What is ACIT v. Vireet Investment Pvt. Ltd. authority for?

No disallowance under section 14A can be made while computing book profits under section 115JB unless the expenditure is debited to the profit and loss account and satisfies clause (f) of Explanation 1 to section 115JB(2).

How many judgments cite ACIT v. Vireet Investment Pvt. Ltd.?

882 judgments on BharatTax cite ACIT v. Vireet Investment Pvt. Ltd. (165 ITD 27), spanning 2017 to 2026.

Which sections of the Income Tax Act does ACIT v. Vireet Investment Pvt. Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 115JB, Section 143(3), Section 1961, Section 8D, Section 37(1).

ACIT v. Vireet Investment Pvt. Ltd. (165 ITD 27)

Crisil Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1564/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…sidered for making disallowances are only on those investments which has actually earned the dividend. So far as disallowance of other administrative expenditure is considered, it is observed that Hon'ble Delhi ITAT in the case of Vireet Investment Pvt. Ltd. [165 ITD 27] has held as under: “Section 14A of the Income-tax Act, 1961 read with rule 8D of the Income-tax Rules, 1962 - Expenditure incurred in relation to exempt income not includible in total income - Assessment year 2008-09 - Whether only those investments are to be considered for computing average value of investment which yielded exempt income during…

Crisil Ltd, Mumbai vs. Addl CIT 8(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 7603/MUM/2012[2008-09]Status: DisposedITAT Mumbai10 Jan 2024AY 2008-09

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…sidered for making disallowances are only on those investments which has actually earned the dividend. So far as disallowance of other administrative expenditure is considered, it is observed that Hon'ble Delhi ITAT in the case of Vireet Investment Pvt. Ltd. [165 ITD 27] has held as under: “Section 14A of the Income-tax Act, 1961 read with rule 8D of the Income-tax Rules, 1962 - Expenditure incurred in relation to exempt income not includible in total income - Assessment year 2008-09 - Whether only those investments are to be considered for computing average value of investment which yielded exempt income during…

M/S. Prime Property Development Corporation Ltd, Mumbai vs. ACIT C 10 (3) (2), Mumbai

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

ITA 3291/MUM/2023[2016-17]Status: DisposedITAT Mumbai03 Jan 2024AY 2016-17

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 115JSection 14Section 14A

…t earned exempt income during this year. Accordingly, we set aside the order passed by the learned CIT(A) on this issue and direct the Assessing Officer to delete the disallowance made under section 14A of the Act. 6. In the case of Vireet Investments P Ltd (165 ITD 27), the Delhi Special bench has held that the disallowance made u/s 14A of the Act cannot be imported in sec.115JB of the Act. Hence the addition of Rs.15,38,295/- to the net profit for the purpose of computing book profit u/s 115JB of the Act should be deleted. Then the question that arises is whether any addition is called for under clause (f) of…

Reliance Power Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 15(3)(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 3042/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Dec 2023AY 2012-13

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Jitendra Sanghvi a/wFor Respondent: Smt. Somogyan Pal

Section 115JSection 14ASection 250

…assessee’s own case in DCIT v/s M/s Reliance Power Ltd., ITA No. 1952/Mum/2023, for the assessment year 2014-15, vide order dated 25/10/2023 following the decision of the Special Bench of the Tribunal in the case of ACIT vs. Vireet Investment (P) Ltd. (2017) 165 ITD 27 (Delhi-Trib.) directed the AO to compute the average value of investments by considering only those investments which yields exempt income and then compute the disallowance under Rule 8D of the Rules. The Co-ordinate Bench further directed that if own funds available with the assessee exceed the value of investments, then no disallowance of intere…

Reliance Power Limited, Mumbai vs. Deputy Commissioner of Income Tax .Circle 15(3)(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 3041/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Dec 2023AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Jitendra Sanghvi a/wFor Respondent: Smt. Somogyan Pal

