UFLEX LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE- 2, NOIDA

ITA 5157/DEL/2025Status: DisposedITAT Delhi24 December 2025AY 2016-175 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A(2) read with Rule 8D(2)(iii) was illegal as the Assessing Officer failed to record the mandatory 'satisfaction'. Consequently, the addition made under Section 14A for normal provisions and the corresponding addition under Section 115JB were deleted.

What were the facts?

The assessee filed its income tax return, and the Assessing Officer made additions of Rs. 59,93,373/- and Rs. 1,39,11,673/-. The CIT(A) partly allowed the assessee's appeal. The assessee appealed further, primarily challenging disallowances under Section 14A.

What were the issues?

Whether disallowance under Section 14A can be made without recording the prerequisite satisfaction by the AO, and whether such disallowance can be added back for computing book profit under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 14A,Section 14A(2),Section 115JB

AI-generated summary — verify with the full judgment below

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

Before: SHRI VIMAL KUMAR & SMT. RENU JAUHRI

For Appellant: Shri Rohit Kapoor, Advocates
For Respondent: Ms. Ankush Kalra, SR. DR
Hearing: 18.12.2025Pronounced: 24.12.2025

PER VIMAL KUMAR, JUDICIAL MEMBER:

The appeal filed by the assessee is against order dated 12.08.2025 of Learned Commissioner of Income Tax-3, Noida (hereinafter referred to as “Ld. CIT(A)") arising out of assessment order dated 27.12.2018 of the Learned Assessing Officer/Learned Assistant Commissioner of Income Tax (hereinafter

2 referred to as "Ld. AO") under Section 143(3) of the Income Tax Act, 1961 ((hereinafter referred to as "the Act”)) Act for assessment year 2016-17. 2. Brief facts of the case are that the assessee filed Income Tax Return declaring total income of Rs.1,59,33,08,690/- under the normal provisions of the Act and book profit of Rs.2,25,92,70

The order continues below.

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