How many judgments cite Cheminvest Ltd. v. CIT?

1,569 judgments on BharatTax cite Cheminvest Ltd. v. CIT (378 ITR 33), spanning 2015 to 2026.

Which sections of the Income Tax Act does Cheminvest Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 14A, Section 143(3), Section 8D, Section 115JB, Section 250, Section 1961.

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 367,181 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 14A Section 143(3)Section 8D Section 115JB Section 250 Section 1961 Section 37(1)Section 143(2)

Read the full judgment

Issues it is cited on

disallowance u/s 14a disallowance under section 14a section 14a section 36(1)(iii)section 115jb revenue expenditure section 37(1)section 37 section 36 previous year scrutiny assessment section 115

Judgments citing Cheminvest Ltd. v. CIT

DCIT, New Delhi vs. M/S. Mawana Sugars Ltd., New Delhi

ITA 1479/DEL/2010[2006-07]Status: DisposedITAT Delhi28 May 2018AY 2006-07

Bench: Hon’Ble, Shri G.D. Agrawal & Shri Kuldip Singh

…on of Daga Capital Management Pvt. Ltd. 312 ITR (AT) 01. ITA No.751 & 752/Del/2012 CO No.153, 154 & 379/Del/2012 46. Identical issue has come up for consideration before the Hon’ble jurisdictional High Court in case cited as Cheminvest Ltd. vs. CIT - (2015) 378 ITR 33 (Delhi) wherein it is held as under :- “Held, that no exempted income was earned by the assessee in the relevant assessment year and since the genuineness of the expenditure incurred by the assessee was not in doubt, no disallowance could be made under section 14A.” Hon’ble Apex Court in Godrej & Boyce Manufacturing 47. Company Ltd. vs. DCIT – 3…

DCIT, New Delhi vs. M/S. Mawana Sugars Ltd., New Delhi

ITA 1463/DEL/2010[2005-06]Status: DisposedITAT Delhi28 May 2018AY 2005-06

Bench: Hon’Ble, Shri G.D. Agrawal & Shri Kuldip Singh

ACIT, Cir-11(2), Kol, Kolkata vs. M/S Vrishah Services Pvt. Ltd., Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1468/KOL/2016[2012-13]Status: DisposedITAT Kolkata25 May 2018AY 2012-13

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1468/Kol/2016 Assessment Year : 2012-13 Acit, Circle-11(2), Kolkata -Vs- M/S Vrishah Services Pvt. Ltd. [Pan: Aaccr 3949 Q] (Appellant) (Respondent)

For Appellant: Shri G.Mallikarjuna, CIT DRFor Respondent: Shri Manoj Kataruka, Advocate

Section 143(1)Section 143(3)Section 194HSection 40

…wance u/s 14A of the Act read with Rule 8D of the Rules in the sum of Rs. 3,17,734/- under third limb of Rule 8D(2) of the Rules. The Ld. CIT(A) by applying the ratio laid down by the Hon’ble Delhi High Court in the case of Cheminvest Ltd. vs. CIT reported in 378 ITR 33 wherein it was held that where there is no exempt 4 5 M/s Vrishah Servics Pvt. Ltd. A.Yr. 2012-13 income, no disallowance is called for u/s 14A of the Act, and accordingly deleted the disallowance u/s 14A of the Act. Aggrieved, the revenue is in appeal before us . 9. We have heard the rival submissions. It is not in dispute that the assessee had…

Ideal Toll & Infrastructure P.Ltd, Mumbai vs. DCIT 6(1), Mumbai

In the result, the appeal of the assessee is treated as allowed

ITA 7758/MUM/2014[2010-11]Status: DisposedITAT Mumbai25 May 2018AY 2010-11

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 14ASection 36(1)(iii)

…see, we agree with the contention that disallowance under section 14A of the Act cannot exceed the exempt income earned by the assessee during the year under consideration, in view of the decision of the Hon'ble Delhi High Court in the case of Cheminvest Ltd [378 ITR 33(Del)], wherein it is held as under: "15. Turning to the central question that arises for consideration, the Court finds that the complete answer is provided by the decision of this Court in CIT v. Holcim India (P) Ltd. (decision dated 5th September 2014 in ITA No. 486/2014). In that case a similar question arose, viz., whether the ITAT was justif…

Aditi Technologies Private Ltd, Banlgaore vs. The Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 1423/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2018AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Inturi Rama Rao

