TRC ENGINEERING INDIA PRIVATE LIMITED,BENGALURU vs. ACIT, CIRCLE-7(1)(1), BENGALURU

ITA 1655/BANG/2025Status: DisposedITAT Bangalore11 September 2026AY 2017-185 pages
AI SummaryAllowed

What were the facts?

The assessee company engaged in architectural engineering made investments, including Rs. 60 lakhs in Neev Capital India Opportunity Series I, from which it earned exempt income. The assessee suo moto disallowed Rs. 17,945/- as expenditure relatable to this exempt income.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) did not record satisfaction regarding the suo moto disallowance made by the assessee before computing disallowance under Section 14A. The AO's disallowance of Rs. 11,37,141/- was therefore not justifiable.

What were the issues?

Whether the Assessing Officer can compute disallowance under Section 14A without recording satisfaction on the assessee's suo moto disallowance, and whether disallowance can be made on the entire investment when exempt income relates to a portion.

Which sections of the Income-tax Act were involved?

Section 14A,Section 10(35)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI BALAKRISHNAN S & SHRI KESHAV DUBEY

For Respondent: Shri. Pradeep S - Addl. CIT
Pronounced: 11.09.2026

PER SHRI BALAKRISHNAN S, ACCOUNTANT MEMBER:

This appeal is filed by the Assessee against the order of Ld. Addl/JCIT(A)-3, Chennai, vide DIN: ITBA/APL/S/250/2025-26/1076542512(1) dated 30-May-2025 for the Assessment Year 2017-18, arising out of the Order passed under section 143(3) of the Act, dated 04.12.2019. 2. Briefly stated, the facts of the case are assessee company engaged in the business of

The order continues below.

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