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

35 judgments on BharatTax cite ACIT v. Vireet Investments Pvt. Ltd. (188 TTJ 1), spanning 2018 to 2026.

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

It is most often cited in judgments turning on Section 10(34), Section 14A, Section 115JB.

ACIT v. Vireet Investments Pvt. Ltd.

188 TTJ 1Income Tax Appellate Tribunal2017#3349 most cited

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

For the purpose of disallowing expenses under Section 14A, only investments that have yielded exempt income should be considered when calculating the average value of investments.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2026.

Also referred to as

ACIT v. Vireet Investments Pvt. Ltd. · Section 14A · Rule 8D · exempt income · dividend yielding investments · disallowance

Sections most often in play

Section 10(34)Section 14A Section 115JB

Issues it is cited on

section 10(34)disallowance u/s 14a disallowance under section 14a section 36(1)(iii)section 260 section 14a book profits arm's length price section 115j section 115jb transfer pricing adjustment section 92ca

Judgments citing ACIT v. Vireet Investments Pvt. Ltd.

VEEDOL CORPORATION LIMITED,KOLKATA vs. DCIT, CIRCLE 4(1), KOLKATA

The appeal of the assessee is partly allowed

ITA 1945/KOL/2025[2017-2018]Status: DisposedITAT Kolkata13 Jan 2026AY 2017-2018

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Circle 4(1) Veedol Corporation Limited Aaykar Bhawan Poorva, Yule House, 8, Dr. Rajendra 8Th Floor, P-7, Chowringhee Prasad Sarani, Kolkata-700001, Vs. Square, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabct1122C Assessee By : Shri Anup Sinha, Ar Revenue By : Shri Bonnie Debbarma, Dr Date Of Hearing: 29.10.2025 Date Of Pronouncement: 13.01.2026

For Appellant: Shri Anup Sinha, ARFor Respondent: Shri Bonnie Debbarma, DR

Section 10(34)Section 14A

…ase of the assessee is also covered by the decision of the Special Bench in the case of ACIT vs. Vireet Investment (P.) Ltd. [2017] 82 taxmann.com 415 (Delhi - Trib.) (SB)/[2017] 58 ITR(T) 313 (Delhi - Trib.) (SB)/[2017] 165 ITD 27 (Delhi - Trib.) (SB)/[2017] 188 TTJ 1 Veedol Corporation Limited; A.Y. 2017-18 (Delhi - Trib.) (SB)[16-06-2017]. Considering the ratio laid down in the above decisions, we are inclined to set aside the order of ld. CIT (A) and direct the AO to delete the addition. The ground no. 3 is allowed. 5. In the Result, the appeal of the assessee is partly allowed. Order pronounced in the open…

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…25130/2019 reported in 268 Taxman 317  ACB India Ltd. v. ACIT: 374 ITR 108 (Del.)  REI Agro Ltd v. DCIT: 144 ITD 141 (Kol. Trib.) – Revenue appeal dismissed by Calcutta HC in appeal No.GA No.3581 of 2013  ACIT v. Vireet Investments Pvt. Ltd.: 165 ITD 27 / 188 TTJ 1 (Del Trib.) (SB)  Religare Enterprises Ltd. v. DCIT: 1549/Del/2014 (Del Trib.)  11. It is submitted that if only the dividend yielding investments are considered for the purpose of section 14A of the Act, then the disallowance would not exceed Rs.2,09,65,159, being the suo-motu disallowance made by the assessee. 12. He further submitted that thes…

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

SAHARA ONE MEDIA & ENTERTAINMENT LTD.,GURGAON vs. DCIT, NEW DELHI

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

ITA 5320/DEL/2013[2009-10]Status: DisposedITAT Delhi26 Jun 2024AY 2009-10

Bench: Shri Shamim Yahya & Shri Sudhir Pareeksahara One Media & Entertainment Ltd., Vs. Dcit, (Formerly Known As Sahara India Mass Central Circle 6, Communication Limited), New Delhi. Cts 40-44, Sahara India Point, S.V. Road, Goregaon (W), Mumbai – 400 104. (Pan : Aaacp3047R) (Appellant) (Respondent) Assessee By : Shri Adhitya Vohra, Advocate Shri Arpit Goyal, Ca Revenue By : Shri Kanav Bali, Sr. Dr Date Of Hearing : 24.06.2024 Date Of Order : 26.06.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)-I, New Delhi Dated 11.07.2013 For The Assessment Year 2009-10. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “1. That The Ld. Cit (A) Has Erred In Law & On Facts & Circumstances Of The Case In Conformity The Disallowance Of Rs.9,82,452/- Under Section 14A In Respect Of Alleged Expenditure Incurred For Earning Of Income Exempt From Tax.

