Cheminvest Ltd. v. CIT

378 ITR 33High Court2015#24 most cited

What is Cheminvest Ltd. v. CIT authority for?

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

1,569

judgments rely on this decision, according to BharatTax’s citation analysis of 367,347 Indian tax judgments — from 2015 to 2026.

Also referred to as

Cheminvest Ltd. v. CIT · Section 14A disallowance · no exempt income · exempt dividend income · expenditure related to exempt income · Section 8D · Section 115JB · Income-tax Act 1961 · Delhi High Court

Also reported as

61 Taxmann.com 118234 Taxmann 761317 ITD 33281 CTR 447

Sections most often in play

Section 14ASection 143(3)Section 8DSection 115JBSection 250Section 1961Section 37(1)Section 143(2)
Read the full judgment

Issues it is cited on

disallowance u/s 14adisallowance under section 14asection 14asection 36(1)(iii)section 115jbrevenue expendituresection 37(1)section 37section 36previous yearscrutiny assessmentsection 115

Judgments citing Cheminvest Ltd. v. CIT

Chhattisgarh Sponge Manufacturing Consortium Coalfields Private Limited, Raipur vs. Income Tax Officer, Ward 1(3), Raipur

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 207/RPR/2018[2015-16]Status: DisposedITAT Raipur31 May 2022AY 2015-16

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No.207/Rpr/2018 "नधा"रण वष" / Assessment Year : 2015-16 C.G. Sponge Manufacturing Consortium Coalfields Pvt. Ltd. Room No.208, Lalganga Midas, Bilaspur Road, Fafadih, Raipur-492 009 Pan : Aaccc6516E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(3), Raipur (C.G.) ……""यथ" / Respondent Assessee By : Shri R.B Doshi, Ar Revenue By : Shri G.N Singh, Dr

For Appellant: Shri R.B Doshi, ARFor Respondent: Shri G.N Singh, DR
Section 143(2)Section 143(3)Section 14A

…its hand. Our aforesaid view is fortified by the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Chettinad Logistics Pvt. Ltd. (2018) 257 Taxmann 2 (SC) and also of the Hon’ble High Court of Delhi in the case of Cheminvest Limited Vs. CIT, (2015) 378 ITR 33 (Delhi). Backed by the aforesaid judicial pronouncements, it was submitted by the Ld. AR that as per the settled position of law no disallowance u/s.14A in absence of any exempt income could have been made in the hands of the assessee. In the backdrop of the facts involved in the case before us r/w. the aforesaid settled position of law we find su…

DCIT 3(2) (1), Mumbai vs. M/S. Mukund Ltd, Mumbai

Accordingly, ground no 3 is allowed

ITA 1794/MUM/2021[2017-18]Status: DisposedITAT Mumbai31 May 2022AY 2017-18

Bench: Shri M. Balaganesh & Shri Kuldip Singhassessment Year: 2017-18

For Appellant: Shri Raj Mehta(ACA), A.RFor Respondent: Smt. Sonia Kumar, D.R
Section 115JSection 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year: 2017-18 DCIT- 3(2)(1), M/s. Mukand Limited, 3rd Floor, Bajaj Bhavan, Room No.674, 6th Floor, Vs. Jamnalal Bajaj Marg, Aayakar Bhavan, Nariman Point, M.K. Road, Mumbai – 400 021 Mumbai - 400020 PAN: AAACM5008R (Appellant) (Respondent) Present for: Assessee by : Shri Raj Mehta(ACA), A.R. Shri Alpesh Dharod (FCA), A.R. Revenue by : Smt. Sonia Kumar, D.R. Date of Hearing : 24 . 05 . 2022 Date of Pronouncement : 31 . 05 . 2022 O R D E R Per : Kuldi…

M/S. Mgi Coutier Exotech Industries Pvt.Ltd, Pune vs. Deputy Commissioner of Income Tax

