This compilation indexes twelve recent rulings — spanning multiple benches of the Income Tax Appellate Tribunal (ITAT) and two High Courts — in which Section 14A of the Income Tax Act, 1961 was a central or co-central issue. The rulings were pronounced between March 2026 and June 2026 and are drawn from the TaxNoticeAI structured legal corpus. The compilation is designed for use by in-house tax teams, Big-4 associates, and law firm researchers who need a consolidated, citation-ready index of recent judicial activity on this provision.

Research index only. This page is a structured case-law reference tool and does not constitute legal or tax advice. Readers should verify all rulings against the full text of the judgment and check for subsequent stays, reversals, or appeals before relying on any entry.

The statutory framework in one paragraph

Section 14A of the Income Tax Act, 1961 provides that no deduction shall be allowed in respect of expenditure incurred by an assessee in relation to income which does not form part of the total income under the Act — i.e., exempt income. The provision was introduced to prevent taxpayers from claiming deductions for expenses that are attributable to income streams that are entirely exempt from tax. Rule 8D of the Income Tax Rules, 1962 prescribes the method for computing the disallowance where the Assessing Officer is not satisfied with the correctness of the assessee's own claim of expenditure under this section. The interplay between Section 14A, Rule 8D, and the requirement that the Assessing Officer record satisfaction before invoking the provision has generated a significant body of litigation across ITATs and High Courts.

The 12 rulings

1. Sanjiv Dhireshbhai Shah vs Income Tax Officer Ward 1(3)(5)

Bench: Gujarat High Court
Date: 15 June 2026
Sections engaged: 10(38), 142(1), 143(3), 147, 148, 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as a Special Civil Application (R/SCA No. 18268 of 2019) before the Gujarat High Court at Ahmedabad. Per the source preview, the petitioner had disclosed exempt income at the time of filing the original Return of Income, with details provided regarding long-term capital gain of Rs. 1,74,34,398/- under section 10(38) of the Act; the Senior Standing Counsel for the Revenue was unable to controvert this position at the time of final hearing on 15 June 2026. An ad-interim order had been granted in the petitioner's favour by a Coordinate Bench of the same Court on 21 October 2019.

2. Shankara Building Products vs DCIT, Circle-6(1)(1), Bengaluru

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 11 June 2026
Sections engaged: 10(34), 142(1), 143(2), 143(3), 14A, 234A, 234B, 234C, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee, a retailer of home improvement and building products, filed this appeal (ITA No. 291/Bang/2026) for Assessment Year 2020-21 against an order passed under section 250 by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 10 November 2025. Per the source preview, the solitary grievance of the assessee was against the disallowance made under section 14A read with Rule 8D of the Income Tax Rules, 1962.

3. Dahej Harbour And Infrastructure vs ACIT, Circle 5(1)(2), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 June 2026
Sections engaged: 115J, 142(1), 143(1), 143(3), 14A, 14A(2), 198, 250, 32
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee, a company engaged in the business of development, maintenance, administration and operation of a jetty, filed this appeal (ITA No. 281/Mum/2026) for Assessment Year 2017-18 against an order of the CIT(A), National Faceless Appeal Centre, Delhi, dated 28 November 2025, which itself arose from an assessment order passed under section 143(3) dated 21 December 2019. The appeal was heard on 23 April 2026 and pronounced on 10 June 2026.

4. Triton Trading Company Private Limited vs DCIT 5(3)(2), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 9 June 2026
Sections engaged: 143(3), 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee company (PAN: AAACC1480H) challenged, through its grounds of appeal for Assessment Year 2015-16, the disallowance of Rs. 1,15,68,030/- made under section 14A read with Rule 8D of the Income Tax Rules, 1962. Per the source preview, the assessee had itself offered a disallowance of Rs. 60,000/- under section 14A in its return of income, having made investments in shares and mutual funds from which exempt income was derived; the Assessing Officer, however, took the view that the disallowance should be higher given the extent of those investments.

