ACB India Ltd. v. ACIT

374 ITR 108High Court2015#197 most cited

What is ACB India Ltd. v. ACIT authority for?

When computing disallowance under Section 14A of the Income-tax Act using Rule 8D of the Income-tax Rules, only investments that have actually yielded exempt income during the relevant previous year are to be considered for the calculation.

364

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

ACB India Ltd v ACIT · Section 14A · Rule 8D · disallowance under Section 14A · expenditure for exempt income · investments yielding exempt income · computation of disallowance · Delhi High Court 374 ITR 108 · non-yielding investments · average investments Rule 8D

Also reported as

62 Taxmann.com 71235 Taxmann 22

Sections most often in play

Section 14ASection 143(3)Section 153ASection 1961Section 80ICSection 153DSection 132(1)Section 56(2)(x)

Issues it is cited on

section 153a proceedingsstrategic investmentsection 14a(2)section 80icdisallowance under section 14asection 115jb(2)section 56(2)(x)valuation of sharesdisallowance u/s 14asection 139(5)disallowance of interest expendituresection 92b

Judgments citing ACB India Ltd. v. ACIT

THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED,MUMBAI vs. INCOME TAX CENTRAL CIRCLE 2(1)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is hereby allowed for statistical\npurposes

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm\Nand\Nms. Kavitha Rajagopal, Am\N\Nita No.5274/Mum/2025\N(Assessment Year: 2018-19)\Nm/S. The Bombay Dyeing And\Nmanufacturing Company Limited,\Nneville House, Jn Heredia Marg,\Nballard Estate,\Nmumbai - 400 001\Npan: Aaact2328K\Nvs.\Nnational Faceless Appeal Centre,\Ndelhi (Deputy Commissioner Of\Nincome Tax, Central Circle-2(1)(1),\Nmumbai - 400001\N(Appellant)\N(Respondent)\Nassessee By\N:\Nshri Yogesh Thar, A.R.\Nms. Sukanya Jairam, A.R &\Nshri Saurabh Surana, A.R.\Nrespondent By\N:\Nshri Leyaqat Ali Aafaqui, Sr. Ar\Ndate Of Hearing\N:\N22.12.2025\Ndate Of Pronouncement\N:\N18.03.2025\Norder\Nper Kavitha Rajagopal, J M:\Nthis Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned\Ncommissioner Of Income Tax (Appeals) [‘Ld. Cit(A)' For Short], National Faceless\Nappeal Centre (‘Nfac' For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'),\Npertaining To The Assessment Year (‘A.Y.' For Short) 2018-19.\N2.\Nthe Assessee Has Raised The Following Grounds Of Appeal:\N“1. Ground No. 1: Disallowance Of Rs. 4,65,28,171/- Under Section 14A Of The\Nact:\N1.

Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI\nBEFORE SHRI OM PRAKASH KANT, JM\nAND\nMS. KAVITHA RAJAGOPAL, AM\n\nITA No.5274/Mum/2025\n(Assessment Year: 2018-19)\nM/s. The Bombay Dyeing and\nManufacturing Company Limited,\nNeville House, JN Heredia Marg,\nBallard Estate,\nMumbai - 400 001\nPAN: AAACT2328K\nVs.\nNational Faceless Appeal Centre,\nDelhi (Deputy Commissioner of\nIncome Tax, Central Circle-2(1)(1),\nMumbai - 400001\n(Appellant)\n(Respondent)\nAssessee by\n:\nShri Yogesh Thar, A.R.\nMs. Sukanya Jairam, A.R &\nShri Saurabh Surana, A.R.\nRespondent by\n:\nShri Leyaqat Ali Aaf…

DCIT, CIRCLE- 25(1), NEW DELHI vs. TELECOM CONSULT INDIA LTD., NEW DELHI

Appeal is dismissed

ITA 28/DEL/2020[2016-17]Status: DisposedITAT Delhi12 Feb 2026AY 2016-17

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER Assessment Year: 2016-17 DCIT, Vs. Telecom Consult India Ltd., Circle-25(1), TCIL, Bhawan, GK-1, New Delhi New Delhi PAN: AAACT0061H (Appellant) (Respondent) Assessee by Sh. Rahul Yadav, Adv. Department by Ms. Harpreet Kaur Hansra, Sr. DR Date of hearing 12.02.2026 Date of pronouncement 12.02.2026 ORDER PER SATBEER SINGH GODARA, JM This Revenue’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)-36 [in short, the “CI…