Section 115JSection 14ASection 250

…assessee’s own case in DCIT v/s M/s Reliance Power Ltd., ITA No. 1952/Mum/2023, for the assessment year 2014-15, vide order dated 25/10/2023 following the decision of the Special Bench of the Tribunal in the case of ACIT vs. Vireet Investment (P) Ltd. (2017) 165 ITD 27 (Delhi-Trib.) directed the AO to compute the average value of investments by considering only those investments which yields exempt income and then compute the disallowance under Rule 8D of the Rules. The Co-ordinate Bench further directed that if own funds available with the assessee exceed the value of investments, then no disallowance of intere…

Asst CIT (Ltu) 1, Mumbai vs. Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1248/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Dec 2023AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar, ARFor Respondent: Ms. A. Alankrutha, Sr. DR

Section 10BSection 115JSection 14ASection 234BSection 271(1)(c)Section 32(1)(iia)Section 37Section 40Section 43BSection 80I

…been considered by the AO which is not correct since the investments in subsidiaries and investments not yielding dividend income are to be excluded. The ld. AR in this regard relied on the decisions in the case of ACIT Vs. Vireet Investments Pvt. Ltd. (2017) 165 ITD 27 (Del. Trib.(SB). The ld. AR further submitted that this issue has been considered by the decision of Co-ordinate Bench in assessee's own case for AY 20110-11 (ITA No. 4220 & ITA No. 4704/Mum/2015 dated 24.02.2020 6. The ld. DR on the other hand, relied on the order of the lower authorities. 7. We have heard the parties and perused the material on…

Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd), Mumbai vs. Addl CIT Ltu, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1065/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Dec 2023AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar, ARFor Respondent: Ms. A. Alankrutha, Sr. DR

Section 10BSection 115JSection 14ASection 234BSection 271(1)(c)Section 32(1)(iia)Section 37Section 40Section 43BSection 80I

…been considered by the AO which is not correct since the investments in subsidiaries and investments not yielding dividend income are to be excluded. The ld. AR in this regard relied on the decisions in the case of ACIT Vs. Vireet Investments Pvt. Ltd. (2017) 165 ITD 27 (Del. Trib.(SB). The ld. AR further submitted that this issue has been considered by the decision of Co-ordinate Bench in assessee's own case for AY 20110-11 (ITA No. 4220 & ITA No. 4704/Mum/2015 dated 24.02.2020 6. The ld. DR on the other hand, relied on the order of the lower authorities. 7. We have heard the parties and perused the material on…

ACIT, Ncc-8, Chennai vs. Saint Gobain India Pvt Ltd, Chennai

In the result, the appeal in ITA No

ITA 585/CHNY/2021[2011-12]Status: DisposedITAT Chennai20 Dec 2023AY 2011-12

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.581 & 585/Chny/2021 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. Saint-Gobain India Pvt. Ltd. Income Tax, Non Corporate Circle 8, [Formerly Known As M/S. Saint-Gobain Room No. 507, 5Th Floor, Annexe Glass India Ltd.], 18/3, Sigapi Achi Building, 7Th Floor, Rukmini Lakshmipathi Building, No. 121, M.G. Road, Chennai -600 034. Road, Egmore, Chennai 600 008. [Pan:Aabcs4338M] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Ar V Sreenivasan, Addl. Cit : ""थ" की ओर से/Respondent By Shri R. Vijayaragahavan, Advocate & : Shri Saroj Kumar Parida, Advocate सुनवाई की तारीख/ Date Of Hearing 11.12.2023 : घोषणा की तारीख /Date Of Pronouncement : 20.12.2023 आदेश /O R D E R Per V. Durga Rao: The Appeal In Ita No. 581/Chny/2021 Filed By The Revenue Is Directed Against The Assessment Order Passed Under Section 143(3) R.W.S. 92Ca Of The Income Tax Act, 1961 [“Act” In Short] Dated 28.02.2015 For The Assessment Year 2011-12 & The Other Appeal In Ita No. 585/Chny/2021 Is Directed Against The Order Of The Ld. Commissioner Of 2

Section 143(3)Section 40

…ments, the ld. CIT(A) has directed the Assessing Officer to recompute the disallowance. 5.2 We have heard the rival contentions. We have also perused the decision of Delhi Special Bench of the Tribunal in the case of ACIT v. Vireet Investment (P) Ltd. (2017) 165 ITD 27 (Delhi)(SB), wherein, it has been held that while computing the disallowance under section 14A of the Act read with Rule 8D(2)(ii)/(iii) of Income Tax Rules, 1962, only the investments which yielded exempt income during the year under consideration are to be included for the purpose of average value of investments. The ld. DR could not controvert…