For Appellant: Shri L. Bharath, C.AFor Respondent: Smt. Padma Meenakshi, JCIT (D.R)

Section 10ASection 143(3)Section 14ASection 40Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH ‘ B ’ BEFORE SHRI N.V. VASUDEVAN, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER I.T. A. No.1423/Bang/2017 (Assessment Year : 2012-13) M/s. Aditi Technologies Private Limited, (now known as Harman Connected Services Technologies Private Limited, No.C-4, Block, Wing A, Manyata Embassy Business Park, Outer Ring Road, Bangalore-560 011. …. Appellant. Vs. Dy. Commissioner of Income Tax, Circle 1(1)(1), Bangalore. ….. Respondent. Appellant By : Shri L. Bharath, C.A. Respondent By : Smt. Padma Meenakshi, JCIT (D.R) Date of Hearing : 22.05.2018. D…

Assistant Commissioner of Income Tax, Kota vs. Smt. Manisha Agarwal, Kota

In the result, appeal of the revenue is dismissed

ITA 340/JPR/2018[2011-12]Status: DisposedITAT Jaipur16 May 2018AY 2011-12

For Appellant: NoneFor Respondent: Shri Raj Mehra (JCIT) fu/kZkfjrh dh vksj ls@

Section 14A

…n decision of Tribunal rendered in case of Cheminvest Ltd. v. ITO 120091 121 ITD 318 (Delhi) (SB) rejected assessee's contention - Whether since above decision of Tribunal had been reversed by jurisdictional High Court in case of Cheminvest Ltd. v. CIT 12015] 378 ITR 33/234 Taxman 761/ 61 taxinann.corn 118 (Delhi), it would have to be held that no disallowance under section 14A can be made, where there is no exempt income - Held, yes Thus relying on the position in this regard as was also applicable for the year under appeal, I am of the view that the disallowance could not be made as the appellant had not earne…

Deputy Commissioner of Income-Tax, Jalgaon vs. M/S. Rajmal Lakhichand & Sons

Appeal is dismissed

ITA 1547/PUN/2014[2009-10]Status: DisposedITAT Pune14 May 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपील सं. / Ita No.1360/Pun/2014 आयकर अपील सं आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Year : 2009-10 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Sunil PathakFor Respondent: Shri Anil Kumar Chaware

Section 14Section 143(3)Section 14ASection 36

…hich formed part of the total income, the provisions of section 14A of the Act should not be invoked. The CIT(A) considered the same and however, confirmed the addition of Assessing Officer relying on the decision of Cheminvest Ltd. Vs. Income Tax Officer, 378 ITR 33 as well as CBDT Circular No. 225/182/2013 dated 11.02.2014. 6. Before us, on this issue relating to applying the provisions of section 14A r.w.r 8D of the I.T. Rules, Ld. Counsel for the assessee submitted that the instant case is squarely covered in favour of the assessee. Referring to the decision of Hon'ble Delhi High Court in the case of Chem…

M/S. Rajmal Lakhichand & Sons vs. Joint Commissiner of Income-Tax

Appeal is dismissed

ITA 1360/PUN/2014[2009-10]Status: DisposedITAT Pune14 May 2018AY 2009-10

For Appellant: Shri Sunil PathakFor Respondent: Shri Anil Kumar Chaware

Section 14Section 143(3)Section 14ASection 36

DCIT, Circle-2, Kolkata vs. M/S. Infinity Infotech Parks Ltd, Kolkata

In the result, the appeal of revenue is dismissed

ITA 1317/KOL/2012[2009-10]Status: DisposedITAT Kolkata14 May 2018AY 2009-10

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

Section 14A

…em Investments Ltd., supra before deleting the disallowance u/s. 14A of the Act, we note that the aforesaid decision of the Tribunal has since been overruled by the Hon’ble Delhi Infinity Infotech Parks Ltd., AY 2009-10 High Court in its judgment reported in 317 ITR 33 (Del) wherein the Hon’ble High Court held that if the assessee does not receive dividend income or exempt income during the relevant previous year, the disallowance u/s. 14A of the Act read with Rule 8D of the Rules is not warranted. For the aforesaid proposition, we rely on the decision in the case of CIT Vs. Holcim India Pvt. Ltd. 272 CTR 282 (D…

