PATTON INTERNATIONAL LIMITED,KOLKATA vs. ACIT, CIRCLE 7(1), , KOLKATA

ITA 1045/KOL/2025Status: DisposedITAT Kolkata10 February 2026AY 2020-202111 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in not allowing the assessee an opportunity to be heard through VC and in not considering the request to defer the hearing. The Tribunal also found that the CIT(A) erred in affirming the addition made by the AO under Section 14A without proper consideration of the assessee's submissions regarding the disallowance calculation.

What were the facts?

The assessee company appealed against the CIT(A)'s order upholding the disallowance of expenses under Section 14A read with Rule 8D. The Assessing Officer disallowed ₹1,45,94,658 as expenditure incurred to earn exempt income, based on the company's investments.

What were the issues?

Whether the CIT(A) erred in denying an opportunity for virtual hearing and in affirming the disallowance under Section 14A without properly considering the assessee's submissions on the calculation methodology.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, KOLKATA ‘D BENCH, KOLKATA

Before: SHRI SONJOY SARMA & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

Both these appeals filed by the assessee are against the separate orders of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act') for AYs 2018-19 & 2020- 21 dated 05.05.2025 and 23.04.2025, respectively. Since the issues relate to the common assessee, therefore, they are being decided vide this common order for the sake of convenience and brevity.

2.

The assessee is in appeal before the Tribunal raising the following grounds of appeal: I. ITA No. 1044/KOL/2025; AY 2019-20: “1.

The order continues below.

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