Reading section 14 in juxtaposition
with sections 15 to 59 , it is clear that the words
'expenditure incurred ' in section 14A refers ... Reading Section 14 in juxtaposition with Sections 15 to
59 , it is clear that the words "expenditure incurred" in Section 14A refers
section 10(33) . Income from mutual funds stands on the same basis ;
(iii) The provisions of sub-sections (2) and "(3) of section 14A ... Reading section 14 in juxtaposition
with sections 15 to 59 , it is clear that the words
5
'expenditure incurred ' in section 14A refers
during the course of assessment proceedings had invoked the provisions of section 14A of the Income Tax Act read with Rule 8D of the Income ... further held that even in the absence of sub-section (2) and (3) of Section 14A and Rule 8D, the Assessing Officer was not precluded
assessee pointed out that the issue of disallowance under section 14A of the Act on account of expenses incurred for earning dividend income arose before ... further held that even in the absence of sub-section (2) and (3) of Section 14A and Rule 8D, the Assessing Officer was not precluded
under the provision of section 80P(2)(d) of the Income Tax Act to which the provision of section 14A is not applicable ... provisions of section 115-O of the Act and hence there was no merit in invoking the provisions of section 14A
these transactions which were exempt u/s 10(34) / 10(35) and disallowed the same u/s 14A of the Act amounting ... revenue is against the computation of disallowance in view of section 14A of the Income tax Act read with Rule 8D of the Income
view of the provisions of section 14A of the IT Act."
3. The assessee has raised the following grounds ... Ground No.7 is in connection with the provisions of section 14A of the Income Tax Act. The assessee had made investments in shares
case the Ld.
CIT(A) erred in upholding the applicability of section
14A of the Income Tax Act in the appellant's case ... essential ingredient as per provisions of section
under reference. The other investment cannot be covered u/s 14A where
no exempt income is earned
disallowed
the expenses on proportionate basis. Appl ying the provisions of Section
14A(3) , the AO computed the disallowance at Rs.6,31,865/- under ... further held that even in the absence of sub-section (2) and (3) of Section
14A and Rule 8D, the Assessing Officer was not precluded
referred to the language of the provisions of Section
14A of the Act which has been introduced by the Finance ... disallo wance could be made on mere presumptions, and
provisions of Section 14A could not be applied f or such
presumptions. The decision
