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 366,470 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

M/S. Samtel Color Limited, New Delhi vs. ACIT, New Delhi

In the result the appeal of the assessee is allowed

ITA 6681/DEL/2013[2009-10]Status: DisposedITAT Delhi20 May 2016AY 2009-10

Bench: Shri H.S.Sidhu & Shri J. Sudhakar Reddyay: 2009-10 Samtel Color Ltd. Vs. Acit, Circle 7(1) 501, Copia Corporate Suites New Delhi District Centre, Jasola New Delhi 110 025 Pan: Aaacs 6589 D A N D Ay: 2009-10 Dy.Cit, Circle 7(1) Vs. Samtel Color Ltd. New Delhi New Delhi

For Appellant: Shri D.C.Garg, C.AFor Respondent: Sh.T.James Singson, Sr.D.R
Section 143(3)Section 14A

…ncome was earned. (b) Hon’ble Jursidictional High Court in CIT vs. Holcim India P.Ltd. (9- CCH 081) has also endorsed this view of the Hon’ble Punjab & Haryana High Court in the case of Lakhani Marketing.(c ) In the case of Cheminvest Ltd. vs. CIT reported in 378 ITR 33, the Jurisdictional High Court stated that where there is no exempt income, S.14A does not have applicability. 10.4. Respectfully following the proposition of law laid down by the Hon’ble Delhi High Court in the case of Cheminvest Ltd. (supra), as the assessee has not earned any income which is not chargeable to tax, no disallowance can be made u…

DCIT, New Delhi vs. M/S. Samtel Color Ltd., New Delhi

In the result the appeal of the assessee is allowed

ITA 6600/DEL/2013[2009-10]Status: DisposedITAT Delhi20 May 2016AY 2009-10

Bench: Shri H.S.Sidhu & Shri J. Sudhakar Reddyay: 2009-10 Samtel Color Ltd. Vs. Acit, Circle 7(1) 501, Copia Corporate Suites New Delhi District Centre, Jasola New Delhi 110 025 Pan: Aaacs 6589 D A N D Ay: 2009-10 Dy.Cit, Circle 7(1) Vs. Samtel Color Ltd. New Delhi New Delhi

For Appellant: Shri D.C.Garg, C.AFor Respondent: Sh.T.James Singson, Sr.D.R
Section 143(3)Section 14A

…ncome was earned. (b) Hon’ble Jursidictional High Court in CIT vs. Holcim India P.Ltd. (9- CCH 081) has also endorsed this view of the Hon’ble Punjab & Haryana High Court in the case of Lakhani Marketing.(c ) In the case of Cheminvest Ltd. vs. CIT reported in 378 ITR 33, the Jurisdictional High Court stated that where there is no exempt income, S.14A does not have applicability. 10.4. Respectfully following the proposition of law laid down by the Hon’ble Delhi High Court in the case of Cheminvest Ltd. (supra), as the assessee has not earned any income which is not chargeable to tax, no disallowance can be made u…

M/S. Kortek Electronics (India) Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result the appeal of the assessee is allowed in part

ITA 1886/DEL/2013[2008-09]Status: DisposedITAT Delhi18 May 2016AY 2008-09

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Rashmita Jha, Sr.DR
Section 143(3)Section 14ASection 234BSection 40Section 80ISection 80lSection 92C

…ound No. 3 is on the disallowance made u/s 14A r.w.r 8D. The assessee does not have income which is exempt from tax. Under these circumstances no disallowance can be made u/s 14A of the Act. The Hon’ble Delhi High Court in the case of Cheminvest Ltd. vs. CIT 378 ITR 33 (Delhi) laid down as follows :- “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.” 7. Respectfully following the same we allow ground No. 3. 8. Ground No. 4 is against the disal…

