PR. COMMISSIONER OF INCOME TAX, CENTRAL, GURGAON vs. M/S METRO INSTITUTE OF MEDICAL SCIENCE PVT. LTD.

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ITA - 30 / 2024HC Delhi11 January 20242 pages
For Petitioner: PUNEET RAI
AI SummaryDismissed

What did the High Court hold?

The Delhi High Court held that the appeal raised no substantial question of law. The Court's decision was based on its prior ruling in Pr. CIT vs. M/s Era Infrastructure (India) Ltd. [2022 SCC Online Del 2157]. By following this precedent, the High Court found no grounds to interfere with the ITAT's order. Consequently, the appeal filed by the Revenue was dismissed. The operative direction was the dismissal of the appeal and the pending application.

What were the facts?

The appeal is filed by the Principal Commissioner of Income Tax, Central, Gurgaon (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT). The assessee is M/s Metro Institute of Medical Science Pvt. Ltd. The core issue revolves around additions made by the Revenue under Section 14A of the Income Tax Act, 1961. The ITAT, in its decision, relied on a previous judgment of the Delhi High Court in the case of Pr. CIT vs. M/s Era Infrastructure (India) Ltd. The Revenue has appealed this ITAT decision to the Delhi High Court.

What were the issues?

1. Whether the additions made under Section 14A of the Income Tax Act, 1961, by the Assessing Officer were justified, and if the ITAT erred in its decision. Assessee's Contentions: The judgment does not record any specific contentions made by the assessee before the High Court. However, it is implied that the assessee supported the ITAT's decision. Revenue's Contentions: The Revenue's appeal is based on the premise that the ITAT's decision concerning the additions under Section 14A was incorrect. The Revenue is challenging the ITAT's reliance on the judgment in Pr. CIT vs. M/s Era Infrastructure (India) Ltd.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

$~40 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 30/2024 & CM APPL. 1738/2024 PR. COMMISSIONER OF INCOME TAX, CENTRAL, GURGAON ..... Appellant Through: Mr.Puneet Rai, Sr.SC with Mr.Ashvini Kumar and Mr.Rishabh Nangia, Advs. versus M/S METRO INSTITUTE OF MEDICAL SCIENCE PVT. LTD. ..... Respondent Through: Mr.Artatrana Panda and Mr.Satyen Sethi, Advs. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 11.01.2024 CM APPL. 1737/2024 (Exemption) Allowed, subject to all just exceptions. Application is disposed of. ITA 30/2024 & CM APPL. 1738/2024 1. The solitary question which is raised in the instant appeal pertains to the additions which were made in terms of the provisions contained in Section 14A of the Income Tax Act, 1961 [“Act”]. 2. The Income Tax Appellate Tribunal [“ITAT”] while dealing with the aforesaid question has taken note of the judgment rendered by this Court in Pr. CIT vs. M/s Era Infrastructure (India) Ltd. [2022 SCC Online Del 2157]. 3. In view of the aforesaid and following that decision and the view expressed by the Court in Era Infrastructure, we find that the This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:11:37

appeal raises no substantial question of law. 4. Consequently, the appeal along with pending application shall stand dismissed on the aforesaid terms. YASHWANT VARMA, J. PURUSHAINDRA KUMAR KAURAV, J. JANUARY 11, 2024/MJ This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:11:37

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