Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI • Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Appeals on Disallowed Expenses under Income-tax Act Partly Allowed with Remittance for Fresh Consideration The appeals regarding disallowance of expenses under section 14A of the Income-tax Act, 1961 for assessment years 2013-14 and 2014-15 were partly allowed ...
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Provisions expressly mentioned in the judgment/order text.
Appeals on Disallowed Expenses under Income-tax Act Partly Allowed with Remittance for Fresh Consideration
The appeals regarding disallowance of expenses under section 14A of the Income-tax Act, 1961 for assessment years 2013-14 and 2014-15 were partly allowed for statistical purposes by the Tribunal. The Tribunal found that the Assessing Officer had properly satisfied the conditions for disallowance under section 14A but remitted the matters back to the AO for fresh consideration in line with earlier directions. The judgments were pronounced on 17 September 2021.
Issues: 1. Disallowance of expenses under section 14A of the Income-tax Act, 1961 for assessment years 2013-14 & 2014-15.
Analysis: A.Y. 2013-14: The issue in this appeal pertains to the disallowance of &8377; 65,14,825 under section 14A of the Income-tax Act, 1961. The assessee received dividend income and claimed it as exempt u/s. 10(34) of the Act. The Assessing Officer (AO) computed the disallowance under rule 8D(iii) at &8377; 65,14,825. The contention was that the AO did not record proper satisfaction as required by section 14A(2) of the Act. The Tribunal found that the AO had properly satisfied the conditions for disallowance. The Tribunal referred to previous orders and remitted the matter back to the AO for fresh consideration in line with earlier directions.
A.Y. 2014-15: In this appeal, the AO disallowed &8377; 77,66,770 under section 14A read with rule 8D(2)(iii). The facts were similar to the previous year. The AO recorded satisfaction for disallowance u/s. 14A. The Tribunal set aside the order and remitted the matter back to the AO for computation of disallowance in accordance with directions from previous years.
In both cases, the Tribunal found that the AO had properly satisfied the conditions for disallowance under section 14A. The matters were remitted back to the AO for fresh consideration in line with earlier directions. The appeals were partly allowed for statistical purposes in both assessment years.
The judgments were pronounced on 17 September, 2021.
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