PAN India Network Infravest P.Ltd, Mumbai vs. DCIT Cir 7(1), Mumbai

The appeal of the assessee stands allowed

ITA 4170/MUM/2013[2009-10]Status: DisposedITAT Mumbai11 May 2016AY 2009-10
For Appellant: Shri Niraj Seth-ARFor Respondent: Shri Love Kumar-DR
Section 143(3)Section 14ASection 254(1)

…e u/s 14A of the Act ignoring the ratio of the Tribunal in Cheminvest Ltd. (121 ITD 318)(Del.). The crux of argument on behalf of the assessee is that no income was earned by the assessee and merely hypothetical disallowance has been made. Reliance was placed 378 ITR 33 (Del.) order dated 02/09/2015. Considering the totality of facts and the arguments from both sides, we find that the Hon’ble Delhi High Court in the aforesaid order dated 02/09/2015 held that where no exempt income was earned by the assessee in the relevant assessment years and since the genuineness of 3378/13 & 4170/13-Pan India expenditure is n…

DCIT 7(1), Mumbai vs. PAN India Network Infravest P.Ltd, Mumbai

The appeal of the assessee stands allowed

ITA 3378/MUM/2013[2009-10]Status: DisposedITAT Mumbai11 May 2016AY 2009-10
For Appellant: Shri Niraj Seth-ARFor Respondent: Shri Love Kumar-DR
Section 143(3)Section 14ASection 254(1)

…e u/s 14A of the Act ignoring the ratio of the Tribunal in Cheminvest Ltd. (121 ITD 318)(Del.). The crux of argument on behalf of the assessee is that no income was earned by the assessee and merely hypothetical disallowance has been made. Reliance was placed 378 ITR 33 (Del.) order dated 02/09/2015. Considering the totality of facts and the arguments from both sides, we find that the Hon’ble Delhi High Court in the aforesaid order dated 02/09/2015 held that where no exempt income was earned by the assessee in the relevant assessment years and since the genuineness of 3378/13 & 4170/13-Pan India expenditure is n…

Shriram Wealth Advisors Ltd., Chennai vs. DCIT, Chennai

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

ITA 407/CHNY/2016[2012-2013]Status: DisposedITAT Chennai05 May 2016AY 2012-2013

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.407/Mds/2016 "नधा"रण वष" / Assessment Year : 2012-13 M/S Shriram Wealth Advisors Ltd., The Deputy Commissioner Of Mookambika Complex, V. Income Tax, No.4, Lady Desika Road, Corporate Circle 6(1), Mylapore, Chennai – 600 004. Chennai – 600 034. Pan : Aamcs 0723 P (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Sh. R. Sivaraman, AdvocateFor Respondent: Sh. P. Radhakrishnan, JCIT
Section 14A

…s, 1962. The Ld. counsel submitted that the assessee has not received any dividend income during the assessment year under consideration and there was no fresh investment also. Even though the judgement of Delhi High Court in Chem Investments Limited v. CIT (234 Taxmann 761) and the (45 Taxmann.com 116) were brought to the notice of the authorities below, the Assessing Officer disallowed the claim of the assessee by applying third limb of Rule 8D(2) of the Income-Tax Rules, 1962. According to the Ld. counsel for the assessee, when the assessee has not incurred any expenditure, there is no question of any disa…

JCIT (OSD) 8(1), Mumbai vs. Dystar India P.Ltd, Navi Mumbai

In the result appeal of the revenue stands dismissed and both the appeals filed by the assessee are allowed

ITA 4088/MUM/2012[2009-10]Status: DisposedITAT Mumbai27 Apr 2016AY 2009-10

Bench: Shri Amit Shukla & Shri Ramit Kochar

Section 143(3)Section 14A

…r discussing the decision of Hon’ble High Court decision in the case of Maxopp Investment Ltd vs CIT 347 ITR 272 (Del). 4. Before us, the Ld. Counsel submitted that now in wake of latest High Court decision in the case of Cheminvest Ltd. vs. CIT, reported in 378 ITR 33, no disallowance under section 14A can be made if there is no exempt income during the year. 5. On the other hand, Ld. DR relied upon the decision of ITAT Mumbai Bench in the case of Double dot Ltd vs DCIT, reported in [2014] 65 SOT 324 also referred to CBDT Circular No.5 of 2014 dated 11.04.2013 and contended that, even if investment in shares a…