In the result, the appeal is partly allowed

ITA 72/PUN/2017[2010-11]Status: DisposedITAT Pune26 May 2022AY 2010-11

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2010-11

…ed order categorically records the contention of the assessee that no exempt income was earned during the year. Such a contention has not been controverted by the ld. first appellate authority. The Hon'ble Delhi High Court in Cheminvest Ltd. vs. CIT (2015) 378 ITR 33 (Del) has held that if there is no exempt income, there can be no question of making any disallowance u/s 14A of the Act. Similar view has been taken by the Hon'ble Delhi High Court in CIT vs. Holcim India P. Ltd. (2014) 90CCH 081-Del-HC. More recently the Hon’ble jurisdictional High Court in Pr. CIT VS. Kohinoor Projects Pvt. Ltd. (2020) 425…

Dy. Commissioner of Income Tax, Central Cir.-3, Surat vs. Sh. Hareshbhai Mohanbhai Sakariya, Surat

In the result, Revenue’s appeal is dismissed

ITA 48/SRT/2021[2017-18]Status: DisposedITAT Surat25 May 2022AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

Section 132Section 132(1)Section 143(3)Section 14ASection 153ASection 153CSection 158BSection 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER IT(SS)A No.01/SRT/2021 (AY 2010-11) IT(SS)A No.09/SRT/2020 (AY 2014-15) (Hearing in Physical Court) Deputy Commissioner of Shri Dineshchandra D Income-tax, Central Circle- Koradia, 3Room No.507, 5th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/h.Navyug College, Gate, Surat-395001 Rander Road, Surat PAN No: ACUPK 3696 A Assistant Commissioner of Vs Income-tax, Central Circle-3, Room No.507, 5th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue…

Gmr Highways Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 3(1)(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 495/BANG/2020[2016-17]Status: DisposedITAT Bangalore25 May 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Gmr Highways Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle 3(1)(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1643/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bengaluru vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1744/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bangalore vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1743/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bengaluru vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1742/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Gmr Infrastructure Ltd, Bangalore

In the result, Ground no. 1 raised for A

ITA 1741/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1705/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1622/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1600/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Gmr Infrastructure Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1599/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…A.Ys. 2012-13 and 2013-14, we direct the Ld.AO to restrict the disallowance to the extent of exempt income earned by assessee. In support of this view, we refer to the decision of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT reported in (2015) 378 ITR 33 and the decision by Hon’ble Special Bench of this Tribunal in case of ACIT vs. Vireet Investments Pvt. Ltd. (supra). Page 32 of 46 ITA Nos. 1705, 1622, 1599, 1600, 1741 to 1744/Bang/2017, C.O. Nos. 111 to 114/Bang/2017, ITA Nos. 1643/Bang/2019 & 495/Bang/2020 6.29 Accordingly the grounds raised by the assessee for A.Ys. 2010-11 to 2013-14 and 201…

Awas Developers & Construction Pvt. Ltd., Mumbai vs. ACIT Cent. Cir. 5(4), Mumbai

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

ITA 2721/MUM/2016[2010-11]Status: DisposedITAT Mumbai17 May 2022AY 2010-11
Section 115JSection 14ASection 8D(2)(iii)

…rned CIT(A) by the assessee was that the disallowance to be made under section 14A should not exceed exempt income. We notice that this contention is supported by the decision rendered by Hon'ble Delhi High Court in the case of Cheminvest Ltd. Vs. CIT (2015) (378 ITR 33)(Del). Hence, without going into other contentions urged by the assessee, we are of the view that this contention of the assessee 3 M/s. Awas Developers & Construction Private Ltd. may be accepted as it is supported by the decision rendered by Hon’ble Delhi High Court. Accordingly, we hold that the disallowance under section 14A should not exceed…

M/S. Chambal Fertilizers and Chemicals Limited, Kota vs. Assistant Commissioner of Income Tax, Circle-2, Kota

In the result, appeal of the revenue is dismissed

ITA 744/JPR/2018[2014-15]Status: DisposedITAT Jaipur13 May 2022AY 2014-15
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