For Appellant: Shri Adhitya Vohra, AdvocateFor Respondent: Shri Kanav Bali, Sr. DR

Section 10Section 14A

…upon the orders of the authorities below. 13. Upon careful consideration, we find considerable cogency in the submissions of the ld. Counsel for the assessee. It was held by Special Bench of the ITAT in the case of ACIT vs. Vireet Investment (P) Ltd. (2017) 188 TTJ 1 that for the purpose of disallowance under clause (ii) and (iii) of Rule 8D, only those investments which yielded exempt income should be considered while calculating average value of investment. We order accordingly. AO is directed to compute disallowance under Rule 8D (iii) by 5 considering only investments which have earned exempt income. Needle…

SICOM LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1), MUMBAI

In the result, the appeal filed by the assesee is partly allow for statistical purpose and the appeal filed by the revenue is allowed for statistical purposes

ITA 1694/MUM/2023[2013-2014]Status: DisposedITAT Mumbai22 Nov 2023AY 2013-2014

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale, Judicialmember Sicom Ltd, Vs. Dy Commissioner Of Solitaire Corporate Income Tax Circle Park, Bldg No.04, 3(3)(1), Chakala, Andheri(E), 6Th Floor, Room No. Mumbai-400093. 609,Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent) Dy Commissioner Of Vs. Sicom Ltd, Income Tax Circle Solitaire Corporate Park, 3(3)(1), Bldg No.04, Chakala, 6Th Floor, Room No. Andheri(E), 609,Aayakar Bhavan, Mumbai-400093. Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent)

Section 10(34)Section 14ASection 234BSection 36(1)(ii)Section 36(1)(iii)

…llant wishes to place reliance on the decision of Hon'ble Tribunal in Appellant's own case for AY 2012-13 in. ITA 1998/M/2017 dated 14 November 2018 wherein the Hon'ble Tribunal, relying on the Special Bench ruling in case ACIT vs Vireet Industries Pvt. Ltd. (188 TTJ 1) has been held that computation of adjusted book profit, provisions of sub-section (2) and (3) of section 14A cannot be imported into clause (f) of the Explanation to section 115JA of the Act. 4. Similar view has also been taken by Courts/ Tribunal in following cases. Hon'ble Bombay High Court in case of, CIT vs. JSW Energy Ltd., [2015] 60 taxmann.…

M/S. BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

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

ITA 394/BANG/2023[2012-13]Status: DisposedITAT Bangalore29 Sept 2023AY 2012-13

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahuassessment Year : 2012-13 M/S. Bharat Electronics The Assistant Ltd., Commissioner Of Registered Office, Income Tax, Outer Ring Road Ltu, Nagawara, Circle – 1, Vs. Bangalore – 560 045. Bangalore. Pan: Aaacb5985C Appellant Respondent

For Appellant: Smt. Richa .B, CAFor Respondent: Shri Manoj Kumar, CIT-DR

Section 14ASection 43A

…IT (2019) 69 ITR 617 (Mum) (Trib.)  PTC India Ltd. v. DCIT (2019) 69 ITR 37(SN.) (Delhi) (Trib.)  ACIT v. Paras Buildtech (India) (P.) Ltd. (2018)62 ITR 284 (Delhi) (Trib.)  ACIT v. Vireet Investment Pvt. Ltd. (2017) 165 ITD 27 / 58 ITR 313 / 154 DTR 241 / 188 TTJ 1 (SB) (Delhi) (Trib.)  Dy.CIT v. Diamond Co. Ltd. (2017) 162 ITD 131 (Kol.) (Trib.)  Yashoda Health Care Services P. Ltd. v. DCIT (2017) 54 ITR 26 (Hyd.) (Trib.)  Electrosteel Castings Ltd. v. DCIT (2017) 53 ITR 5 (Kol.) (Trib.) 7. While calculating the disallowance under section 14A, only the investments that have generated exempt income should…