Dystar India P.Ltd, Navi Mumbai vs. Jt CIT (OSD) 8(1), Mumbai

In the result appeal of the revenue stands dismissed and both the appeals filed by the assessee are allowed

ITA 3046/MUM/2012[2009-10]Status: DisposedITAT Mumbai27 Apr 2016AY 2009-10

Bench: Shri Amit Shukla & Shri Ramit Kochar

Section 143(3)Section 14A

…r discussing the decision of Hon’ble High Court decision in the case of Maxopp Investment Ltd vs CIT 347 ITR 272 (Del). 4. Before us, the Ld. Counsel submitted that now in wake of latest High Court decision in the case of Cheminvest Ltd. vs. CIT, reported in 378 ITR 33, no disallowance under section 14A can be made if there is no exempt income during the year. 5. On the other hand, Ld. DR relied upon the decision of ITAT Mumbai Bench in the case of Double dot Ltd vs DCIT, reported in [2014] 65 SOT 324 also referred to CBDT Circular No.5 of 2014 dated 11.04.2013 and contended that, even if investment in shares a…

Dystar India P.Ltd, Navi Mumbai vs. Jt CIT (OSD) 8(1), Mumbai

In the result appeal of the revenue stands dismissed and both the appeals filed by the assessee are allowed

ITA 3045/MUM/2012[2008-09]Status: DisposedITAT Mumbai27 Apr 2016AY 2008-09

Bench: Shri Amit Shukla & Shri Ramit Kochar

Section 143(3)Section 14A

…r discussing the decision of Hon’ble High Court decision in the case of Maxopp Investment Ltd vs CIT 347 ITR 272 (Del). 4. Before us, the Ld. Counsel submitted that now in wake of latest High Court decision in the case of Cheminvest Ltd. vs. CIT, reported in 378 ITR 33, no disallowance under section 14A can be made if there is no exempt income during the year. 5. On the other hand, Ld. DR relied upon the decision of ITAT Mumbai Bench in the case of Double dot Ltd vs DCIT, reported in [2014] 65 SOT 324 also referred to CBDT Circular No.5 of 2014 dated 11.04.2013 and contended that, even if investment in shares a…

M/S. Vikon Engineers Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1009/DEL/2013[2007-08]Status: DisposedITAT Delhi18 Apr 2016AY 2007-08

Bench: Shri R.S. Syal & Shri Sudhanshu Srivastavaay: 2007-08 M/S Vikon Engineers Pvt. Ltd., Vs Dcit, 12, Ring Road, Cc-5, Room No. 361, Lajpat Nagar-Iv, E-2, Ara Centre, New Delhi. Jhandewalan Extension, (Pan: Aabcv7701K) New Delhi. (Appellant) (Respondent) Appellant By: Shri Rajiv Saxena, Adv. Ms Sumangla Saxena, Adv. Respondent By: Shri Ram Bilash Meena, Cit Dr Date Of Hearing: 29.01.2016 Date Of Pronouncement: 18.04.2016 Order

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri Ram Bilash Meena, CIT DR
Section 132Section 14ASection 153C

…ncome during the year. He drew our attention to the Return of Income and the Computation thereof to urge this point wherein no income has been claimed as exempt. He relied on the decision of the Hon'ble Delhi High Court in the case of Cheminvest Ltd. vs CIT 378 ITR 33 (Del) for the proposition that section 14A will not apply where no exempt income is received or receivable during the relevant previous year. 6. The Ld. DR supported the orders of the authorities below and submitted that the assessee itself had made a disallowance and had not furnished any details thereof and therefore the disallowance was jus…