N.Nagaraj Ballal, Udupi vs. Income Tax Officer Ward-2, Udupi

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

ITA 840/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 May 2018AY 2012-13

Bench: Shri Arun Kumar Garodiaassessment Year :2012-13

For Appellant: Shri Anil Kumar .H, CAFor Respondent: Smt. Padma Meenakshi, JCIT (DR)

Section 14A

…ance u/s. 14A cannot exceed the exempt income earned by the assessee in the relevant year and in this Tribunal order, the Tribunal has followed the judgment of Hon’ble Delhi High Court rendered in the case of Cheminvest Pvt. Ltd. Vs. CIT as reported in (2015) 378 ITR 33. He submitted that as per this Tribunal order, disallowance in the present case may be maximum Rs. 14,870/-. He further submitted that even these much disallowance in the present case is not justified and in the present case disallowance should not exceed Rs. 10,554/- as per working submitted by him along with the summary of submissions made befor…

DCIT, Circle-16(2), Hyd, Hyderabad vs. Mylan Laboratories Ltd., Hyd, Hyderabad

In the result, appeal of Revenue is partly allowed

ITA 659/HYD/2016[2010-11]Status: DisposedITAT Hyderabad09 May 2018AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Smt. T.H. Vijaya Lakshmi, CIT-DR

Section 10BSection 115JSection 143(3)Section 144CSection 14ASection 92ASection 92C

…he case Prathista Industries Ltd., Vs. DCIT in ITA No. of 1302/Hyd/2015 dated 29-04-2016, directed to delete the disallowance, since there is no income claiming exemption during the year. The Hon'ble Delhi High Court in the case of Cheminvest Ltd., in (2015) [378 ITR 33] (Del) and the Hon'ble Madras High Court in the case of Redington (India) Ltd., Vs. Addl. CIT in TCA No. 520/2016 dt. 26-06-2015 have held that the disallowance u/s. 14A cannot be made where there is no exempt income during the relevant assessment year. Therefore, we set aside the order of Ld.CIT(A) and direct the AO to delete the addition made by…

Mylan Laboratories Ltd, (Formerly Matrix Laboratories Limited), Hyd Hyd, Hyderabad vs. DCIT, Circle-16(2), Hyd, Hyderabad

In the result, appeal of Revenue is partly allowed

ITA 626/HYD/2016[2010-11]Status: DisposedITAT Hyderabad09 May 2018AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Smt. T.H. Vijaya Lakshmi, CIT-DR

Section 10BSection 115JSection 143(3)Section 144CSection 14ASection 92ASection 92C

Goldseal Engineering Products P.Ltd Ltd, Mumbai vs. ACIT 15(1)(2), Mumbai

The appeal of the assessee is allowed as indicated above

ITA 6259/MUM/2016[2011-12]Status: DisposedITAT Mumbai09 May 2018AY 2011-12

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.6259/Mum/2016 (नििाारण वर्ा / Assessment Year : 2012-13) M/S. Gold Seal Engineering बिाम/ Acit 15(1)(2), Mumbai Products P. Ltd., Gr. Floor, Gold Seal House, V. Village Road, Bhandup (W), Mumbai- 400078 स्थायी ऱेखा सं./ Pan : Aaacg1492R (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Firoze AndhyarujinaFor Respondent: Shri V. Vidhyadhar (Sr. DR)

Section 143(3)Section 14ASection 24Section 38

…an exempt income u/s 10(34). The Ld. Counsel for the assessee relied upon following decisions to contend that disallowance u/s. 14A cannot exceed an exempt income : a. Maxopp Investment Limited v. CIT(2018) 402 ITR 640(SC) b. Cheminvest Limited v. CIT. (2015) 378 ITR 33 (Delhi HC ) c. Joint Investments Private Ltd. v. CIT (2015) 373 ITR 694(Delhi HC ) d. M/s. Anjaneya Cold Storage Limited v. ACIT ITA no. 6079/Del/2014 order dated 25.10.2017 e. Daga Global Chemicals P. Ltd. v. ACIT (2017) 82 taxmann.com 254 (Mumbai Trib.) The Ld. DR on the other hand fairly submitted that proposition that disallowance u/s 14A ca…

Crescent Trading P. Ltd(Now Merged With M/S.Rightgrowth Trading Private Limited), Mumbai vs. DCIT Cen Cir 3(3), Mumbai