DOUBLEDOT FINANCE LTD ,MUMBAI vs. ITO WARD 4(1)(4), MUMBAI

In the result, the appeal filed by the assessee stands allowed

ITA 5514/MUM/2025[2014-15]Status: DisposedITAT Mumbai02 Feb 2026AY 2014-15

Bench: Shri Sandeep Gosaindoubledot Finance Ltd Vs. Income Tax Officer- 1St Floor, Kohinoor City 4(1)(4) Mall, Premier Road, Aayakar Bhavan, Mk Kurla (W), Mumbai Road Mumbai. Pan/Gir No:Aqepd9599B (Appellant) (Respondent)

Section 143(3)Section 14ASection 250Section 37

…On this preposition reliance has been placed upon the decision in the case of a. ACIT v. Vireet Investment Pvt. Ltd. [58 ITR (T) 313 (Del SB)] b. Kotak Mahindra Bank Ltd. v. Assessment Unit, Income Tax Department [211 ITD 608 (Mum)] c. ACB India Ltd. v. ACIT [374 ITR 108 (Del)] d. Cargo Motors Pvt. Ltd. v. DCIT [453 ITR 554 (Del)] e. Reliance Power Ltd. v. DCIT [159 taxmann.com 1626 (Mum)] 3 Doubledot Finance Ltd., Mumbai. 6. More particularly under the facts of the present case in para 7.4, the Ld. CIT(A) itself accepted that the disallowance u/s 14A of the Act should be restricted only while investments from…

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 6083/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Jan 2026AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

For Respondent: Mr. Paresh Sondagar, CA
Section 11SSection 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP SINGH KARHAIL (JUDICIAL MEMBER) Assessment Year: 2020-21 ACIT K Raheja Corp Pvt. Ltd., Kautilya Bhavan, BKC Plot No. C-30, Block-G, Raheja Vs. Mumbai-400051. Tower, Bandra, Mumbai-400051. PAN NO. AAACP 0522 B Appellant Respondent : Mr. Paresh Sondagar, CA Assessee by Revenue by : Mr. Hemanshu Joshi, Sr. DR : 25/11/2025 Date of Hearing Date of pronouncement : 22/01/2026 ORDER PER OM PRAKASH KANT, AM This appeal by the Revenue is directed against order dated 25.07.2025 passed by the Ld…

MACWEAR, MUMBAI vs. DCIT, CIRCLE 22(1), MUMBAI, MUMBAI

In the result, Assessee’s appeal is allowed for statistical purposes

ITA 6189/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2017-18 Macwear, Dcit, Circle 22(1), Macwear House, First Floor, Room No.322, 3Rd Floor, Vs. Sunmill Compound, Delisle Piramal Chamber, Lal Baug, Road, Mumbai – 400013. Parel, Pan – Aaafm1927E Mumbai - 400012 (Appellant) (Respondent) Present For: Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Virabhadra Mahajan, (Sr. D.R.) Date Of Hearing : 21.01.2026 Date Of Pronouncement : 21.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 05.08.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2017-18. 2. In The Instant Case, The Ao Vide Assessment Order Dated 13.11.2019 Under Section 143(3) Of The Act, Has Made An Addition Of Rs.13,01,267/- Being 1% Of The Average Investments Of Rs.13,01,26,690/-, Mainly On The Reason That The Assessee Has Failed To Provide Calculation/Submissions & Also, In The Computation Of Total Income, Has Not Disallowed Any Expenditure Attributable To The Earning Of Exempt Income As Required Under The 2 Macwear Provision Of Section 14A Of The Act. The Ld. Commissioner, On The Aforesaid Reasons, Dismissed The Appeal Of The Assessee, Affirming The Addition Made By The Ao. Thus, The Assessee Has Preferred The Instant Appeal.

