OUTSOURCEPARTNERS INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. DCIT CIRCLE- 19(1), DELHI

ITA 5975/DEL/2024Status: DisposedITAT Delhi16 January 2026AY 2018-19Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the computation method in Rule 8D was inapplicable as there was no direct interest or expense related to exempt income. The investments in mutual funds were either redeemed in the same month or yielded capital gains, making the disallowance unsustainable.

What were the facts?

The Revenue appealed against the deletion of disallowance under section 14A read with Rule 8D. The assessee argued that no expenditure was incurred for earning exempt income and that the growth plan of the mutual fund yielded capital gains, not exempt income.

What were the issues?

Whether the disallowance under Section 14A read with Rule 8D is sustainable when no exempt income was earned and the investments did not yield exempt income.

Which sections of the Income-tax Act were involved?

Section 14A,Section 143(3),Section 246A(1)(a)

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA & SHRI S. RIFAUR RAHMAN

For Appellant: Adv. Sh. Dhruv Seth, Adv, Ms. Konika Sharma, CA
For Respondent: Ms. Ankush Kalra, Sr. DR
Hearing: 08.01.2026Pronounced: 16.01.2026

PER SATBEER SINGH GODARA, JM These Revenue’s and assessee’s cross appeals ITA Nos.5808/Del/2024 and 5975/Del/2024 for assessment year 2018-19 arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/

The order continues below.

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