SAMCO SECURITIES LIMITED,MUMBAI vs. CIT (A) NFAC, DELHI

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

ITA 1328/MUM/2023[2016-17]Status: DisposedITAT Mumbai18 Jul 2023AY 2016-17

Bench: Shri Aby T Varkey & Shri Amarjit Singhsamco Securities Ltd. Vs. National Faceless Appeal A/1004, Naman Midtown, Centre (Nfac) Senapati Bapat Road, Prabhadevi Mumbai – 400013 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics2455A Appellant .. Respondent [ Appellant By : None Respondent By : Ram Krishna Kedia Date Of Hearing 06.07.2023 Date Of Pronouncement 18.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Nfac, Delhi, Dated 20.02.2023 For A.Y. 2016-17. The Assessee Has Raised The Following Grounds Before Us: “1. On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Confirming Disallowance U/S. 14A Of Rs. 1,51,214/- Made By The Ld Ao, Without Appreciating Facts, Submissions & Evidences In Proper Perspective & Without Assigning Any Proper Reasons 2. On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Passing Order Which Is Bad In Law & Violating The Principle Of Natural Justice As Ld Cit(A) Passed Order Without Giving Opportunity Of Virtual Online Hearing & Also Without Disposing Ground No. 3 Of Appeal Regarding "Assessment Order Contrary To The Principle Of Natural Justice".

For Appellant: NoneFor Respondent: Ram Krishna Kedia

Section 10(34)Section 143(3)Section 14A

…gistics Pvt. Ltd. v. Dy. CIT (2020) 83 ITR 46(SN) (Mum.)(Trib.) ACB India Ltd. Vs. ACIT, [2015] 62 taxmann.com 71 (Delhi) PTC India Ltd. v. DCIT (2019) 69 ITR 37(SN.) (Delhi) (Trib.) ACIT v. Vireet Investment Pvt. Ltd. (2017) 165 ITD 27/58 ITR 313/154 DTR 241/188 TTJ 1 (SB) (Delhi)(Trib.) Dy. CIT v. Diamond Co. Ltd. (2017) 162 ITD 131 (Kol.) (Trib.) Yashoda Health Care Services P. Ltd. v. DCIT (2017) 54 ITR 26 (Hyd.) (Trib.)” 6. We consider that the AO has not decided the alternative claim of the assessee. To compute the exempt income after taking into consideration the investment on which the exempt income earne…

JINDAL DRUGS PVT LTD,MUMBAI vs. CIRCLE, 3(2)(1), MUMBAI

In the result, the present appeal is partly allowed

ITA 2086/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 Feb 2023AY 2017-18

For Appellant: Sh. Vijay MehtaFor Respondent: Ms. Samruddhi Dhananjay Hande

Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 234DSection 40A(3)Section 68

…he Appellant during the relevant previous year. Further, he submitted that in view of the decision of the Special Bench of the Tribunal in the case of Assistant Commissioner of Income Tax - Circle 17(1), New Delhi vs. Vireet Investment Private Limited: [2017] 188 TTJ 1 (Delhi - Trib.) (SB), only income yielding exempt income are to be considered while computing disallowance in terms of Section 14A of the Act read with Rule 8D of the Rules. 8.3. Per contra, Ld. Departmental Representative relied upon the Draft Assessment Order and the directions issued by the DRP on this issue. The Learned Departmental Representa…