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 14ASection 250

…Further, to restrict the disallowance under Section 14A of the Act, qua only investments, which actually 3 Macwear yielded the exempt income, but not otherwise, specifically in view of the decision of Hon’ble Delhi High Court in ACB India Ltd. vs. CIT (2015) 374 ITR 108 (Del) and Special Bench of the ITAT, in the case of ACIT Vs. M/s. Vireet Investment (P.) Ltd., (2017) 82 taxmann.com 415 (Delhi – Trib.) (SB) wherein also it has been held that the average value of investments, for the purposes of Rule 8D(2)(iii), should be confined to those securities in respect of which exempt income is earned. 5. In the resul…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, JHANDEWLAN EXTN. vs. LOTUS HERBALS PRIVATE LIMITED , DELHI

Appeal is dismissed

ITA 5143/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5143/Del/2025 : Asstt. Year : 2017-18 Dcit, Vs Lotus Herbals Pvt. Ltd., Central Circle-20, No. 2, Forest Lane, Near New Delhi-110055 Ghitorni Metro Station, South West Delhi, Delhi-110030 (Appellant) (Respondent) Pan No. Aaacl0198F Assessee By : Sh. Rohit Jain, Adv. & Ms. Deepashree Rao, Adv. Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2025–26/1076443794(1) Dated 22.05.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rohit Jain, Adv. &For Respondent: Ms. Amish S. Gupt, CIT-DR
Section 147Section 14A

…n the CIT(A)’s detailed discussion. Suffice to say, the earlier learned co-ordinate bench has already settled the same in light 3 Lotus Herbals Pvt. Ltd. of ACIT Vs. Vineet Investments Pvt. Ltd. (2019) 165 ITD 27 (Del. (SB) and ACB India Ltd. Vs. ACIT (2012) 347 ITR 108 (Del.) that only the dividend yielding investments ought to be taken into consideration whilst computing the impugned disallowance. This is what the learned CIT(A) has precisely done in the lower appellate discussion under challenge. We thus find no merit in the Revenue’s instant latter substantive ground as well. 6. This Revenue’s appeal is dis…

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…t investment which yielded exempt income should be considered for making computation of the addition in terms of Rule 8D of the IT Rule, 1962 by placing reliance on the judgment of Hon’ble Delhi High Court in the case of ACB India Limited vs. ACIT reported in 347 ITR 108 (Delhi). It is also a matter of fact that assessee has not challenged such findings of ld. CIT(A) before us. DCIT vs. Lotus Hearbals Pvt. Ltd. 33. Since the assessee is having exempt income and have the investments from which exempt income was not earned besides having investments which yielded exempt income. It is also not in dispute that the p…

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…t investment which yielded exempt income should be considered for making computation of the addition in terms of Rule 8D of the IT Rule, 1962 by placing reliance on the judgment of Hon’ble Delhi High Court in the case of ACB India Limited vs. ACIT reported in 347 ITR 108 (Delhi). It is also a matter of fact that assessee has not challenged such findings of ld. CIT(A) before us. DCIT vs. Lotus Hearbals Pvt. Ltd. 33. Since the assessee is having exempt income and have the investments from which exempt income was not earned besides having investments which yielded exempt income. It is also not in dispute that the p…

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…t investment which yielded exempt income should be considered for making computation of the addition in terms of Rule 8D of the IT Rule, 1962 by placing reliance on the judgment of Hon’ble Delhi High Court in the case of ACB India Limited vs. ACIT reported in 347 ITR 108 (Delhi). It is also a matter of fact that assessee has not challenged such findings of ld. CIT(A) before us. DCIT vs. Lotus Hearbals Pvt. Ltd. 33. Since the assessee is having exempt income and have the investments from which exempt income was not earned besides having investments which yielded exempt income. It is also not in dispute that the p…

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…t investment which yielded exempt income should be considered for making computation of the addition in terms of Rule 8D of the IT Rule, 1962 by placing reliance on the judgment of Hon’ble Delhi High Court in the case of ACB India Limited vs. ACIT reported in 347 ITR 108 (Delhi). It is also a matter of fact that assessee has not challenged such findings of ld. CIT(A) before us. DCIT vs. Lotus Hearbals Pvt. Ltd. 33. Since the assessee is having exempt income and have the investments from which exempt income was not earned besides having investments which yielded exempt income. It is also not in dispute that the p…

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

…t investment which yielded exempt income should be considered for making computation of the addition in terms of Rule 8D of the IT Rule, 1962 by placing reliance on the judgment of Hon’ble Delhi High Court in the case of ACB India Limited vs. ACIT reported in 347 ITR 108 (Delhi). It is also a matter of fact that assessee has not challenged such findings of ld. CIT(A) before us. DCIT vs. Lotus Hearbals Pvt. Ltd. 33. Since the assessee is having exempt income and have the investments from which exempt income was not earned besides having investments which yielded exempt income. It is also not in dispute that the p…

