ACIT 15(3)(1), MUMBAI vs. THYROCARE TECHNOLOGIES LIMITED, NAVI MUMBAI
What did the Tribunal hold?
The Tribunal directed the Assessing Officer to consider only those investments that yielded exempt income for disallowance computation under Rule 8D. The appeals related to sales incentive expenditure were also decided based on similar facts as a lead case.
What were the facts?
The Revenue appealed against the deletion of disallowances made under Section 14A read with Rule 8D and for sales incentive expenditure. The assessee had made investments yielding exempt income and incurred some expenditure, while the Assessing Officer made a higher disallowance.
What were the issues?
Whether disallowance under Section 14A is warranted when exempt income is earned, and the correct method for computing such disallowance, including the treatment of sales incentive expenditure.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(5)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Radhasoami Satsang v. CIT1,695 citing193 ITR 321 · 1992 · SC
- ACIT v. Vireet Investment Pvt. Ltd.882 citing165 ITD 27 · 2017 · ITAT
- Biocon Ltd. v. DCIT322 citing144 ITD 21 · 2013 · ITAT
- CIT v. Biocon Ltd.242 citing121 Taxmann.com 351 · 2020 · HC
- Apex Laboratories Pvt. Ltd. v. CIT148 citing442 ITR 1 · 2022 · SC · Read judgment
Income Tax Appellate Tribunal, “E” BENCH, MUMBAI
Before: SHRI OM PRAKASH KANTSHRI SANDEEP SINGH KARHAIL
Heard together (3 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER SANDEEP SINGH KARHAIL, J.M.
The Revenue has filed the present appeals against the separate impugned orders, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless
ITAs No.6715, 6721, 6723, 7292 & 7293/Mum/2025 2 (A.Ys. 2018-19, 2020-21, 2021-22, 2022-23 & 2023-24 )
Appeal Centre, Delhi [“learned CIT(A)”] for the assessment years 2018-19, 2020-21, 2021-22, 2022-23 and 2
The order continues below.
Read the full judgment
A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.
The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.
Similar judgments
Other orders that rely on the same authority or decide the same section.
- ACIT 15(3)(1), Mumbai vs Thyrocare Technologies Limited, Navi MumbaiMumbai30 Mar 2026Partly Allowed
Also relies on Apex Laboratories Pvt. Ltd. v. CIT and 3 other authorities
The Tribunal directed the Assessing Officer to consider only those investments that yielded exempt income for disallowance computation under Rule 8D. The appeals related to sales incentive expenditure were also decided b...
- Asst CIT Cir 2(2)(1), Mumbai vs State Bank of India, MumbaiMumbai6 Jun 2023Partly Allowed
Also relies on CIT v. Biocon Ltd. and 2 other authorities
The Tribunal directed the AO to allow the set-off of losses from the merged State Bank of Saurashtra after verification. The Tribunal also dismissed the revenue's appeal regarding the provision for Employee Stock Purchas...
- DCIT Circle-7(2)(1), Mumbai vs M/S Mahindra Lifespace Developers Ltd…Mumbai23 Feb 2021Partly Allowed
Also relies on CIT v. Biocon Ltd. and 2 other authorities
The Tribunal directed the AO to recompute the disallowance of expenses related to exempt income by considering the lesser of two methods: proportionate income theory or 0.5% of investment. The Tribunal upheld the CIT(A)'...
- DCIT -CC5(2) Central RG., -5, Mumbai vs M/S. Ipca Laboratories Ltd, MumbaiMumbai8 Apr 2024Partly Allowed
Also relies on Apex Laboratories Pvt. Ltd. v. CIT and 2 other authorities
The Tribunal held that for unabated assessment years, additions made in the original assessment could not be re-added in a Section 153A assessment without incriminating material from the search. It also ruled that subsid...
- Ipca Laboratories Ltd., Mumbai vs Dy CIT -CC-5(2), MumbaiMumbai8 Apr 2024Partly Allowed
Also relies on Apex Laboratories Pvt. Ltd. v. CIT and 2 other authorities
The Tribunal ruled that for unabated assessment years, additions made under Section 153A must be based on incriminating material found during the search. It also allowed the assessee's claim for AY 2014-15 regarding the ...
More judgments on Section 14A
- Blacksoil Capital Private Limited (As… vs DCIT, Circle-1(1), HyderabadITA 2217/HYD/2026[2017-18]Status: Disposed9 Oct 2026AY 2017-18
- Hiral Construction, Mumbai vs ITO Ward 42(1)(2), MumbaiITA 8431/MUM/2025[2017-18]Status: Disposed8 Oct 2026AY 2017-18
- The Dy DIT (It) 1(2), Mumbai vs M/S Citi Bank N.A, MumbaiITA 4981/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S. Citi Bank N.A., Mumbai vs The Addl DIT (It) RG-1, MumbaiITA 4970/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S American Express Bank Ltd., Mumbai vs The Jt DIT (It)1(1), MumbaiITA 9414/MUM/2004[2000-2001]Status: Disposed8 Oct 2026AY 2000-2001
Latest GST High Court judgments
Search GST case law →- Ankil Jagdishchandra Kholwadwala vs. Union Of INDIA And AnrBombay · 22 Oct 2026
- Imtiyaz Shaikh Z Chorlekar vs. Salman ShaikhBombay · 21 Oct 2026
- S. Nithyananda vs. State Of KarnatakaKarnataka · 17 Oct 2026
- Venkadeswara Grill Works vs. The Joint Commissioner (St)Madras · 16 Oct 2026
- Mufti Clothing And Co vs. The Assistant Commissioner (St)Madras · 16 Oct 2026