M/S. JK INVESTORS (BOMBAY ) LTD,MUMBAI vs. DCIT CENT. CIR-8(1), MUMBAI

In the result, the present appeal is allowed for statistical purposes

ITA 2115/MUM/2021[2011-12]Status: DisposedITAT Mumbai14 Dec 2022AY 2011-12

For Appellant: Shri Madhur AggarwalFor Respondent: Shri Achal Sharma

Section 143(3)Section 14ASection 153C

…011-12. In this regard, he relied upon the decision of Special Bench of the Tribunal in the case of Assistant Commissioner of Income Tax - 3 ITA. No. 2115/Mum/2021 Assessment Year: 2011-12 Circle 17(1), New Delhi vs. Vireet Investment Private Limited: [2017] 188 TTJ 1 (Delhi - Trib.) (SB). He also relied upon the judgment of the Hon‟ble Supreme Court in the case of CIT Vs. Shelly Products [2003] 261 ITR 367 in support of Ground No. 1 above. 8. Per contra, Ld. Departmental Representative submitted that the aforesaid submissions were not made by the Appellant before the Assessing Officer or the CIT(A). He further…

UNIFRAX INDIA LTD.,,MUMBAI vs. THE JT. CIT., RANGE-8,, AHMEDABAD

ITA 504/AHD/2014[2009-10]Status: DisposedITAT Mumbai14 Dec 2022AY 2009-10

Bench: The

For Appellant: Shri Shashank MehtaFor Respondent: Shri Nishant Somaiya

Section 115Section 115JSection 143(3)Section 14ASection 32

…of which exempt income was earned during the relevant previous year. He also relied upon the decision of Special Bench of the Tribunal in the case of Assistant Commissioner of Income Tax - Circle 17(1), New Delhi vs. Vireet Investment Private Limited: [2017] 188 TTJ 1 (Delhi - Trib.) (SB) and submitted that the amount of disallowance computed under Rule 8D of the Rules cannot be added back while computing Book Profits in terms of Section 115JB of the Act. 9. In response, the Ld. Departmental Representative relied upon the order passed by the Assessing Officer and the CIT(A) and submitted that the Assessing Offi…

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR

Section 143(1)Section 143(2)Section 14A

…TA.No.105 & 116/PAN./2018 Sociedade De Fomento Industrial Pvt. Ltd., Margao, Goa. 23. The ld. Counsel of the assessee has placed reliance on the judgement of the ITAT, Delhi Special Bench in the case of ACIT vs. Vireet Investment Pvt. Ltd., reported as (2017) 188 TTJ 1 (Del-Tribunal) (SB) and submitted that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. He vehemently pointed out that the AO has also included the amount of investment in shares of Sesa Goa Ltd. for computing the disallowance u/s 14A of the Act r.w. Rule 8D(iii) of t…

SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

ITA 105/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR

Section 143(1)Section 143(2)Section 14A

EDELWEISS COMMODITIES SERVICES LTD,MUMBAI vs. DCIT,CC-1(1), MUMBAI

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

ITA 7475/MUM/2017[2013-14]Status: DisposedITAT Mumbai24 Jun 2022AY 2013-14

Section 115JSection 143(3)Section 144CSection 14A

…iced that the AO has added the amount of disallowance computed as per Rule 8D r.w.s. 14A of the Act to the net profit while computing book profit u/s 115JB of the Act. The Delhi special bench of Tribunal has held in the case of Vireet Investments P Ltd (2017)(188 TTJ 1)(Delhi)(SB) has held that the disallowance computed u/s 14A cannot be adopted for the purpose of 10 Edelweiss Rural & Corporate Services Limited (Earlier known as M/s. Edelweiss Commodities Services Limited) clause (f) of Explanation 1 to sec. 115JB of the Act for computing book profit, meaning thereby, the AO has compute the disallowance under cla…

ACIT CIRCLE -7 (3)(1), MUMBAI vs. PANCARD CLUBS LTD., MUMBAI

ITA 2774/MUM/2018[2015-16]Status: DisposedITAT Mumbai29 Apr 2022AY 2015-16

Bench: Shri Kuldip Singh & Shri Om Prakash Kant

For Appellant: NoneFor Respondent: Shri Jasdeep Singh, D.R

Section 14A

…al are concerned, in view of the decision of ITAT, New Delhi, Special Bench in the case of ACIT Vs Vireet Investment (P.) Ltd [2017] 82 taxmann.com 415 (Delhi - Trib.) (SB)/[2017] 58 ITR(T) 313 (Delhi- Trib.) (SB)/[2017] 165 ITD 27 (Delhi - Trib.) (SB)/[2017] 188 TTJ 1 (Delhi –Trib.) (SB), the AO is directed to make disallowance u/s 14A only in respect of those investments from which exempt income has been earned during the year.” 7. We have perused the findings returned by the Ld. CIT(A) on the ground in question which is decided in accordance with the settled principle of law that only “exempt income yielding…