M/S. Minda Industries Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee are allowed whereas the appeal of the department is dismissed

ITA 5251/DEL/2011[2008-09]Status: DisposedITAT Delhi13 Apr 2016AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Prashant Maharishi

For Appellant: Shri Pradeep Dinodia, CA
Section 143(3)Section 14ASection 43(1)

…tedly and undisputedly, the assessee has not earned any exempt dividend income during both the A.Ys. The ld. AR further contended that as per the recent judgment of the Hon'ble Jurisdictional High Court of Delhi in the case of Chem Invest Pvt. Ltd reported at 378 ITR 33 [Delhi], when no exempt was earned by the assessee in the relevant A.Y and genuineness of the expenditure incurred by the assessee was not in doubt, then no disallowance should be made u/s 14A r.w.r 8D of the Rules. 21. Per contra, the ld. DR strongly supported the action of the authorities below and fairly submitted that while making disallowance…

M/S Minda Industries Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, the appeals of the assessee are allowed whereas the appeal of the department is dismissed

ITA 1506/DEL/2011[2007-08]Status: DisposedITAT Delhi13 Apr 2016AY 2007-08

Bench: Shri Chandra Mohan Garg & Shri Prashant Maharishi

For Appellant: Shri Pradeep Dinodia, CA
Section 143(3)Section 14ASection 43(1)

…tedly and undisputedly, the assessee has not earned any exempt dividend income during both the A.Ys. The ld. AR further contended that as per the recent judgment of the Hon'ble Jurisdictional High Court of Delhi in the case of Chem Invest Pvt. Ltd reported at 378 ITR 33 [Delhi], when no exempt was earned by the assessee in the relevant A.Y and genuineness of the expenditure incurred by the assessee was not in doubt, then no disallowance should be made u/s 14A r.w.r 8D of the Rules. 21. Per contra, the ld. DR strongly supported the action of the authorities below and fairly submitted that while making disallowance…

DCIT Cir 3(1), Mumbai vs. Gateway Distriparks Ltd, Mumbai

The appeal of the Revenue is dismissed

ITA 5746/MUM/2013[2010-11]Status: DisposedITAT Mumbai07 Apr 2016AY 2010-11

Bench: Shri Joginder Singh & Shri Rajendraassessment Year-2010-11 Dcit, M/S Gateway Distriparks Circle-3(1), Ltd. B 1/3, Emca House बनाम/ Room No.607, 6Th Floor, Sahid Bhagatsingh Marg, Vs. Aayakar Bhavan, Mumbai- Mumbai-400020 Pan No.Aaacg3425C (राज"व /Revenue) (""यथ"/Respondent)

Section 80I

…consequential to ground no.2. This factual matrix was not controverted by ld. DR. 4.1. Considering the totality of facts and since we have affirmed the stand of the Commissioner of Income Tax (Appeal), following the decision from Hon’ble Delhi High Court in 378 ITR 333 (supra), the impugned ground is consequential in nature and therefore, dismissed. Finally, the appeal of the Revenue is dismissed. This order was pronounced in the open in the presence of ld. representatives from both sides at the conclusion of the hearing on 06/04/2016. (Rajendra) (Joginder Singh) लेखा सद"य / ACCOUNTANT MEMBER "या"यक सद"य / JU…

DCIT Cir 3(3)(1), Mumbai vs. Siro Clinpharm P.Ltd, Mumbai

In the result, appeal of the Assessing Officer is dismissed

ITA 1493/MUM/2015[2010-11]Status: DisposedITAT Mumbai31 Mar 2016AY 2010-11
Section 144Section 14ASection 92C(3)