…)(SB) held that as per rule 8D(2)(iii), only those investments were to be considered for computing average value of investments which yielded exempt income during the year under consideration. 15.14. The Delhi High Court in Cheminvest Limited v. CIT (2015) 378 ITR 33 (Del) which held that the expression ‘does not form part of the total income’ in section 14A envisages that there should be an actual receipt of income, which was not includible in the total income, during the relevant previous year for the purpose of disallowing any expenditure incurred in relation to the said income. 15.15. The Delhi High Cour…

Chambal Fertilisers and Chemicals Limited, Kota vs. ACIT, Kota

In the result, appeal of the revenue is dismissed

ITA 291/JPR/2017[2013-14]Status: DisposedITAT Jaipur13 May 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

…)(SB) held that as per rule 8D(2)(iii), only those investments were to be considered for computing average value of investments which yielded exempt income during the year under consideration. 15.14. The Delhi High Court in Cheminvest Limited v. CIT (2015) 378 ITR 33 (Del) which held that the expression ‘does not form part of the total income’ in section 14A envisages that there should be an actual receipt of income, which was not includible in the total income, during the relevant previous year for the purpose of disallowing any expenditure incurred in relation to the said income. 15.15. The Delhi High Cour…

Chambal Fertilisers and Chemicals Limited, Kota vs. DCIT, Kota

In the result, appeal of the revenue is dismissed

ITA 201/JPR/2017[2012-13]Status: DisposedITAT Jaipur13 May 2022AY 2012-13
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

…)(SB) held that as per rule 8D(2)(iii), only those investments were to be considered for computing average value of investments which yielded exempt income during the year under consideration. 15.14. The Delhi High Court in Cheminvest Limited v. CIT (2015) 378 ITR 33 (Del) which held that the expression ‘does not form part of the total income’ in section 14A envisages that there should be an actual receipt of income, which was not includible in the total income, during the relevant previous year for the purpose of disallowing any expenditure incurred in relation to the said income. 15.15. The Delhi High Cour…

M/S Traditional Gallery Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-4, Jaipur

In the result, appeals of the assessee are allowed

ITA 108/JPR/2019[2014-15]Status: DisposedITAT Jaipur12 May 2022AY 2014-15
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt. Runi Pal (Addl.CIT)
Section 143(3)Section 14ASection 36(1)(iii)

…To support his contention, the ld. A/R placed reliance on the judgment of Hon’ble Supreme Court in case of Maxopp Investment Ltd vs. CIT reported in 402 ITR 640 (SC) and also on the judgment of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT, 378 ITR 33 (Delhi) and also relied on the decision of Jaipur Bench of 8 ITA Nos. 107 & 108/JP/2019. M/s. Traditional Gallery Pvt. Ltd., Jaipur. the Tribunal in case of Deepak Vegpro (P) Ltd vs. ACIT in ITA No. 110/JP/2014 and in the case of M/s. Mahalaxmi Saws Pvt. Ltd. in ITA No. 280/JP/2019 and prayed for deletion of disallowance made by the AO under sect…

M/S Traditional Gallery Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-4, Jaipur

In the result, appeals of the assessee are allowed

ITA 107/JPR/2019[2013-14]Status: DisposedITAT Jaipur12 May 2022AY 2013-14
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt. Runi Pal (Addl.CIT)
Section 143(3)Section 14ASection 36(1)(iii)

…To support his contention, the ld. A/R placed reliance on the judgment of Hon’ble Supreme Court in case of Maxopp Investment Ltd vs. CIT reported in 402 ITR 640 (SC) and also on the judgment of Hon’ble Delhi High Court in case of Cheminvest Ltd. vs. CIT, 378 ITR 33 (Delhi) and also relied on the decision of Jaipur Bench of 8 ITA Nos. 107 & 108/JP/2019. M/s. Traditional Gallery Pvt. Ltd., Jaipur. the Tribunal in case of Deepak Vegpro (P) Ltd vs. ACIT in ITA No. 110/JP/2014 and in the case of M/s. Mahalaxmi Saws Pvt. Ltd. in ITA No. 280/JP/2019 and prayed for deletion of disallowance made by the AO under sect…