DCIT, CIRCLE-2(1)(1), KANPUR, KANPUR vs. JAGRAN PRAKASHAN LIMITED, KANPUR
What did the Tribunal hold?
The Tribunal found that the CIT(A) did not provide a speaking order for the reduced disallowance and that the assessee's computation was illegible. Therefore, the issue was restored to the CIT(A) for a de novo assessment.
What were the facts?
The Revenue appealed against the CIT(A)'s order which reduced a disallowance under Section 14A from Rs. 3,23,75,462 to Rs. 17,44,468. The assessee had earned exempt dividend income of Rs. 40,91,883.
What were the issues?
Whether the CIT(A) erred in reducing the disallowance under Section 14A without a proper speaking order and adequate justification, and whether the disallowance should be restricted to the exempt income earned.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, LUCKNOW BENCH ‘A’, LUCKNOW
Before: SHRI KUL BHARAT, VICE- & SHRI ANADEE NATH MISSHRA
PER ANADEE NATH MISSHRA:A.M.
(A) The present appeal has been filed by Revenue against the impugned appellate order of learned CIT(A)/ National Faceless Appeal Centre (NFAC), Delhi dated 23.06.2025, for the AY 2018-19. The Revenue has raised the following grounds of appeal:
“1. The Ld. CTT(A) erred in law and facts failed to appreciate that the assessee's own ledger shows the dividend claimed as exempt was entirely from mutual funds; hence the assessee's contention R that such dividend is taxable for the relevant year is factually and legally untenable.
The Ld. CIT(A) erred in law and facts in accepting the assessee's
The order continues below.
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