JAMIPOL LIMITED,JAMSHEDPUR vs. DCIT CIRCLE- 1 JAMSHEDPUR, JAMSHEDPUR

ITA 285/RAN/2024Status: DisposedITAT Ranchi29 June 2026AY 2017-20183 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that where an assessee has not earned any exempt income, no disallowance under Section 14A is warranted. Following various High Court decisions, the disallowance was deleted.

What were the facts?

The assessee argued that no exempt income was earned and that the amendment relied upon by the Assessing Officer was prospective. The Assessing Officer had made a disallowance under Section 14A read with Rule 8D.

What were the issues?

Whether disallowance under Section 14A is applicable when no exempt income is earned by the assessee.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Rajiv R Mittal, AR
For Respondent: Shri Sandipan Kha, Sr. DR
Hearing: 29.06.2026Pronounced: 29.06.2026

Per George Mathan, JM: This is an appeal filed by the assessee against the order of the NFAC, Delhi [hereinafter referred to as the ‘CIT(A)’] in appeal no. CIT(A), Jamshedpur/10181/2019-20 dated 18.04.2024 for the assessment year 2017-18. 2. Shri Rajiv R Mittal, AR represented on behalf of the assessee and Shri Sandipan Kha, Sr. DR represented on behalf of the revenue.

3.

It was submitted by the ld. AR that at the outset, the assessee has not earned any exempt income. It was further submitted that the amendment of 2022 which has been relied upon by the Assessing Officer is prospective in nature. It was the submission that it was held in various decision including the decision of the Hon’ble

The order continues below.

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