ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

ITA 2618/CHNY/2019Status: DisposedITAT Chennai07 July 2025AY 2015-16Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the interest disallowance under Rule 8D(2)(ii) was unwarranted as the assessee's own funds were sufficient to cover investments. Regarding disallowance under Rule 8D(2)(iii), the Tribunal directed the AO to re-compute it considering only dividend-yielding investments, following a previous decision.

What were the facts?

The assessee claimed a deduction under Section 14A read with Rule 8D for expenses incurred in relation to exempt income. The Assessing Officer (AO) disallowed a significant portion of these expenses, both under normal provisions and for book profit. The Commissioner (Appeals) confirmed the disallowance under normal provisions but deleted it for book profit.

What were the issues?

Whether the disallowance of expenses under Section 14A read with Rule 8D for exempt income is justified, and whether such disallowance should apply to book profit under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI AMITABH SHUKLA

For Appellant: Adv. &
Hearing: 02.05.2025Pronounced: 07.07.2025

Heard together (2 matters)

ITA No.2330/Chny/2019
ITA No.2618/Chny/2019

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PER ABY T. VARKEY, JM: These appeals by the assessee and Revenue are arising out of the order of the Learned Commissioner of Income Tax (Ap

The order continues below.

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