In the result, the appeal Assessee is partly allowed

ITA 995/MUM/2018[2013-14]Status: DisposedITAT Mumbai08 May 2018AY 2013-14

Bench: Sri Mahavir Singh

For Appellant: None, ARFor Respondent: P.R. Chauhan, DR

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

…xempt income earned by assessee is only to the tune of ₹ 1,82,371/- on shares held as investment and claim the same 4 as exempt under section 10(34) of the Act. In view of the decision of Hon’ble Delhi High Court in the case of Cheminvest Ltd. vs. CIT (2015) 378 ITR 33 (Delhi) the issue is squarely covered in favour of assessee. The decision of Delhi High Court in the case of Cheminvest Limited (supra), reads as under: - “23. In the context of the facts enumerated hereinbefore the Court answers the question framed by holding that the expression „does not form part of the total income‟ in Section 14A of the envi…

Slc Projects Pvt.Ltd., Visakhapatnam vs. ACIT, Central Circle-2, Visakhapatnam

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

ITA 513/VIZ/2017[2013-14]Status: DisposedITAT Visakhapatnam04 May 2018AY 2013-14

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri I. Kama Sastry, AR

Section 43(6)(c)

…ITA No.513 /Vizag/2017 SLC Projects Pvt. Ltd., VSKP आयकर अपील"य अ"धकरण, "वशाखापटणम पीठ, "वशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM "ी वी. दुगा"राव, "या"यक सद"य एवं "ी ड.एस. . . . सु"दर "संह, लेखा सद"य के सम% BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI D.S. SUNDER SINGH, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A.No.513/Vizag/2017 ("नधा"रण वष" / Assessment Year: 2013-14) SLC Projects Pvt. Ltd. ACIT, Central Circle-2 Visakhapatnam Visakhapatnam [PAN No.AAJCS8616C] (अपीलाथ' / Appellant) (()याथ' / Respondent) अपीलाथ" क" ओर से / Appellant by : Shri I. Kama Sastry, AR : S…

ACIT -3(1)(2), Mumbai vs. Golden Life Finacial Services Pvt. Ltd., Mumbai

In the result, this appeal by the Revenue stands partly allowed for statistical purposes

ITA 3053/MUM/2016[2010-11]Status: DisposedITAT Mumbai02 May 2018AY 2010-11

Bench: Shri Shamim Yahya & Shri Amarjit Singha C I T - 3(1)(2) M/S. Golden Life Financial Room No. 607, 6Th Floor Services Pvt. Ltd. Aayakar Bhavan (Formerly Lifeline Inusrance Vs. Distribution Co. Pvt. Ltd.) Mumbai 400020 125-B, Mittal Court, Nariman Point Mumbai 400021 Pan – Aaacl8998D Appellant Respondent

For Appellant: Shri Rajat MittalFor Respondent: Ms. Krupa Gandhi

Section 10(34)Section 143(1)Section 143(2)Section 143(3)Section 14A

…ed the dividend earned. Against this order the Revenue is in appeal before us. 5. We have heard both the counsels and perused the record. We find that the issue stands covered in favour of the assessee by the following case law: - i) Cheminvest Ltd. vs. CIT 281 CTR 447 ii) Hon'ble Bombay High Court in the case of Pr. CIT vs. Ballarpur Industries Ltd. in ITA No. 51 of 2016 6. In these decisions it was held that disallowance under Section 14A cannot exceed the dividend income earned. Accordingly in the background of aforesaid precedents we do not find any infirmity in the order of the learned CIT(A) on this issue…

Indur Avenues and Foods Private Limited, Nizamabad vs. Asst. Commissioner of Income Tax, Circle-1, Nizamabad

In the result the appeal filed by the assessee is allowed

ITA 1138/HYD/2017[2013-14]Status: DisposedITAT Hyderabad27 Apr 2018AY 2013-14

Bench: Smt P. Madhavi Devi & Shri S. Rifiaur Rahmanassessment Year: 2013-14 Indur Avenues & Foods Pvt Vs. Acit, Ltd., Circle-1 Nizamabad. Nizamabad. Pan – Aabci0260Q