R. M. COMMERCIAL PVT. LTD., (EARLIER KNOWN AS CITRINE MERCHANTS PRIVATE LIMITED),KOLKATA vs. DCIT, CIRCLE 5(1),, KOLKATA

In the result, the appeal filed by the assessee is allowed

ITA 2114/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Dec 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 R. M Commercial Pvt. Ltd (Citrine Merchants Pvt. Ltd.).……..………………….……….……….……Appellant 113, Netaji Subhash Road, 2Nd Floor, Dalhousie, Kolkata - 1. [Pan: Aabcc3113A] Vs. Dcit, Circle-5(1), Kolkata………….…………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Adv., Appeared On Behalf Of The Appellant. Shri S B Chakraborthy, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 19, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.09.2025 Of The Addl/Jcit(A), Panaji [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. Brief Facts Of The Case Are That The Assessee Is A Domestic Company & Had Filed Its E-Return For Ay 2017-18 On 26-10-2017 Declaring A Total Income Of Rs.2,68,77,750/-. The Case Was Selected For Complete Scrutiny Assessment Under Cass & Notices Were Issued U/S 143(2) & 142(1) Of The Act, Against Which The Assessee Filed All The Details Along With Books Of Accounts. The Assessing Officer Completed The Assessment Of The Assessee U/S 143(3) Vide Order Dated 18-12-2019 On A Total Income Of Rs.2,79,27,779/- By Making An Addition Of Rs.10,50,029/- U/S 14A R.W.R 8D. R. M Commercial Pvt. Ltd 3. Being Aggrieved By The Said Order, The Assessee Filed An Appeal Before The Ld. Cit(A) & The Ld. Cit(A) Confirmed The Order Of The Assessing Officer.

Section 143(2)Section 143(3)Section 14ASection 250

…of law that the disallowance u/s 14A r.w r. Rule 8D(ii) is to be made only on those investments which has given rise to exempt income and entire investments cannot be taken into consideration. He relied on the following case laws: i. ACB India Ltd. vs. ACIT 374 ITR 108 (Delhi) ii. DCIT vs. GKK Capital Markets Ltd. ITA 805/Kol/2012 iii. ACIT vs. I.P Support Services India P Ltd. ITA no.283 of 2014 2 R. M Commercial Pvt. Ltd 5. Contrary to that, the ld. DR supports the impugned order. 6. Upon hearing the submissions of the counsels of the respective parties, we have perused the records. We find that the assessee…

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

…A of the Act, have erred in taking entire value of investments instead of investments related to tax-free income and thus not following the judgments of the various courts including jurisdictional Delhi High Court in the case of ACB India Ltd. vs. ACIT (2015) 374 ITR 108 (Delhi) and others. The ld. AO erred in taking the following incorrect opening & closing balances of value of viz. a) Rs. 245.50 Crores instead of correct amount of Rs. 8.91 Crores w.r.t. opening balance of investments; b) Rs. 255.07 Crores instead of correct amount of Rs. 4.12 Crores w.r.t. closing balance of investments. 67.0 Without prejudice…

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

…A of the Act, have erred in taking entire value of investments instead of investments related to tax-free income and thus not following the judgments of the various courts including jurisdictional Delhi High Court in the case of ACB India Ltd. vs. ACIT (2015) 374 ITR 108 (Delhi) and others. The ld. AO erred in taking the following incorrect opening & closing balances of value of viz. a) Rs. 245.50 Crores instead of correct amount of Rs. 8.91 Crores w.r.t. opening balance of investments; b) Rs. 255.07 Crores instead of correct amount of Rs. 4.12 Crores w.r.t. closing balance of investments. 67.0 Without prejudice…

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

…A of the Act, have erred in taking entire value of investments instead of investments related to tax-free income and thus not following the judgments of the various courts including jurisdictional Delhi High Court in the case of ACB India Ltd. vs. ACIT (2015) 374 ITR 108 (Delhi) and others. The ld. AO erred in taking the following incorrect opening & closing balances of value of viz. a) Rs. 245.50 Crores instead of correct amount of Rs. 8.91 Crores w.r.t. opening balance of investments; b) Rs. 255.07 Crores instead of correct amount of Rs. 4.12 Crores w.r.t. closing balance of investments. 67.0 Without prejudice…

