MAHABHADRA CONSTRUCTIONS LTD,GAUTAM BUDH NAGAR vs. DCIT, CIRCLE-13(2), DELHI

ITA 5902/DEL/2024Status: DisposedITAT Delhi08 January 2026AY 2014-15Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. S. Rifaur Rahman (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal noted that the assessee had earned exempt income in the nature of dividends. Both lower authorities failed to consider that under Section 14A and Rule 8D, only dividend-yielding investments should be considered for disallowance, as settled by precedents like PCIT Vs. Caraf Builders and Construction Pvt. Ltd. and ACIT Vs. Vireet Investment Pvt. Ltd.

What were the facts?

The assessee, M/s Mahabhadra Constructions Ltd., appealed against an order related to a disallowance under Section 14A read with Rule 8D for Assessment Year 2014-15. The disallowance amounted to Rs. 2,21,36,173/-.

What were the issues?

Whether the disallowance under Section 14A read with Rule 8D was computed correctly, considering only dividend-yielding investments.

Which sections of the Income-tax Act were involved?

Section 14A,Section 143(3)

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

Before: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Respondent: Ms. Ankush Kalra, Sr. DR
Hearing: 08.01.2026Pronounced: 08.01.2026

Per Satbeer Singh Godara, Judicial Member:

This assessee’s appeal for Assessment Year 2014-15, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2023–24/10552668445(1) dated 21.08.2023, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

It transpires during the course of hearing that the assessee/appellant herein is aggrieved against both the learned lower authorities’ action invoking section 14A r.w. Rule 8D disallowance amounting to Rs.2,21,36,173; in assessment

2 Mahabhadra Constructions Ltd. order dated

The order continues below.

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