…04 (P&H), which has been followed by many other Hon’ble High Courts as well, such as Hon’ble Gujarat High Court in the case of CIT Vs Corrtech Energy Pvt Ltd [(2015) 372 ITR 97 (Guj) and by Hon’ble Delhi High Court in the case of Cheminvest Ltd Vs CIT [(2015) 378 ITR 33 (Del)]. Respectfully following the views of Hon’ble Courts above, we uphold the grievance of the assessee. The disallowance must stand deleted. I.T.A. Nos. 1269 amd 1493/Mum/2015 Assessment year: 2010-11 Page 5 of 7 8. Ground no. 2 is thus allowed. 9. In ground no. 3, the assessee is aggrieved of the Assessing Officer not giving credit of Rs 60…

Siro Clinpharm P.Ltd, Mumbai vs. DCIT RG 3(3)(1), Mumbai

In the result, appeal of the Assessing Officer is dismissed

ITA 1269/MUM/2015[2010-11]Status: DisposedITAT Mumbai31 Mar 2016AY 2010-11
Section 144Section 14ASection 92C(3)

…04 (P&H), which has been followed by many other Hon’ble High Courts as well, such as Hon’ble Gujarat High Court in the case of CIT Vs Corrtech Energy Pvt Ltd [(2015) 372 ITR 97 (Guj) and by Hon’ble Delhi High Court in the case of Cheminvest Ltd Vs CIT [(2015) 378 ITR 33 (Del)]. Respectfully following the views of Hon’ble Courts above, we uphold the grievance of the assessee. The disallowance must stand deleted. I.T.A. Nos. 1269 amd 1493/Mum/2015 Assessment year: 2010-11 Page 5 of 7 8. Ground no. 2 is thus allowed. 9. In ground no. 3, the assessee is aggrieved of the Assessing Officer not giving credit of Rs 60…

Apm Terminals India P.Ltd ( Formlerly Know As Maersk India P. Ltd), Mumbai vs. Asst CIT RG 6(3), Mumbai

In the result ground no. 3 is treated as allowed

ITA 3284/MUM/2013[2008-09]Status: DisposedITAT Mumbai30 Mar 2016AY 2008-09

Bench: Shri R.C. Sharma & Shri Pawan Singh: (A.Y : 2007-08)

For Appellant: Shri Niraj ShethFor Respondent: Shri D. Prabhakar Reddy (DR)
Section 143(3)Section 145Section 145A

…s no exempt income during the year under consideration, therefore, no disallowance should be made. The issue with regard to disallowance u/s 14A when there is no exempt income has been considered by the Hon'ble Delhi High Court in the case of Cheminvest Ltd., 378 ITR 33 wherein it was held that no disallowance u/s 14A should be made when there is no exempt income during the 5 M/s. Maersk India Pvt. Ltd. & APM Terminals India Pvt. Ltd. ITA Nos. 3069, 3072, 3283 & 3284/Mum/2013 year. Respectfully following the order of the Hon'ble Delhi High Court, we delete the disallowance made u/s 14A of the Income Tax Act, 19…

Apm Terminals India P.Ltd ( Formlerly Know As Maersk India P. Ltd), Mumbai vs. Asst CIT RG 6(3), Mumbai

In the result ground no. 3 is treated as allowed

ITA 3283/MUM/2013[2007-08]Status: DisposedITAT Mumbai30 Mar 2016AY 2007-08

Bench: Shri R.C. Sharma & Shri Pawan Singh: (A.Y : 2007-08)

For Appellant: Shri Niraj ShethFor Respondent: Shri D. Prabhakar Reddy (DR)
Section 143(3)Section 145Section 145A

…s no exempt income during the year under consideration, therefore, no disallowance should be made. The issue with regard to disallowance u/s 14A when there is no exempt income has been considered by the Hon'ble Delhi High Court in the case of Cheminvest Ltd., 378 ITR 33 wherein it was held that no disallowance u/s 14A should be made when there is no exempt income during the 5 M/s. Maersk India Pvt. Ltd. & APM Terminals India Pvt. Ltd. ITA Nos. 3069, 3072, 3283 & 3284/Mum/2013 year. Respectfully following the order of the Hon'ble Delhi High Court, we delete the disallowance made u/s 14A of the Income Tax Act, 19…

