinished work claimed as expenditure. CIT (A) upheld AO's...

  11. Disallowance made u/s.14A of the Act while computing book profit u/s.115JB - actual expenses debited to profit and loss account which are incurred for the purpose of...

  12. Disallowance u/s 14A r.w.r. 8D - Addition of interest expenditure - The ITAT found substantial merit in the alternative contention of learned counsel for the assessee...

  13. Addition u/s 14A r.w.r.8D - AO mandation to record dis-satisfaction with the correctness of the Assessee's claim regarding expenditure related to exempt income - The...

  14. The ITAT upheld disallowance u/s 14A r.w.r.8D for expenditure on earning exempt income due to lack of fund utilization details. Dismissed appeal as assessee failed to...

  15. The ITAT upheld the CIT(A)'s decision to restrict TP adjustment on guarantee commission to 0.2% for one financial year, finding TPO's 0.77% adjustment unjustified. The...

 

Quick Updates:Latest Updates