5. ACIT, Cc-2, Thane, Thane vs Rajesh Manuprasad Trivedi, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 9 June 2026
Sections engaged: 131, 133(6), 14A, 68
Outcome: Outcome not specified in source
Procedural / substantive ground: These cross-appeals, covering Assessment Years 2015-16 and 2016-17, involved the assessee (PAN: ABXPT5347F), who is engaged in the business of civil construction and execution of contract and sub-contract works mainly for Government and Semi-Government authorities. Per the source preview, the principal controversy in these appeals related to additions made by the Assessing Officer; section 14A was among the provisions engaged alongside section 68. The matter was heard on 8 April 2026 and pronounced on 9 June 2026.

6. Deputy Commissioner Of Income Tax vs Essar Ports Limited, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 8 June 2026
Sections engaged: 115J, 14, 143(3), 14A, 254(1), 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: These cross-appeals (ITA No. 2997/MUM/2025 and ITA No. 2544/MUM/2025) were directed against the order of CIT(A)-56, Mumbai dated 10 February 2025 for Assessment Year 2013-14. The order was passed under section 254(1) of the Income Tax Act. Per the source preview, both the Revenue and the assessee (PAN: AAACE8391D) had raised grounds before the Tribunal; the matter was heard on 18 March 2026 and pronounced on 8 June 2026.

7. ACIT Circle 15(1)(2), Mumbai vs Hitech Corporation Limited, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 April 2026
Sections engaged: 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter involved a consolidated hearing of multiple ITA numbers (ITA Nos. 8503, 8504, 8505, 8506 and 8507/MUM/2025, and ITA Nos. 536 and 537/MUM/2026) covering Assessment Years 2011-12 to 2015-16 for the assessee (PAN: AAACH5161N). Per the source preview, the appeals arose from orders of the ACIT/DCIT-10(3), Mumbai passed under section 143(3) for various years, and the matter was heard on 9 April 2026 with pronouncement on 29 April 2026. Section 14A was the sole provision cited in the sections list for this case.

8. Bosch Chassis Systems India Private vs The Assistant Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Pune
Date: 20 April 2026
Sections engaged: 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee (PAN: AAACK7312E) filed these appeals (ITA Nos. 1387 & 1388/PUN/2025) for Assessment Years 2016-17 and 2017-18 against ACIT, Circle 1(1), Pune. Per the source preview, ground of appeal No. 3 was not pressed by the assessee's counsel and was accordingly dismissed as 'not pressed', while ground of appeal No. 4 was dismissed as general in nature; ground of appeal No. 1 involved a challenge under section 14A. The matter was heard on 13 April 2026 and pronounced on 20 April 2026.

9. Care Detergents Private vs ACIT, Circle 2(1)(1), Kanpur, Civil

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 10 April 2026
Sections engaged: 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee (PAN: AACCC1365M) filed this appeal (ITA No. 414/LKW/2025) for Assessment Year 2017-18 against an order of the Addl/JCIT(A)-1 dated 20 May 2025, which had dismissed the assessee's appeal against the Assessing Officer's order passed under section 143(3) on 20 December 2019. Per the source preview, the assessee had filed a return of income on 26 October 2017 disclosing a total income of Rs. 30,74,64,300/-, and the case was selected for limited scrutiny to examine expenses debited through the P&L account for earning exempt income, which were significantly lower as compared to the investments made to earn such income.

10. Archit Gupta S/O Shri Radheshyam Gupta vs Union Of India (2026:Rj-Jp:13718-Db)

Bench: Rajasthan High Court - Jaipur
Date: 2 April 2026
Sections engaged: 14A, 24(xia)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 18221/2023 before the High Court of Judicature for Rajasthan, Bench at Jaipur. Per the source preview, the petition was filed against multiple respondents including the Union of India and various state and central government departments. The available text preview is largely procedural and does not disclose the substantive grounds argued; the sections cited include section 14A alongside section 24(xia).

11. DCIT Cc 5 2, Mumbai, Mumbai vs Kalyan Vyapaar Private Limited, Mumba

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 27 March 2026
Sections engaged: 148, 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: These three Revenue appeals (ITA Nos. 6257, 6258 and 6851/MUM/2025) covering Assessment Years 2011-12, 2013-14 and 2015-16 were directed against three separate orders passed by CIT(A)-53, Mumbai in respect of the assessee Kalyan Vyapaar Pvt. Ltd. (PAN: AABCK1377N). Per the source preview, as common issues-in-dispute were involved, the appeals were heard together and disposed of by a consolidated order; the sole ground raised by the Revenue for Assessment Year 2011-12 is noted in the source preview but the text is truncated before disclosing the substantive ground.

