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Income Tax - Highlights / Catch Notes

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Disallowance u/s 14A - The disallowance u/s 14A was warranted ...

Income Tax

September 12, 2013

Disallowance u/s 14A - The disallowance u/s 14A was warranted even if there was no exempt income. - AT

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  1. Disallowance u/s 14A - expenses towards exempted income - AO could not have straightaway resorted to Rule 8D(2)(iii) of the Rules in order to compute the disallowance u/s 14A - AT

  2. Disallowance u/s 14A - voluntarily disallowance made was more than dividend income received - further disallowance made by the AO and confirmed by CIT(A)is not warranted...

  3. Disallowance u/s 14A in return - not earned any exempt income - request for withdrawal of suo moto disallowance before the AO itself - permitted

  4. Disallowance u/s 14A - correctness of the claim - no disallowance can be made by the Assessing Officer more than the exempt income - AT

  5. Disallowance u/s 14A - Exempted income - proportionate disallowance of interest paid by the banks for investments made in tax free bonds/ securities which yield tax free...

  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. Disallowance u/s 14A - There is direct and proximate nexus between the exempted income, which the investments shall genearate and the expenditures directly or indirectly...

  8. Disallowance u/s 14A - Disallowance made on account of interest expenditure - AO has not made any disallowance on account of interest expenditure u/s 14A of the I.T. Act...

  9. Addition u/s 14A r/w rule 8D - There being no income for shares hence obviously there are no administrative and other expenses incurred. In such facts of the case, no...

  10. Disallows of interest expenditure u/s 14A - the disallowance has to be made even in case of strategic investments in the associate company. - AT

 

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