ACIT, Ncc-8, Chennai vs. Saint Gobain India P Ltd, Chennai

In the result, the appeal in ITA No

ITA 581/CHNY/2021[2011-12]Status: DisposedITAT Chennai20 Dec 2023AY 2011-12

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.581 & 585/Chny/2021 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. Saint-Gobain India Pvt. Ltd. Income Tax, Non Corporate Circle 8, [Formerly Known As M/S. Saint-Gobain Room No. 507, 5Th Floor, Annexe Glass India Ltd.], 18/3, Sigapi Achi Building, 7Th Floor, Rukmini Lakshmipathi Building, No. 121, M.G. Road, Chennai -600 034. Road, Egmore, Chennai 600 008. [Pan:Aabcs4338M] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Ar V Sreenivasan, Addl. Cit : ""थ" की ओर से/Respondent By Shri R. Vijayaragahavan, Advocate & : Shri Saroj Kumar Parida, Advocate सुनवाई की तारीख/ Date Of Hearing 11.12.2023 : घोषणा की तारीख /Date Of Pronouncement : 20.12.2023 आदेश /O R D E R Per V. Durga Rao: The Appeal In Ita No. 581/Chny/2021 Filed By The Revenue Is Directed Against The Assessment Order Passed Under Section 143(3) R.W.S. 92Ca Of The Income Tax Act, 1961 [“Act” In Short] Dated 28.02.2015 For The Assessment Year 2011-12 & The Other Appeal In Ita No. 585/Chny/2021 Is Directed Against The Order Of The Ld. Commissioner Of 2

Section 143(3)Section 40

…ments, the ld. CIT(A) has directed the Assessing Officer to recompute the disallowance. 5.2 We have heard the rival contentions. We have also perused the decision of Delhi Special Bench of the Tribunal in the case of ACIT v. Vireet Investment (P) Ltd. (2017) 165 ITD 27 (Delhi)(SB), wherein, it has been held that while computing the disallowance under section 14A of the Act read with Rule 8D(2)(ii)/(iii) of Income Tax Rules, 1962, only the investments which yielded exempt income during the year under consideration are to be included for the purpose of average value of investments. The ld. DR could not controvert…

Atc Global Logistics Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle2(1)(1), Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 2595/MUM/2023[2016-17]Status: DisposedITAT Mumbai19 Dec 2023AY 2016-17

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Manoj Kumar Sinha, Sr. DR

Section 115JSection 14A

…a without prejudice submission that the assessee has paid tax on book profits on which the AO has made an addition towards disallowance under section 14A which is not correct in view of the decision in the case of ACIT Vs. Vireet Investments Pvt. Ltd. (2017) 165 ITD 27 (Del. 4 ATC Global Logistics Pvt. Ltd. Trib.(SB). The ld AR prayed that though the assessee did not raise the ground contending this, the alternate contention may be considered for adjudication. 7. The ld. DR on the other hand, submitted that the assessee is having substantial amount of investment in equity shares and mutual funds from which th…

Idfc First Bank Limited, Chennai vs. DCIT- Corp Circle 2(2), Chennai

The appeal stand partly allowed in terms of our above order

ITA 607/CHNY/2023[2017-18]Status: DisposedITAT Chennai18 Dec 2023AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.607/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) Idfc First Bank Limited Dcit., (Earlier Known As Idfc Bank Limited) Corporate Circle-2(2), बनाम/ Vs. Krm Tower, 7Th Floor, Chennai. No.1Harrinton Road, Chetpet, Chennai-600 031. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadci-6523-Q (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Niraj Sheth (Advocate)- Ld.Ar !"थ"कीओरसे/Respondent By : Shri J.Premanand (Cit)-Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12-12-2023 घोषणाकीतारीख /Date Of Pronouncement : 19-12-2023 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Niraj Sheth (Advocate)- Ld.ARFor Respondent: Shri J.Premanand (CIT)-Ld. Sr. DR

