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The Tax Publishers
Section 14A disallowances under tonnage tax regime
Facts: Assessee offered his income under presumptive basis as per tonnage tax scheme. Revenue chose to do additions to the same under Section 14A. On higher appeal -
Held in favour of the assessee that once income is presumptively taxed under tonnage tax scheme, no resort to Section 14A disallowance is possible.
Ed. Note: The decision talks on another appeal arising out of liquidator of the Company as well besides touching upon this fine print based on the assessee's own case of earlier year. Even under MAT no disallowance under Section 14A was possible earlier, now no longer correct due to forced legislative amendments.
Case:Varun Global Ltd. v. Dy. CIT 2023 TaxPub(DT) 781 (Mum-Trib)
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