For Appellant: Shri T. Chaitanya KumarFor Respondent: Date of hearing

Section 10Section 143(1)Section 143(3)Section 14A

…efore there is no claim of exempt income and the disallowance u/s 14A is not called for. He submitted that this issue is covered in favour of the assessee by the decision of the Hon’ble Delhi High Court in the case of M/s Cheminvest Ltd. Vs. CIT-IV, New Delhi 378 ITR 33 (Delhi) and also the various other decisions of the Tribunal. 5. The Ld. DR on the other hand, supported the orders of the authorities below. 6. Having regard to the rival contentions and material on record, we find that this issue is covered in favour of the assessee by the decision of Hon’ble Delhi High Court in the case of M/s Cheminvest Ltd.…

Encord Refricool Private Limited, Kolkata vs. ITO, Ward - 8(2), Kolkata

In the result, appeal of assessee is allowed

ITA 1226/KOL/2017[2012-13]Status: DisposedITAT Kolkata26 Apr 2018AY 2012-13

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M.Balaganesh, Am]

Section 14ASection 263

…1 Encord Refricool Private Limited, AY- 2012-13 आयकर अपील"य अधीकरण, "यायपीठ – “A” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: KOLKATA (सम")Before "ी ऐ. ट". वक", "यायीक सद"य एवं/and "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, JM & Shri M.Balaganesh, AM] I.T.A. No. 1226/Kol/2017 Assessment Year: 2012-13 Encord Refricool Private Limited Vs. Income-tax Officer, Wd-8(2), Kolkata (PAN: AABCE6922D) Appellant Respondent Date of Hearing 15.02.2018 Date of Pronouncement 26.04.2018 For the Appellant Shri P. R. Kothari, AR For the Respondent Shri G. Hangshing, CIT ORDER Per Shri A.T.Varkey, JM…

Gouranga Modak, Kolkata vs. JCIT, RG-49, Kolkata

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

ITA 674/KOL/2015[2010-2011]Status: DisposedITAT Kolkata25 Apr 2018AY 2010-2011

Bench: The Ao In Support Of The Claim. The Ao Considering The Submissions Along With Details Filed Determined The Total Income At Rs. 2,04,65,720/- By Making The Following Additions Vide An Order Dt. 01-03-2013 Passed U/Sec 143(3) Of The Act:

For Appellant: Shri Subhash Agarwal, Advocate, ld.ARFor Respondent: Shri Sallong Yaden, Addl.CIT, ld. Sr.DR

Section 14Section 143(2)Section 14A

…as made by the AO. 7. Before us the ld.AR reiterated his same submissions made before the CIT-A. He further submits that the Hon’ble High Court of Delhi reversed the finding of Hon’ble Special Bench, ITAT, Delhi in the case of Cheminvestment Ltd reported in 378 ITR 33 (Del). The Hon’ble High Court set aside the order of Special Bench, ITAT, Delhi and held that section 14A of the Act is not applicable if no exempt income is received. The ld.AR referred to the order dt. 06-12-2017 of Co-ordinate Bench of this Tribunal in the case of Development 2 Consultant P.Ltd, copy of the same is on record, and argued that di…

DCIT CC 6(4), Mumbai vs. J M Baxi & Co, Mumbai

In the result, the appeals filed by the Revenue for the aforementioned years are dismissed

ITA 4246/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Apr 2018AY 2011-12

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 J.M. Baxi& Co., The Deputy Commissioner 16, Bank Street, Fort, Of Income Tax, Central Vs. Mumbai-400001. Circle-6(4), Room No. 1925, 19Th Floor, Air India Building, Nariman Point, Mumbai-400021. Pan No. Aaafj51698E Appellant Respondent Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 The Deputy Commissioner Of J.M. Baxi& Co., Income Tax, Central Circle- 16, Bank Street, Fort, Vs. 6(4), Mumbai-400001. Room No. 1925, 19Th Floor, Air India Building, Nariman Point, Mumbai-400021. Pan No. Aaafj51698E Appellant Respondent

For Respondent: Ms. S. Padmaja, CIT(DR)

Section 14Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI C.N. PRASAD (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 J.M. Baxi& Co., The Deputy Commissioner 16, Bank Street, Fort, of Income Tax, Central Vs. Mumbai-400001. Circle-6(4), Room No. 1925, 19th floor, Air India Building, Nariman Point, Mumbai-400021. PAN No. AAAFJ51698E Appellant Respondent Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 The Deputy Commissioner of J.M. Baxi& Co., Income Tax, Central Circle- 16, Bank…