Section 115JSection 14A

…by the assessee, no further disallowance would be called for. 6. So far as the adjustment of this item u/s 115JB is concerned, we find that this issue is covered in assessee’s favor by the decision of Special Bench of Tribunal in Vireet Investments Pvt. Ltd. (165 ITD 27). Respectfully following the same, we direct Ld. AO not to make any such adjustment u/s 115JB. 7. The appeal stand partly allowed in terms of our above order. Order pronounced on 19th December,2023 (V. DURGA RAO) (MANOJ KUMAR AGGARWAL) "ाियक सद!/JUDICIAL MEMBER लेखासद! / ACCOUNTANT MEMBER चे5ई Chennai; िदनांक Dated :19-12-2023 DS आदेशकीTितिलिपअ%ेि…

Dy.CIT -5(2)(1), Mumbai vs. M/S. Kec International Ltd, Mumbai

In the result appeal filed by the assessee is partly allowed and appeal of the learned assessing officer is dismissed

ITA 1883/MUM/2022[2014-15]Status: DisposedITAT Mumbai04 Dec 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Dy. Commissioner Of Income Kec International Ltd. Tax 463, Rpg House, Circle 5(2)(1) Dr. Annie Besant Road, Vs. 5Th Floor, Aaykar Bhavan, Worli, Mumbai-400 030 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aacck5599H Dy. Commissioner Of Income Kec International Ltd. Tax 463, Rpg House, Circle 5(2)(1) Dr. Annie Besant Road, Vs. 5Th Floor, Aaykar Bhavan, Worli, Mumbai-400 030 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Assessee By : Shri Vijay Mehta, Ar Revenue By : Shri Akhtar Hussain Ansari, Dr Date Of Hearing: 07.09.2023 Date Of Pronouncement : 04.12.2023

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Akhtar Hussain Ansari, DR

Section 115JSection 143(3)Section 147(3)Section 14ASection 92BSection 92F

…d with rule 8D of the income tax rule in computing the book profit under section 115JB of the act. We find that this issue is squarely covered in favour of the assessee by the decision of special bench in case of ACIT versus vireet investments private limited 165 ITD 27. Even otherwise it is stated that assessee has not received any exempt income during the year and therefore there is no question of making any disallowance under section 14 A of the income tax act even in the normal computation of total income and therefore the same also cannot be imputed while computing the book profit under section 115JB of the…

Kec International Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result appeal filed by the assessee is partly allowed and appeal of the learned assessing officer is dismissed

ITA 1852/MUM/2022[2014-15]Status: DisposedITAT Mumbai04 Dec 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Dy. Commissioner Of Income Kec International Ltd. Tax 463, Rpg House, Circle 5(2)(1) Dr. Annie Besant Road, Vs. 5Th Floor, Aaykar Bhavan, Worli, Mumbai-400 030 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aacck5599H Dy. Commissioner Of Income Kec International Ltd. Tax 463, Rpg House, Circle 5(2)(1) Dr. Annie Besant Road, Vs. 5Th Floor, Aaykar Bhavan, Worli, Mumbai-400 030 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Assessee By : Shri Vijay Mehta, Ar Revenue By : Shri Akhtar Hussain Ansari, Dr Date Of Hearing: 07.09.2023 Date Of Pronouncement : 04.12.2023

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Akhtar Hussain Ansari, DR

Section 115JSection 143(3)Section 147(3)Section 14ASection 92BSection 92F

…d with rule 8D of the income tax rule in computing the book profit under section 115JB of the act. We find that this issue is squarely covered in favour of the assessee by the decision of special bench in case of ACIT versus vireet investments private limited 165 ITD 27. Even otherwise it is stated that assessee has not received any exempt income during the year and therefore there is no question of making any disallowance under section 14 A of the income tax act even in the normal computation of total income and therefore the same also cannot be imputed while computing the book profit under section 115JB of the…

DCIT- CC - 7(3), Mumbai vs. Acg Associated Capsules Pvt. Ltd., Mumbai

In the result, no question of law arises

ITA 3283/MUM/2018[2013-14]Status: DisposedITAT Mumbai04 Dec 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved/For Respondent: Shri Akhtar Hussain Ansari