DCIT, MUMBAI vs. HUBTOWN LIMITED , MUMBAI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 3038/MUM/2025[2018 19]Status: DisposedITAT Mumbai10 Dec 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Madhur Agarwal a/w Shri FenilFor Respondent: Shri Ritesh Misra, CIT DR
Section 132Section 132(4)Section 135Section 14ASection 153ASection 250Section 37(1)Section 69ASection 80G

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER I.T.A No.1601/Mum/2025 (Assessment Year: 2018-19) Hubtown Limited vs Assistant Commissioner of Hubtown Seasons, CTS No. Income-tax, Central Circle-2(4), 469A, Opp. Jain Temple, R.K. Mumbai Room No.802, 8th Floor, Pratishtha Chembur Marg, Chembur East, Mumbai-400 071 Bhavan, Old CGO Annexe, M.K. PAN : AAACA6101D Road, Mumbai-400 020 APPELLANT RESPONDENT I.T.A No.3038 /Mum/2025 (Assessment Year: 2018-19) Assistant Commissioner of vs Hubtown Limited Income-tax…

HUBTOWN LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), MUMBAI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 1601/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Dec 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Madhur Agarwal a/w Shri FenilFor Respondent: Shri Ritesh Misra, CIT DR
Section 132Section 132(4)Section 135Section 14ASection 153ASection 250Section 37(1)Section 69ASection 80G

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER I.T.A No.1601/Mum/2025 (Assessment Year: 2018-19) Hubtown Limited vs Assistant Commissioner of Hubtown Seasons, CTS No. Income-tax, Central Circle-2(4), 469A, Opp. Jain Temple, R.K. Mumbai Room No.802, 8th Floor, Pratishtha Chembur Marg, Chembur East, Mumbai-400 071 Bhavan, Old CGO Annexe, M.K. PAN : AAACA6101D Road, Mumbai-400 020 APPELLANT RESPONDENT I.T.A No.3038 /Mum/2025 (Assessment Year: 2018-19) Assistant Commissioner of vs Hubtown Limited Income-tax…

DCIT CIRCLE 1(1), NEW DELHI vs. ACME TELE POWER LTD. (NOW KNOWN AS ACME CLEANTECH SOLUTION LTD.), NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

…ncome needs to be considered and therefore, the action of the AO in considering the average value of gross value of investment is not correct. This view is supported by the judgement of Hon’ble Delhi High Court in the case of ACB India Ltd. reported in [2015] 374 ITR 108 (Delhi) and by the judgement of hon’ble Special Bench of the Delhi Tribunal in the case of ACIT, Circle-17(1), New Delhi vs Vireet Investment (P.) Ltd. reported in [2017] 82 taxmann.com 415 (Delhi-Trib.) (SB). 24. In view of the above facts and discussions and by respectfully following the judgement of Hon’ble Delhi High Court in the case of ACB…

M/S. ACME CLEANTECH SOLUTIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

…ncome needs to be considered and therefore, the action of the AO in considering the average value of gross value of investment is not correct. This view is supported by the judgement of Hon’ble Delhi High Court in the case of ACB India Ltd. reported in [2015] 374 ITR 108 (Delhi) and by the judgement of hon’ble Special Bench of the Delhi Tribunal in the case of ACIT, Circle-17(1), New Delhi vs Vireet Investment (P.) Ltd. reported in [2017] 82 taxmann.com 415 (Delhi-Trib.) (SB). 24. In view of the above facts and discussions and by respectfully following the judgement of Hon’ble Delhi High Court in the case of ACB…

M/S. ACME CLEANTECH SOLUTIONS LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

…ncome needs to be considered and therefore, the action of the AO in considering the average value of gross value of investment is not correct. This view is supported by the judgement of Hon’ble Delhi High Court in the case of ACB India Ltd. reported in [2015] 374 ITR 108 (Delhi) and by the judgement of hon’ble Special Bench of the Delhi Tribunal in the case of ACIT, Circle-17(1), New Delhi vs Vireet Investment (P.) Ltd. reported in [2017] 82 taxmann.com 415 (Delhi-Trib.) (SB). 24. In view of the above facts and discussions and by respectfully following the judgement of Hon’ble Delhi High Court in the case of ACB…

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