ACIT 7(3)(1), MUMBAI vs. PANCARD CLUBS LTD., MUMBAI

ITA 2773/MUM/2018[2010-11]Status: DisposedITAT Mumbai29 Apr 2022AY 2010-11

Bench: Shri Kuldip Singh & Shri Om Prakash Kant

For Appellant: NoneFor Respondent: Shri Jasdeep Singh, D.R

Section 14A

ASSTT. CIT (OSD) - CC -7 (3), MUMBAI vs. M/S. MACROTECH DEVELOPERS LTD. (EARLIER KNOWN AS M/S LODHA DEVELOPERS LTD.), MUMBAI

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

ITA 68/MUM/2019[2015-16]Status: DisposedITAT Mumbai25 Mar 2022AY 2015-16

Bench: S Shri Rifaur Rahamn & Pavan Kumar Gadaledcit – Cc-7(3) Vs. Macrotech Developers Room No. 655, 6Th Ltd (Successor To Floor, Aayakar Bhavan, Bellissimo Crown Mk Road, Mumbai – Buildmart Pvt Ltd) 400020. (Earlier Known As Lodha Crown Build Mart Ltd) 412, 17-G, Vardhaman Chambers, Cp Road, Horniman Circle Fort, Mumbai – 400001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacl1490J Appellant .. Respondent Macrotech Developers Vs. Dcit – Cc-7(3) Ltd (Successor To Room No. 655, 6Th Bellissimo Crown Floor, Aayakar Bhavan, Buildmart Pvt Ltd) Mk Road, Mumbai – (Earlier Known As 400020. Lodha Crown Build Mart Ltd) 412, 17-G, Vardhaman Chambers, Cp Road, Horniman Circle Fort, Mumbai – 400001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacl1490J Appellant .. Respondent

Section 143(2)Section 14ASection 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE S SHRI RIFAUR RAHAMN, ACCOUNTANT MEMBER & PAVAN KUMAR GADALE, JUDICIAL MEMBER DCIT – CC-7(3) Vs. Macrotech Developers Room No. 655, 6th Ltd (Successor to Floor, aayakar Bhavan, Bellissimo Crown MK Road, Mumbai – Buildmart Pvt Ltd) 400020. (Earlier known as Lodha Crown Build Mart Ltd) 412, 17-G, Vardhaman Chambers, CP Road, Horniman Circle Fort, Mumbai – 400001 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACL1490J Appellant .. Respondent Macrotech Developers Vs. DCIT – CC-7(3) Ltd (Successor to Room No. 655, 6th Bellissimo Crown Floor, aayakar Bhavan, Bu…

DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

ITA 7362/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Oct 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Pradeep Dinodia, C. A.; &For Respondent: Shri Surendra Pal [CIT] – DR

Section 133(6)Section 143Section 143(3)Section 144Section 92C

…is squarely covered in favour of the assessee by the decision of special bench in case of ACIT V Vireet Investments [P] Ltd [2017] 82 taxmann.com 415 (Delhi - Trib.) (SB)/[2017] 58 ITR(T) 313 (Delhi - Trib.) (SB)/[2017] 165 ITD 27 (Delhi - Trib.) (SB)/[2017] 188 TTJ 1 (Delhi - Trib.) (SB) where in Page 49 of 55 it has been held that the computation under clause (f) of Explanation 1 to section 115JB(2), is to be made without resorting to the computation as contemplated under section 14A, read with rule 8D of the Income-tax Rules, 1962. Therefore action of ld AO of imputing disallowance u/s 14 A of the act as add…

