ASSISTANT COMMISSIONER OF INCOME TAX-15(3)(1), MUMBAI, MUMBAI vs. M/S THYROCARE TECHNOLOGIES LIMITED, MUMBAI

ITA 7292/MUM/2025Status: DisposedITAT Mumbai30 March 2026AY 2021-2219 pages
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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?

Section 14A,Section 37(1),Section 10(34)

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, “E” BENCH, MUMBAI

Before: SHRI OM PRAKASH KANTSHRI SANDEEP SINGH KARHAIL

For Appellant: Shri M. Subramaniam
For Respondent: Shri Hemanshu Joshi, Sr.DR

Heard together (3 matters)

ITA No. 7292/MUM/2025
ITA No. 6721/MUM/2025
ITA No. 7293/MUM/2025

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.

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