SEMPLICE CORPORATE SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), MUMBAI

ITA 1729/MUM/2026Status: DisposedITAT Mumbai11 August 2026AY 2018-197 pages
AI SummaryAllowed

What were the facts?

The assessee claimed a deduction under Section 35DD for stamp duty related to a demerger and also had investments. The Assessing Officer disallowed a portion of expenses under Section 14A and the entire deduction claimed under Section 35DD. The CIT(A) upheld these disallowances.

What did the Tribunal hold?

The Tribunal held that no disallowance under Section 14A is permissible in the absence of exempt income. It also ruled that the deduction under Section 35DD for stamp duty related to demerger expenses should be allowed, following its own prior decision.

What were the issues?

Whether disallowance under Section 14A is valid without exempt income, and whether stamp duty paid for a demerger is deductible under Section 35DD.

Which sections of the Income-tax Act were involved?

Section 14A,Section 35DD,Section 250,Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI JAGADISH

For Appellant: Shri Ronak Doshi (Virtually appeared)
For Respondent: Shri Kishor Dhule - CIT DR
Hearing: 19.05.2026Pronounced: 11.08.2026

Per: SHRI JAGADISH, A.M.:

1.

This appeal by the assessee is directed against the order dated 30.01.2026 passed by the National Faceless Appeal Centre, Delhi [learned Commissioner of Income-tax (Appeals)] under section 250 of the Income-tax Act, 1961 (“the Act”) for Assessment Year 2018-19. The order appealed against arises from the assessment order dated 23.04.2021 passed under section 143(3) read with section 144B of the Act. Semplice Corporate Solutions Private Limited

2.

The assessee has raised the following grounds of appeal:

1.

“GROUND NO. I: DISALLOWANCE U/S 14A OF THE AC

The order continues below.

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