THRILL PARK LIMITED,MUMBAI vs. ITO , WARD 11(3)(1), MUMBAI

In the result, appeal is partly allowed

ITA 7157/MUM/2019[2016-17]Status: DisposedITAT Mumbai28 Sept 2021AY 2016-17

Section 10(35)Section 14Section 143(3)Section 14A

…l is allowed and the matter is remitted to work out the tax effect to the AO who shall do so after giving due notice to the party. " 2.3 The above view was reiterated by the Hon'ble Special Bench Delhi in the case of ACIT vs Vireet Investment Pvt Ltd [(2017) 188 TTJ 1(DeIhi)(SB)[ wherein Hon'ble Special Bench has held that the for the purposes of computing the disallowance as per Rule 8D only those investment shall be considered on which Appellant has actually earned the exempt income. Identical view was taken in the following judicial pronouncements: • Edelweiss Finance and Investment Limited vs Addl. CIT (ITA…

DCIT RG 5(3)(1), MUMBAI vs. RAPTAKOS BRETT AND CO. LTD, MUMBAI

In the result, assessee‟s appeal is partly allowed for statistical purposes and the revenue‟s appeal is dismissed

ITA 4052/MUM/2018[2014-15]Status: DisposedITAT Mumbai29 Oct 2020AY 2014-15

Bench: Shri Rajesh Kumar (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2014-15 M/S Raptakos Brett & Co. The Deputy Commissioner Of Limited, Income Tax- Range 5(3)(1), 253, Dr. Annie Besant Road, Mumbai - 400030 Worli, Vs. Mumbai - 400030 Pan: Aaacr1772R (Appellant) (Respondent) & Assessment Year: 2014-15 The Asst. Commissioner Of M/S Raptakos Brett & Company Income Tax – 5(3)(1), Limited, Room No. 519, 5Th Floor, Aayakar 21 A, Mittal Tower Free Press Bhavan, M.K. Road, Vs. Journal Marg, Nariman Point, Mumbai - 20 Mumbai - 400021 Pan: Aaacr1772R (Appellant) (Respondent) Assessee By : Shri Ronak Doshi (Ar) Revenue By : Shri Michael Jerald (Dr) Date Of Hearing: 04/08/2020 Date Of Pronouncement: 29/10/2020

For Appellant: Shri Ronak Doshi (AR)For Respondent: Shri Michael Jerald (DR)

Section 115JSection 143Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “D”, MUMBAI BEFORE SHRI RAJESH KUMAR (AM) AND SHRI RAM LAL NEGI (JM) Assessment Year: 2014-15 M/s Raptakos Brett & Co. The Deputy Commissioner of Limited, Income Tax- Range 5(3)(1), 253, Dr. Annie Besant Road, Mumbai - 400030 Worli, Vs. Mumbai - 400030 PAN: AAACR1772R (Appellant) (Respondent) & Assessment Year: 2014-15 The Asst. Commissioner of M/s Raptakos Brett & Company Income Tax – 5(3)(1), Limited, Room No. 519, 5th Floor, Aayakar 21 a, Mittal Tower Free Press Bhavan, M.K. Road, Vs. Journal Marg, Nariman Point, Mumbai - 20 Mumbai - 400021 PAN: AAACR1772R (A…

IFCI LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed partly for statistical purposes

ITA 2982/DEL/2015[2010-11]Status: DisposedITAT Delhi08 Oct 2020AY 2010-11

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 115JSection 143(3)Section 14A

…e decision of the special bench of the ITAT in the Asst Commissioner of Income Tax Versus Vireet investments private limited [2017] 82 taxmann.com 415 (Delhi - Trib.) (SB)/[2017] 58 ITR(T) 313 (Delhi - Trib.) (SB)/[2017] 165 ITD 27 (Delhi - Trib.) (SB)/[2017] 188 TTJ 1 (Delhi - Trib.) (SB) wherein it has been held that holding that the computation under clause (f) of Explanation 1 to section 115JB(2). is to be made without resorting to the computation as contemplated u/s 14A read with Rule 8D of the Income-tax Rules, 1962.. Accordingly we restore this ground of appeal back to the file of the learned Assessing Off…

Showing 1–20 of 35 · Page 1 of 2