ACIT,CC-4(2), MUMBAI, MUMBAI vs. TRAPTI TRADING & INVESTMENTS PRIVATE LIMITED, MUMBAI

ITA 4851/MUM/2025Status: DisposedITAT Mumbai30 September 2025AY 2013-14Bench: SMT. BEENA PILLAI (Judicial Member), SHRI OMKARESHWAR CHIDARA ( (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that disallowance calculated under Section 14A cannot be added while computing book profit under Section 115JB, following the Special Bench ruling in ACIT vs. Vireet Investment Pvt. Ltd. The CIT(A)'s order was upheld.

What were the facts?

The assessee, a Non-Banking Financial Company, filed its return for AY 2013-14. The AO made a disallowance under Section 14A. The CIT(A) deleted this disallowance. The revenue is in appeal before the tribunal.

What were the issues?

Whether disallowance under Section 14A can be added for the computation of book profit under Section 115JB of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 14A,Section 8D,Section 143(3),Section 115JB,Section 263

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Cases cited in this judgment(2)Show 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.

Income Tax Appellate Tribunal, “E” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI OMKARESHWAR CHIDARA

For Appellant: Shri. Ronak Doshi a/w, Shri. Riken Shah
For Respondent: Shri. Hemanshu Joshi, SR. D.R
Hearing: 09.09.2025Pronounced: 30.09.2025

Per: Smt. Beena Pillai, J.M.: The Present appeal filed by the revenue arises out of order dated 19/05/2025 passed by NFAC for assessment year 2013-14 on following grounds of appeal:

2 ITA 4851/Mum/2025; A.Y. 2013-14 Trapti Trading & Investments Private Limited “1. "On the facts and circumstances of the case, the Ld. CIT(A) erred in deleting disallowance of Rs.3,91,73,235/- made u/s. 14A & Rule 8D(2)(i), Rule 8D(2)(ii) & Rule 8(2)(iii) of the income tax act, 1961 without properly appreciating the facts of the case, that such addition was on the basis of the calculation as provided in Rul

The order continues below.

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