366 ITR 505 (Bom), CIT v. Reliance Utilities and Power

239 ITR 735High Court#8333 most cited

What is 366 ITR 505 (Bom), CIT v. Reliance Utilities and Power authority for?

Investments made by an assessee are presumed to be out of interest-free funds, and no disallowance under Section 14A is warranted if no dividend income is received from such strategic investments.

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2022 to 2022.

Also referred to as

CIT v. Reliance Utilities and Power · Section 14A · interest-free funds · disallowance · dividend income · strategic investments · Rule 8D(2)(iii) · investment income

Judgments citing 366 ITR 505 (Bom), CIT v. Reliance Utilities and Power

ACIT, Madurai vs. J.K.Fenner (India) Limited, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 967/CHNY/2017[2013-14]Status: DisposedITAT Chennai21 Jan 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. ACIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 947/CHNY/2017[2013-14]Status: DisposedITAT Chennai21 Jan 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

ACIT Corporate Circle 1, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1883/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Jan 2022AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Madurai vs. ACIT Corporate Circle 1, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1846/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Jan 2022AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1272/CHNY/2016[2012-13]Status: DisposedITAT Chennai21 Jan 2022AY 2012-13

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1078/CHNY/2016[2010-11]Status: DisposedITAT Chennai21 Jan 2022AY 2010-11

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1077/CHNY/2016[2009-10]Status: DisposedITAT Chennai21 Jan 2022AY 2009-10

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1076/CHNY/2016[2008-09]Status: DisposedITAT Chennai21 Jan 2022AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1063/CHNY/2016[2012-13]Status: DisposedITAT Chennai21 Jan 2022AY 2012-13

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1062/CHNY/2016[2011-12]Status: DisposedITAT Chennai21 Jan 2022AY 2011-12

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1061/CHNY/2016[2010-11]Status: DisposedITAT Chennai21 Jan 2022AY 2010-11

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1060/CHNY/2016[2009-10]Status: DisposedITAT Chennai21 Jan 2022AY 2009-10

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1059/CHNY/2016[2008-09]Status: DisposedITAT Chennai21 Jan 2022AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…tments made by the assessee would be out of interest-free funds available with the assessee and no disallowance was warranted u/s 14A-CIT v. HDFC Bank Ltd. [2014] 366 ITR 505 (Bom), CIT V. Reliance Utilities and Power 313 ITR 340 (Bom) and CIT v. Hotel Savera 239 ITR 735 (Mad). 2.9 The Commissioner of Income Tax (Appeals) ought to have appreciated that the investment in M/s Modern Cotton Yarn Sinners Ltd. and M/s Southern Spinners and processors Ltd represent strategic investments. Further, no dividend was received from these investments, making it clear that these investments should not be taken into considerati…

366 ITR 505 (Bom), CIT v. Reliance Utilities and Power (239 ITR 735) — Cited in 13 Judgments | BharatTax