12. ACIT, Circle-5(1), Hyderabad vs Ushodaya Enterprises Private Limited

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 13 March 2026
Sections engaged: 14A, 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: These Revenue appeals (ITA Nos. 1781 & 1782/Hyd/2025) for Assessment Years 2017-18 and 2018-19 were filed by ACIT, Circle-5(1), Hyderabad against the assessee Ushodaya Enterprises Private Limited (PAN: AAACU2690P), feeling aggrieved by orders passed by the CIT(A), National Faceless Appeal Centre (NFAC). The hearing concluded on 4 March 2026 and the order was pronounced on 13 March 2026. The source preview does not disclose further substantive detail beyond the identity of the parties and the appellate procedural context.

Patterns across these 12 rulings

Rule 8D invocation is a recurring dispute axis. At least two cases in this set — Shankara Building Products and Triton Trading Company — explicitly involve the computation of disallowance under section 14A read with Rule 8D. The Triton Trading matter also illustrates a recurring pattern in which the assessee itself offers a self-assessed disallowance in the return, which the Assessing Officer then augments during scrutiny proceedings.
Consolidated multi-year hearings are common. Multiple rulings in this set (Hitech Corporation Limited, Kalyan Vyapaar, and the Rajesh Manuprasad Trivedi cross-appeals) involved consolidated disposal of appeals spanning two or more assessment years where a common issue was involved — suggesting that section 14A disputes frequently recur across successive years for the same assessee.
Revenue appeals are not uncommon. Cases 6 (Essar Ports), 7 (Hitech Corporation — cross-appeals), 11 (Kalyan Vyapaar), and 12 (Ushodaya Enterprises) all involve the Revenue as the appellant before the ITAT, indicating that CIT(A) orders granting relief on section 14A grounds are regularly contested by the department.
Section 14A frequently appears alongside substantive assessment provisions. Across the 12 rulings, section 14A is consistently cited alongside provisions such as section 143(3) (scrutiny assessment) and section 250 (appellate orders), reflecting the standard procedural pathway: assessment → CIT(A) → ITAT, with section 14A disallowance as the subject matter at each tier.
High Court jurisdiction is invoked in select cases. Two of the twelve rulings (cases 1 and 10) are before High Courts rather than the ITAT — one via a writ petition challenging the basis of a reassessment, the other via a civil writ petition — indicating that section 14A issues occasionally escalate to constitutional or supervisory jurisdiction, though the ITAT remains the primary forum.

How to use this compilation

This compilation is organised as a structured research index, not an exhaustive digest. Each entry records the bench, date, sections engaged, and outcome direction as extracted from the source data, along with a brief procedural note drawn strictly from the available text preview. Because several text previews in the underlying source data are truncated before disclosing the substantive holding, the outcome direction for all twelve entries is recorded as "Outcome not specified in source." Researchers should retrieve and read the full text of each judgment — available on indiankanoon.org or the respective court portal — before drawing any analytical conclusions about the ratio or holding.

When using this index for litigation or advisory support, always verify whether the ruling has been stayed, appealed, or reversed at a higher forum. An ITAT order may have been challenged before the jurisdictional High Court; a High Court order may be pending before the Supreme Court. The TaxNoticeAI corpus is updated periodically, but real-time tracking of appeal chains is not guaranteed. Additionally, check for any applicable CBDT circulars or instructions issued after the date of a ruling that may affect the provision's application, particularly given the legislative history of section 14A and the periodic CBDT guidance on the satisfaction-recording requirement.

For research across multiple section 14A rulings, it is useful to note the assessment year(s) involved in each case, since the application of Rule 8D and the judicial interpretation of the "satisfaction" requirement have evolved over time. Rulings pertaining to older assessment years may reflect the legal position before subsequent legislative or judicial clarification; researchers should map each ruling to the applicable assessment year before applying it to a current matter.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 14A Disallowance: 12 ITAT and HC Rulings (2026)