ACIT Cir 6(3), Mumbai vs. Maersk India P.Ltd, Mumbai

In the result ground no. 3 is treated as allowed

ITA 3072/MUM/2013[2007-08]Status: DisposedITAT Mumbai30 Mar 2016AY 2007-08

Bench: Shri R.C. Sharma & Shri Pawan Singh: (A.Y : 2007-08)

For Appellant: Shri Niraj ShethFor Respondent: Shri D. Prabhakar Reddy (DR)
Section 143(3)Section 145Section 145A

…s no exempt income during the year under consideration, therefore, no disallowance should be made. The issue with regard to disallowance u/s 14A when there is no exempt income has been considered by the Hon'ble Delhi High Court in the case of Cheminvest Ltd., 378 ITR 33 wherein it was held that no disallowance u/s 14A should be made when there is no exempt income during the 5 M/s. Maersk India Pvt. Ltd. & APM Terminals India Pvt. Ltd. ITA Nos. 3069, 3072, 3283 & 3284/Mum/2013 year. Respectfully following the order of the Hon'ble Delhi High Court, we delete the disallowance made u/s 14A of the Income Tax Act, 19…

ACIT 6(3), Mumbai vs. Apm Terminals India P.Ltd, Mumbai

In the result ground no. 3 is treated as allowed

ITA 3069/MUM/2013[2008-09]Status: DisposedITAT Mumbai30 Mar 2016AY 2008-09

Bench: Shri R.C. Sharma & Shri Pawan Singh: (A.Y : 2007-08)

For Appellant: Shri Niraj ShethFor Respondent: Shri D. Prabhakar Reddy (DR)
Section 143(3)Section 145Section 145A

…s no exempt income during the year under consideration, therefore, no disallowance should be made. The issue with regard to disallowance u/s 14A when there is no exempt income has been considered by the Hon'ble Delhi High Court in the case of Cheminvest Ltd., 378 ITR 33 wherein it was held that no disallowance u/s 14A should be made when there is no exempt income during the 5 M/s. Maersk India Pvt. Ltd. & APM Terminals India Pvt. Ltd. ITA Nos. 3069, 3072, 3283 & 3284/Mum/2013 year. Respectfully following the order of the Hon'ble Delhi High Court, we delete the disallowance made u/s 14A of the Income Tax Act, 19…

DCIT 5(2), Mumbai vs. Lahoti Overseas Ltd, Mumbai

In the result, appeal of the assessee company in ITA

ITA 3812/MUM/2012[2003-04]Status: DisposedITAT Mumbai30 Mar 2016AY 2003-04

Bench: Shri Amit Shukla & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 3812/Mum/2012 ("नधा"रण वष" / Assessment Year : 2003-04) Dy. Commissioner Of Income M/S Lahoti Overseas Ltd., बनाम/ Tax , 5(2),Room No. 571, 307, Arun Chambers, V. 5 Th Floor, Tardeo Road, Tardeo, Aayakar Bhavan, Mumbai - 400034. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./Pan : Aaacl2578 H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Yogesh TharFor Respondent: Shri Ganesh Bare (Sr.DR)
Section 133ASection 143(3)Section 147Section 148Section 151(1)

…आयकर अपील"य अ"धकरण “A” "यायपीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 3812/Mum/2012 ("नधा"रण वष" / Assessment Year : 2003-04) Dy. Commissioner of Income M/s Lahoti Overseas Ltd., बनाम/ Tax , 5(2),Room No. 571, 307, Arun Chambers, v. 5 th floor, Tardeo Road, Tardeo, Aayakar Bhavan, Mumbai - 400034. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./PAN : AAACL2578 H .. (अपीलाथ" /Appellant) (""यथ" / Respondent) आयकर अपील सं./I.T.A. No. 821/Mum/2014 ("नधा"रण वष" / Assessment Year : 2007-08)…