ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD.,, LUCKNOW

ITA 453/LKW/2020Status: DisposedITAT Lucknow02 April 2025AY 2016-1770 pages
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What did the Tribunal hold?

The Tribunal held that interest on borrowed funds invested in SPVs to earn exempt dividend income is disallowable under Section 14A. It also noted that the CIT(A) provided adequate opportunities of hearing to the assessee.

What were the facts?

The assessee claimed deduction under Section 80IA(4) on interest income and also claimed deletion of disallowance under Section 14A. The CIT(A) had allowed the deduction on interest income and deleted the disallowance under Section 14A.

What were the issues?

Whether interest income is eligible for deduction under Section 80IA(4) and whether expenditure incurred for earning exempt income is disallowable under Section 14A.

Which sections of the Income-tax Act were involved?

Section 80IA,Section 14A,Section 10(34),Section 143(2),Section 251

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Cases cited in this judgment(19)Show list

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Heard together (3 matters)

I.T.A. No.17/Lkw/2024
I.T.A. No.623/Lkw/2024
C.O.No.01/Lkw/2025

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IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH 'A', LUCKNOW BEFORE SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER AND SHRI SUBHASH MALGURIA, JUDICIAL MEMBER Assessment Years:2018-19 M/s APCO Infratech Pvt. Ltd., Vs. Dy./A.C.I.T.-1, B-9, Vibhuti Khand, (Central-1), Gomti Nagar, Lucknow Lucknow. PAN:AADCA5639H (Appellant) (Respondent) I.T.A. No.356 & 357/Lkw/2020

Assessment Years:2016-17 & 17-18 M/s APCO Infratech Pvt. Ltd., Vs. A.C.I.T.-1, B-9, Vibhuti Khand, (Central-1), Gomti Nagar, Lucknow Lucknow. PAN:AADCA5639H (Appellant) (Respondent) I.T.A. No.453 & 454/Lkw/2020

Assessment Years:2016-17 & 17-18 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, (Appellant) Lucknow. PAN:AADCA5639H (Respondent) Assessment Years:2018-19 A.C.I.T.-1, Vs. M/s APCO Infratech Pvt. Ltd., (Central-1), B-9, Vibhuti Khand, Lucknow Gomti Nagar, (Appellant) Lucknow. PAN:AADCA5639H (Respondent) C.O.No.01/Lkw/2025 ( in I.T.A. No.623/Lkw/2024

Assessment Years:2018-19 M/s APCO Infratech Pvt. Ltd., Vs. Dy./A.C.I.T.-1, B-9, Vibhuti Khand, (Central-1), Gomti Nagar, Lucknow Lucknow. PAN:AADCA5639H (Appellant) (Respo

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