RADHE RENEWABLE ENERGY DEVELOPMENT PVT LTD,RAJKOT vs. THE ACIT, CIRCLE-1(1), RAJKOT, RAJKOT

ITA 609/RJT/2026Status: DisposedITAT Rajkot17 September 2026AY 2016-1713 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that disallowance under Section 14A is not warranted in the absence of exempt income. Regarding the loan additions, the Tribunal found that the assessee had discharged its onus by providing identity, genuineness, and creditworthiness of the creditor, and therefore, the additions were deleted.

What were the facts?

The assessee appealed against disallowance of expenses under Section 14A and additions made on account of alleged fictitious loans and commission. The assessee argued that no exempt income was earned, and the loan transactions were genuine and supported by documentary evidence.

What were the issues?

Whether disallowance under Section 14A is justified without exempt income, and whether additions for alleged fictitious loans and commission are sustainable when the assessee proves identity, genuineness, and creditworthiness of the creditor.

Which sections of the Income-tax Act were involved?

Section 14A,Section 8D,Section 143(3),Section 147,Section 148,Section 68,Section 131,Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Mehul Ranpura, Ld. AR
For Respondent: Shri Gopi Nath Chaubey, Ld. Sr. DR
Hearing: 02/07/2026

Per, Dr. Arjun Lal Saini, AM: Captioned two appeals filed by the assessee, pertaining to assessment years (AY) 2013-14 & 2016-17, are directed against the order under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre (NAC) Delhi/Commissioner of Income-tax (Appeals) [in short ‘NFAC/Ld.CIT(A)’], dated 12.02.2026, which in turn arises out of an

The order continues below.

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