ACIT SPECIAL RANGE-1, NEW DELHI vs. AGRICULTURAL INSURANCE COMPANY OF INDIA LTD., NEW DELHI
What did the Tribunal hold?
The Tribunal held that since the factual matrix and legal propositions were identical to previous cases decided in favor of the assessee, the current appeal by the Revenue should be dismissed.
What were the facts?
The Revenue filed an appeal against the CIT(A)'s order concerning disallowance under Section 14A and interest on corpus fund. The Tribunal noted that identical issues for previous assessment years were decided in the assessee's favor.
What were the issues?
Whether disallowance under Section 14A and interest on corpus fund for the current assessment year should be decided in line with previous favorable rulings for the assessee.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI
Before: Sh. Saktijit DeyDr. B. R. R. Kumar
ORDER
Per Dr. B. R. R. Kumar, Accountant Member:
The present appeal has been filed by the Revenue against the order of ld. CIT(A)-32, New Delhi dated 22.11.2018.
At the outset, it was brought to our notice that the identical issue of disallowance u/s 14A and interest on corpus fund has been a subject matter of adjudication in assessee’s own case for A.Y. 2012-13 by the Tribunal vide order dated 06.11.2019 in and also in ITA No. 6647/Del/2016 for A.Y. 2008-09 vide order dated 05.04.2022. In the absence of any change in the factual matrix and legal proposition, the appeal of the revenue is hereby dismissed.
Agricultural Insurance Company of India Ltd. 3. In the result, the appeal of the Revenue is dismissed. Order Pronounced in the Open Court on 30/06/2023.
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