ICRA LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10(1), CR BUILDING, IP ESTATE, DELHI

ITA 2720/DEL/2025Status: DisposedITAT Delhi28 January 2026AY 2013-14Bench: SHRI C.N. PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that disallowance under Section 14A read with Rule 8D should only consider dividend-yielding investments, reversing the CIT(A)'s order. The Tribunal also dismissed the Revenue's grounds concerning ESOP expenses, citing jurisdictional High Court decisions. Regarding the additional claims for medical reimbursement and leave travel allowance, the Tribunal upheld the CIT(A)'s decision to admit them, based on the Hon'ble Supreme Court's ruling in Goetze (India) Ltd. Furthermore, the Tribunal quashed the AO's rectification order under Section 154 as it was passed after the settlement of disputes under the DTVSV Scheme.

What were the facts?

The assessee filed appeals challenging the disallowance under Section 14A read with Rule 8D, and the Revenue appealed regarding ESOP expenses and additional claims. The assessee also argued that a settlement under the DTVSV Scheme should preclude further actions by the AO.

What were the issues?

Whether disallowance under Section 14A r.w.r. 8D is applicable without dividend income, validity of rectification orders post-DTVSV settlement, and admissibility of ESOP expenses.

Which sections of the Income-tax Act were involved?

Section 14A,Section 8D,Section 37(1),Section 154,Section 282A,Section 156,Section 234A,Section 234B,Section 234C,Section 115JB

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Income Tax Appellate Tribunal, DELHI BENCH, ‘B’: NEW DELHI

Before: SHRI C.N. PRASAD & SHRI M. BALAGANESH

Hearing: 03.12.2025Pronounced: 28.01.2026

PER C.N. PRASAD, JM, These appeals are filed by the assessee for the A.Y.2013- 14, 2017-18, 2018-19 and 2020-21 and appeal by the Revenue for the A.Y. 2013-14 against different orders of the Ld. CIT(A).

2.

First we take up appeal of the assessee for the A.Y.2013- 14 in ITA No.2720/Del/2025 and the only issue in the appeal of the assessee is in respect of disallowance u/s.14A of the Act r.w.r. 8D of the IT Rules.

3.

The Ld. Coun

The order continues below.

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