Section 143(2)Section 143(3)Section 250Section 92C

…here the assessee has not earned any exempt income for the purpose of computing the disallowance u/s. 14A read with Rule 8D. For this, we place reliance on the decision of the Special Bench of ITAT Delhi in the case of ACIT vs. Vireet Investments Pvt. Ltd. 165 ITD 27 (Trib-Del). We, therefore, remand this issue back (A.Ys. 2012-13 & 2013-14) ACG Associated Capsules Pvt. Ltd. to the file of the ld. A.O. for recomputing the disallowance u/s. 14A read with Rule 8D to the extent of the investments made by the assessee which has resulted in earning of the exempt income. Hence, ground no. III raised by the assessee…

DCIT CC- 7(3), Mumbai vs. Acg Associated Capsules Pvt. Ltd., Mumbai

In the result, no question of law arises

ITA 3282/MUM/2018[2012-13]Status: DisposedITAT Mumbai04 Dec 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved/For Respondent: Shri Akhtar Hussain Ansari

Section 143(2)Section 143(3)Section 250Section 92C

…here the assessee has not earned any exempt income for the purpose of computing the disallowance u/s. 14A read with Rule 8D. For this, we place reliance on the decision of the Special Bench of ITAT Delhi in the case of ACIT vs. Vireet Investments Pvt. Ltd. 165 ITD 27 (Trib-Del). We, therefore, remand this issue back (A.Ys. 2012-13 & 2013-14) ACG Associated Capsules Pvt. Ltd. to the file of the ld. A.O. for recomputing the disallowance u/s. 14A read with Rule 8D to the extent of the investments made by the assessee which has resulted in earning of the exempt income. Hence, ground no. III raised by the assessee…

Acg Assocation Capsules P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, no question of law arises

ITA 2384/MUM/2018[2013-14]Status: DisposedITAT Mumbai04 Dec 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved/For Respondent: Shri Akhtar Hussain Ansari

Section 143(2)Section 143(3)Section 250Section 92C

…here the assessee has not earned any exempt income for the purpose of computing the disallowance u/s. 14A read with Rule 8D. For this, we place reliance on the decision of the Special Bench of ITAT Delhi in the case of ACIT vs. Vireet Investments Pvt. Ltd. 165 ITD 27 (Trib-Del). We, therefore, remand this issue back (A.Ys. 2012-13 & 2013-14) ACG Associated Capsules Pvt. Ltd. to the file of the ld. A.O. for recomputing the disallowance u/s. 14A read with Rule 8D to the extent of the investments made by the assessee which has resulted in earning of the exempt income. Hence, ground no. III raised by the assessee…

Acg Assocation Capsules P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, no question of law arises

ITA 2383/MUM/2018[2012-13]Status: DisposedITAT Mumbai04 Dec 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved/For Respondent: Shri Akhtar Hussain Ansari

Section 143(2)Section 143(3)Section 250Section 92C

…here the assessee has not earned any exempt income for the purpose of computing the disallowance u/s. 14A read with Rule 8D. For this, we place reliance on the decision of the Special Bench of ITAT Delhi in the case of ACIT vs. Vireet Investments Pvt. Ltd. 165 ITD 27 (Trib-Del). We, therefore, remand this issue back (A.Ys. 2012-13 & 2013-14) ACG Associated Capsules Pvt. Ltd. to the file of the ld. A.O. for recomputing the disallowance u/s. 14A read with Rule 8D to the extent of the investments made by the assessee which has resulted in earning of the exempt income. Hence, ground no. III raised by the assessee…

DCIT RG. - 6(3), Mumbai vs. M/S. Kansai Nerolac Paints Ltd., Mumbai

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

ITA 4607/MUM/2017[2011-12]Status: DisposedITAT Mumbai04 Dec 2023AY 2011-12

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 115Section 143(2)Section 145ASection 35DSection 36(1)(va)Section 40

