PRINCIPAL COMMISSIONER OF INCOME TAX-1 DELHI vs. BHILWARA ENERGY LTD

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ITA/366/2025HC DelhiDLHC01101136202319 January 20262 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted that the issue had been decided by its previous judgments, and the appellant's counsel could not dispute this. Therefore, the appeals were dismissed.

What were the facts?

The appeals concerned whether the disallowance under Section 14A of the Income Tax Act could exceed the dividend income received by the assessee. The respondents argued that this issue was already decided by previous judgments of the High Court.

What were the issues?

Whether the disallowance under Section 14A can exceed the amount of dividend received by the assessee.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

$~17, 19 & 20 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 366/2025 and CM APPL. 54343/2025, CM APPL. 54344/2025

PRINCIPAL COMMISSIONER OF INCOME TAX-1 DELHI

.....Appellant Through: Mr. Abhishek Maratha, SSC with Mr. Apoorv Agarwal, JSC.

versus

BHILWARA ENERGY LTD

.....Respondent Through: Mr. Satyen Sethi, Ms. Arta Trana Panda and Mr. Gargi Sethee, Advocates.

+ ITA 545/2025 and CM APPL. 66717/2025 PRINCIPAL CMMISSIONER OF INCOME TAX, CENTRAL-3, DELHI

.....Appellant Through: Mr. Abhishek Maratha, SSC with Mr. Apoorv Agarwal, JSC.

versus

M/S MALANA POWER COMPANY LTD .....Respondent Through: Mr. Satyen Sethi, Ms. Arta Trana Panda and Mr. Gargi Sethee, Advocates.

+ ITA 547/2025 and CM APPL. 66813/2025, CM APPL. 66814/2025

PCIT, CENTRAL-3

.....Appellant Through: Mr. Abhishek Maratha, SSC with Mr. Apoorv Agarwal, JSC.

versus

MALANA POWER COMPANY LTD.

.....Respondent Through: Mr. Satyen Sethi, Ms. Arta Trana This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/01/2026 at 13:36:46

Panda and Mr. Gargi Sethee, Advocates. CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

19.01.2026 1. Issue involve in the present appeals is as under:- “Whether disallowance under Section 14A can exceed the amount of dividend received by assessee?” 2. Mr. Satyen Sethi, learned Counsel appearing for the respondents, at the outset, submitted that the issue involved in the present appeals have already been decided by a number of judgments of this Court including Judgment rendered in the case of Principal Commissioner of Income-tax Central-1 versus R.J. Corp. Ltd. [2025] 181 taxmann.com749 (Delhi). 3. Mr. Agarwal, learned counsel for the appellants despite his attempts could not dispute the aforesaid position of facts and law. 4. Hence, the captioned appeals, with pending applications are dismissed.

DINESH MEHTA, J.

VINOD KUMAR, J. JANUARY 19, 2026/MR This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/01/2026 at 13:36:46

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