What is CCI Ltd. v. JCIT authority for?

Disallowance under Section 14A for exempt income is not warranted for notional expenditure where no actual expenditure is incurred. This principle extends to shares held as stock-in-trade if the primary purpose is not to earn dividend income.

How many judgments cite CCI Ltd. v. JCIT?

128 judgments on BharatTax cite CCI Ltd. v. JCIT (250 CTR 291), spanning 2008 to 2025.

Which sections of the Income Tax Act does CCI Ltd. v. JCIT come up under?

It is most often cited in judgments turning on Section 10(34), Section 143(3), Section 14A, Section 250.

CCI Ltd. v. JCIT (250 CTR 291)

DCIT 2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 4355/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Apr 2018AY 2011-12

Bench: Shri B.R. Baskaran & Shri Pawan Singhdcit-2(1)(1) M/S Bank Of Baroda Room No. 561, 5Th Floor, C-26, ‘G’ Block, Baroda Aayakar Bhavan, M.K. Road, Corporate Centre, Bandra Kurla Vs. Mumbai-400020 Complex, Bandra (E), Mumbai-400051 Pan: Aaacb1534F (Appellant) (Respondent) M/S Bank Of Baroda Dcit-2(1)(1) Room No. 561, 5Th Floor, C-26, ‘G’ Block, Baroda Corporate Centre, Bandra Kurla Aayakar Bhavan, M.K. Road, Vs. Mumbai-400020 Complex, Bandra (E), Mumbai-400051 Pan: Aaacb1534F (Appellant) (Respondent) Dcit-2(1)(1) M/S Bank Of Baroda Room No. 561, 5Th Floor, C-26, ‘G’ Block, Baroda Aayakar Bhavan, M.K. Road, Corporate Centre, Bandra Kurla Vs. Mumbai-400020 Complex, Bandra (E), Mumbai-400051 Pan: Aaacb1534F (Appellant) (Respondent) M/S Bank Of Baroda Dcit-2(1)(1) Vs. Room No. 561, 5Th Floor, C-26, ‘G’ Block, Baroda Corporate Centre, Bandra Kurla Aayakar Bhavan, M.K. Road

Section 253Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “I”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER DCIT-2(1)(1) M/s Bank of Baroda Room No. 561, 5th Floor, C-26, ‘G’ Block, Baroda Aayakar Bhavan, M.K. Road, Corporate Centre, Bandra Kurla Vs. Mumbai-400020 Complex, Bandra (E), Mumbai-400051 PAN: AAACB1534F (Appellant) (Respondent) M/s Bank of Baroda DCIT-2(1)(1) Room No. 561, 5th Floor, C-26, ‘G’ Block, Baroda Corporate Centre, Bandra Kurla Aayakar Bhavan, M.K. Road, Vs. Mumbai-400020 Complex, Bandra (E), Mumbai-400051 PAN: AAACB1534F (Appellant) (Respondent) DCIT-2(1)(1)…

DCIT, Circle, Patiala vs. M/S State Bank of Patiala, Patiala

In the result the appeal of the revenue is dismissed

ITA 1325/CHANDI/2017[2015-16]Status: DisposedITAT Chandigarh03 Apr 2018AY 2015-16

Bench: Ms. Diva Singh & Ms. Annapurna Guptaassessment Year: 2015-16

For Appellant: Shri C. NareshFor Respondent: Shri Ashish Abrol

Section 14A

…had also relied on the order of Id. CIT(Appeal) and Hon'ble ITAT, Chandigarh for the A.Y. 2010-11 wherein Hon'ble ITAT had deleted the disallowance made u/s 14A of the Act, relying upon the decision of Hon'ble Karnataka High Court in the case of CCI Vs. JCIT 250 CTR 291 (Kar) , wherein it was held that where securities are held as stock in trade, no disallowance u/s 14A can be made. 5.2 I have considered the assessment order and submissions made by the appellant. It is worthwhile to mention here that the issue involved in these grounds has been decided by Hon'ble ITAT, Chandigarh vide its consolidated order in a…

Rajasthan State Industrial Development & Investment Corp. Ltd., Jaipur vs. ACIT, Jaipur

In the result, both set of cross appeals for the respective assessment years are disposed off with above directions

ITA 380/JPR/2017[2013-14]Status: DisposedITAT Jaipur29 Mar 2018AY 2013-14

For Appellant: Shri P C ParwalFor Respondent: Shri Varindar Mehta (CIT) fu/kZkfjrh dh vksj ls@

