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Income Tax : No disallowance under section 14A can be made if assessee has not incurred and claimed any expenditure on exempt income

Facts in brief:- The assessee is a Private Limited Company. It filed its return of income on 26.9.20

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Income Tax : Disallowance under sec 14A cannot exceed dividend income and rebate can be allowed only when there is some liability to income tax

During the assessment proceeding the AO found that the assessee had shown dividend income of Rs.5,60

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Income Tax : AO has to determine amount of such expenditure on the basis of a reasonable and acceptable method of apportionment to disallow under sec 14A

The only issue for consideration relates to disallowance u/s 14A of the Act. The facts of the case s

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Income Tax : AO can made addition under sec 14A read with rule 8D the dividend received from investment out of surplus fund

This appeal of the assessee is directed against the order passed by the CIT (A)- IV, New Delhi, date

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Income Tax : Provisions of Rule 8D are not ultra virus the provision of sec 14A and do not offend Article 14 of the Constitution

The assessee is a company engaged in the business of syndication of loans, placement of bond and oth

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Income Tax : As per sec 14A Rule 8D is applicable with effect from A.Y 2008-09

Facts of the case are that the assessee filed its return qua the assessment year on14.11.2006 declar

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Income Tax : Before the assessment year 2008-09 provision of sec 14A(1) should apply instead of Rule 8D

The facts, in brief, are that in the assessment order the AO had noted that assessee had shown divid

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Income Tax : Disallowance can be made under sec 14A and Rule 8D only after giving opportunity of being heard to the asseessee

The facts are that against the assessment order, the assessee filed an appeal before the CIT(A), whe

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Income Tax : Sec 14A restrict the allowance of expenditure related to exempted income subject to the date of introduction of rule 8D

We have heard both the parties and gone through the facts of the case as also the aforesaid decision

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Income Tax : Disallowance under sec 14A for earning exempt dividend income restricted to 1% of the dividend

Brief facts are that the assessee is a private limited company carrying on business of dealing in sh

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Income Tax : Sec 14A not applied on the interest accrued on bond issued by Bank and assessee need to prove the source of investment to claim deduction under sec 10(33)

The tribunal in the impugned order has examined the factual matrix relating to acquisition/purchase

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Income Tax : Before the date rule 8D come into existence sec 14A(1) applied to determine the expenditure incurred for income not forming part of the taxable income

We have heard the learned counsel for the assessee and the ld. Departmental Representative and consi

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Income Tax : Disallowance under sec 14A can be made if the expenditure related with exempted income

First issue which is common in both the appeals relates to addition made under sec. 14A of the Act.

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Income Tax : Before Rule 8D came in to existence AO is duty bound under sec 14A(1) to determine the expenses related to exempted income

Briefly stated facts of the case are that the assessee company is engaged in the business of Trading

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Income Tax : Until and unless there was actual expenditure for earning the exempted income there could not be any disallowance under sec 14A

The short issue involved in these appeals is: whether common expenses incurred by an assessee can be

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Income Tax : When Rule 8D is not applicable the provision of sec 14A is to be followed and AO is duty bound to determine the expenses related to particular income

Briefly stated facts of the case are that the assessee company is engaged in the business of Trading

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Income Tax : As per sec 14A of IT expenses incurred to earn tax free income is liable to be disallowed

The captioned appeals being three (3) in number are directed against a common judgment of the Inc

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Income Tax : Interest bearing fund can be invested in share of another company and the expenditure on investment can not be disallowed under sec 14A

Facts of the case in brief are that the A.O. during the course of assessment proceedings noted that

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Income Tax : CIT can not directed AO for disallowance under sec 14A by invoking Rule 8D of the IT Act.

The above appeal is filed by assessee against the order dated 01.06.2009 of the ld. CIT-XII (Admn.),

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Income Tax : Sec 14A is applicable on all Expenditure of Investment in share of operating Company for controlling interest and new introduced rule can not be applicable on the pending proce

Whether expenditure (including interest paid on funds borrowed) in respect of investment in shares o

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