ACIT, CENTRAL CIRCLE- 20, NEW DELHI vs. AMBIENCE PVT. LTD., NEW DELHI
In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that if an assessee does not claim any exempt income, no disallowance can be made under Section 14A of the Income Tax Act. The CIT(A)'s deletion of the disallowance was upheld.
What were the facts?
The assessee company reported significant investments. The Assessing Officer disallowed expenses under Section 14A, citing the lack of bifurcation for expenses related to exempt income. The CIT(A) deleted this disallowance.
What were the issues?
Whether disallowance under Section 14A is permissible when the assessee has not claimed any exempt income.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(1)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Cheminvest Ltd. v. CIT1,569 citing378 ITR 33 · 2015 · HC · Read judgment
Income Tax Appellate Tribunal, DELHI BENCH “A”: NEW DELHI
Before: SHRI H.S.SIDHU & SHRI PRASHANT MAHARISHI
O R D E R PER PRASHANT MAHARISHI, A. M.
This is an appeal filed by the ld ACIT, Central Circle 20, New Delhi (ld AO) for AY 2013-14 against the order of the ld CIT(A)-27, New Delhi dated 19.09.2017 raising the solitary ground of against deletion of disallowance u/s 14A of the Act as under:- “1. That the ld CIT(A) erred in law and on facts in deleting the addition of Rs. 24368923/- made on account of disallowance of expenses u/s 14A without appreciating the facts and circumstances of the case that the assessee is not able to bifurcate the expenses incurred on exempt income and taxable income. Also assessee is not maintaining separate a/c for exempt income and taxable income.”
More judgments on Section 14A
- Blacksoil Capital Private Limited (As… vs DCIT, Circle-1(1), HyderabadITA 2217/HYD/2026[2017-18]Status: Disposed9 Oct 2026AY 2017-18
- Hiral Construction, Mumbai vs ITO Ward 42(1)(2), MumbaiITA 8431/MUM/2025[2017-18]Status: Disposed8 Oct 2026AY 2017-18
- The Dy DIT (It) 1(2), Mumbai vs M/S Citi Bank N.A, MumbaiITA 4981/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S. Citi Bank N.A., Mumbai vs The Addl DIT (It) RG-1, MumbaiITA 4970/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S American Express Bank Ltd., Mumbai vs The Jt DIT (It)1(1), MumbaiITA 9414/MUM/2004[2000-2001]Status: Disposed8 Oct 2026AY 2000-2001
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