Section 115JSection 14ASection 80I

…(ii) & (iii) fails, the disallowance under the said provision cannot be made as the said provision is rendered unworkable. For this, reliance is placed on following decisions: • PCIT Vs. State Bank Of Patiala (2017) 391 ITR 218 (P&H) • CCI Ltd. Vs DCIT (2012) 206 Taxmann 563 (Kar): • DCIT Vs. Gulshan Investment Company Ltd. (2013) 86 DTR 262 (Kol-Trib) In view of above, the disallowance of Rs.71,75,575/- made by AO under Rule 8D(2)(iii) is incorrect and against the provisions of the Act. 5.4 It was further submitted that this issue has been considered by the Hon’ble ITAT in assessee’s own case for AY 2011-12 vi…

Icici Securities Ltd, Mumbai vs. DCIT RG 4(1), Mumbai

In the result, the appeal for the AY 2010-11 is partly allowed

ITA 4269/MUM/2013[2009-10]Status: DisposedITAT Mumbai19 Mar 2018AY 2009-10

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2009-10 & Assessment Year: 2010-11 Icici Securities Ltd. Dy. Commissioner Of Icici Centre, H.T. Parekh Income Tax Range Vs. Marg, Churchgate, 4(1), Mumbai-400020. Mumbai. Pan No. Aaaci0996E (Appellant) (Respondent) Assessee By : Mr. Yogesh A. Thar, Ar Revenue By : Mr. M.C. Omi Ningshen, Dr

For Appellant: Mr. Yogesh A. Thar, ARFor Respondent: Mr. M.C. Omi Ningshen, DR

Section 143(3)Section 40Section 40a

…e of Rs.2,36,22,473/- made by the AO u/s 14A r.w. Rule 8D. 4.3 Before us, the Ld. counsel of the assessee submits that section 14A is not applicable to securities held as stock-in-trade. In this regard, reliance is placed by him on the decision in CCI v. JCIT(250 CTR 291) (Karn.), DCIT v. India Advantage Securities Ltd. (ITA No. 6711/Mum/2011) (Mum. Trib.) and affirmed by the Hon’ble Bombay High Court in the case of CIT v. India Advantage Securities Ltd. (ITA No. 1131 of 2013) and CIT v. Credit Suissee First Boston (ITA No. 2387 of 2013) (Bom.) Also it is submitted that if own funds are more than tax-free funds,…

ACIT - 19(3), Mumbai vs. Safe Enterprises, Mumbai

In the result, the appeal filed by the Revenue and the assessee are partly allowed

ITA 2700/MUM/2016[2012-13]Status: DisposedITAT Mumbai26 Feb 2018AY 2012-13

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan () Assessment Year: 2012-13 Asst. Commissioner Of M/S Safe Enterprises Income Tax-19(3), Vs. 19, B, Manek, 11, L.D. Room No. 206, 2Nd Floor, Ruparel Marg, Napean Matru Mandir, Tardeo, Sea Road, Mumbai-400007 Mumbai-400006 Pan No. Abhfs4029H Appellant Respondent Assessment Year: 2012-13 Safe Enterprise Asst. Commissioner Of C/O. Kalyaniwalla& Mistry, Vs. Income Tax-19(3), Army & Navy Building, 3Rd Room No. 206, 2Nd Floor, 148, M.G. Road, Fort, Floor, Matru Mandir, Mumbai-400001 Tardeo, Mumbai-400007 Pan No. Abhfs4029H Appellant Respondent

For Appellant: Mr. M.M. Golvala, ARFor Respondent: Mr. Ram Tiwari, DR

Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I” MUMBAI BEFORE SHRI MAHAVIR SINGH (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2012-13 Asst. Commissioner of M/s Safe Enterprises Income Tax-19(3), Vs. 19, B, Manek, 11, L.D. Room No. 206, 2nd floor, Ruparel Marg, Napean Matru Mandir, Tardeo, Sea Road, Mumbai-400007 Mumbai-400006 PAN No. ABHFS4029H Appellant Respondent Assessment Year: 2012-13 Safe Enterprise Asst. Commissioner of C/o. Kalyaniwalla& Mistry, Vs. Income Tax-19(3), Army & Navy Building, 3rd Room No. 206, 2nd floor, 148, M.G. Road, Fort, floor, Matru Mandir, Mumbai…