…h regard to the disallowance made under Rule 8D(2)(iii) the ld AR submitted that the investments that have yielded exempt income alone can be considered. The ld AR placed reliance on the decision of Hon’ble ITAT Special Bench in Vireet Investments reported in 165 ITD 27. The ld AR also prayed that the investments in Growth Funds to be excluded while calculating the disallowance under rule 8D(2)(iii) and in this regard relied on the decision of the coordinate bench in the case of Manugraph Industries ITA No.4761/M/2013 (Ann.A)[2023] 151 taxmann.com 250 (Mumbai). Accordingly the ld AR submitted that the disallowanc…

M/S. Kansai Nerolac Paints Ltd., Mumbai vs. DCIT RG. - 6(3), Mumbai

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

ITA 4562/MUM/2017[2011-12]Status: DisposedITAT Mumbai04 Dec 2023AY 2011-12

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 115Section 143(2)Section 145ASection 35DSection 36(1)(va)Section 40

…h regard to the disallowance made under Rule 8D(2)(iii) the ld AR submitted that the investments that have yielded exempt income alone can be considered. The ld AR placed reliance on the decision of Hon’ble ITAT Special Bench in Vireet Investments reported in 165 ITD 27. The ld AR also prayed that the investments in Growth Funds to be excluded while calculating the disallowance under rule 8D(2)(iii) and in this regard relied on the decision of the coordinate bench in the case of Manugraph Industries ITA No.4761/M/2013 (Ann.A)[2023] 151 taxmann.com 250 (Mumbai). Accordingly the ld AR submitted that the disallowanc…

Kansai Nerolac Paints Ltd, Mumbai vs. DCIT RG 6(2), Mumbai

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

ITA 3642/MUM/2016[2010-11]Status: DisposedITAT Mumbai04 Dec 2023AY 2010-11

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 115Section 143(2)Section 145ASection 35DSection 36(1)(va)Section 40

…h regard to the disallowance made under Rule 8D(2)(iii) the ld AR submitted that the investments that have yielded exempt income alone can be considered. The ld AR placed reliance on the decision of Hon’ble ITAT Special Bench in Vireet Investments reported in 165 ITD 27. The ld AR also prayed that the investments in Growth Funds to be excluded while calculating the disallowance under rule 8D(2)(iii) and in this regard relied on the decision of the coordinate bench in the case of Manugraph Industries ITA No.4761/M/2013 (Ann.A)[2023] 151 taxmann.com 250 (Mumbai). Accordingly the ld AR submitted that the disallowanc…

ACIT v. Vireet Investment Pvt. Ltd.

What is ACIT v. Vireet Investment Pvt. Ltd. authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing ACIT v. Vireet Investment Pvt. Ltd.

Crisil Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

Crisil Ltd, Mumbai vs. Addl CIT 8(1), Mumbai

M/S. Prime Property Development Corporation Ltd, Mumbai vs. ACIT C 10 (3) (2), Mumbai

Reliance Power Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 15(3)(1), Mumbai

Reliance Power Limited, Mumbai vs. Deputy Commissioner of Income Tax .Circle 15(3)(1), Mumbai

Asst CIT (Ltu) 1, Mumbai vs. Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd, Mumbai

Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd), Mumbai vs. Addl CIT Ltu, Mumbai

ACIT, Ncc-8, Chennai vs. Saint Gobain India Pvt Ltd, Chennai

ACIT, Ncc-8, Chennai vs. Saint Gobain India P Ltd, Chennai

Atc Global Logistics Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle2(1)(1), Mumbai

Idfc First Bank Limited, Chennai vs. DCIT- Corp Circle 2(2), Chennai

Dy.CIT -5(2)(1), Mumbai vs. M/S. Kec International Ltd, Mumbai

Kec International Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

DCIT- CC - 7(3), Mumbai vs. Acg Associated Capsules Pvt. Ltd., Mumbai

DCIT CC- 7(3), Mumbai vs. Acg Associated Capsules Pvt. Ltd., Mumbai

Acg Assocation Capsules P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

Acg Assocation Capsules P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

DCIT RG. - 6(3), Mumbai vs. M/S. Kansai Nerolac Paints Ltd., Mumbai

M/S. Kansai Nerolac Paints Ltd., Mumbai vs. DCIT RG. - 6(3), Mumbai

Kansai Nerolac Paints Ltd, Mumbai vs. DCIT RG 6(2), Mumbai