LIFESTYLE AND MEDIA HOLDING LTD,NEW DELHI vs. DCIT, CIRCLE-18(1), NEW DELHI

ITA 64/DEL/2019Status: DisposedITAT Delhi31 December 2025AY 2014-159 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee's activity of holding investments in subsidiary companies, as per its main object, constitutes business activity. Therefore, the claimed business expenses are allowable, and the set-off of business loss against other income is also permissible.

What were the facts?

The assessee, a holding company, claimed business expenses which were disallowed by the Assessing Officer (AO) and confirmed by the CIT(A) on the grounds that holding investments does not constitute business. The assessee argued that its main object was to act as a holding company for other group entities involved in content production and aggregation.

What were the issues?

Whether the activity of a holding company in making investments in its subsidiaries qualifies as 'business' for the purpose of allowing expenses and set-off of losses? Whether expenses incurred by a holding company for its operations and statutory compliance are deductible?

Which sections of the Income-tax Act were involved?

Section 143(3),Section 2(13),Section 37(1),Section 71,Section 36(1)(iii),Section 80M

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Cases cited in this judgment(6)Show list

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

Before: SHRI SUDHIR KUMAR & SHRI MANISH AGARWAL

For Appellant: Ms. Ankush Kalra, Sr. DR
For Respondent: Ms. Ankush Kalra, Sr. DR
Hearing: 29/10/2025Pronounced: 31/12/2025

[ PER BENCH: All the captioned appeals filed by the assessee against the separate orders passed by Learned Commissioner of Income Tax (Appeals)-6, Delhi [ld. CIT(A)] for AY 2014-15 to 1016017 and having common issues, therefore, they are dispose- off by a common order. First, we taken assessee appeal for Ay 2014-15 in ITA No. 64/Del/2019. ITA No.3714/Del/2024 & ITA No.64/Del/2019 for Assessment Year 2014-15

2.

This appeal is filed by the assessee against the order passed by Learned Commissioner of Income Tax (Appeals)-6,

The order continues below.

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