M/S. Xs Real Properties Pvt Ltd., Chennai vs. ACIT, Chennai
In the result, the appeal in I
ITA 42/CHNY/2019[2014-15]Status: DisposedITAT Chennai16 Sept 2021AY 2014-15
Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 41 & 42/Chny/2019 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 M/S. Xs Real Properties P. Ltd., The Assistant Commissioner Of No. 12, South Mada Street, Vs. Income Tax, Corporate Circle 3(2), Srinagar Colony, Saidapet, Chennai. Chennai 600 015. [Pan:Aaacx0030G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj, C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai, Both Dated 28.09.2018 Relevant To The Assessment Years 2013-14 & 2014-15. Since The Assessee Has Raised Common Grounds, Both The Appeals Were Heard Together & Are Being Disposed Of By This Common Order.
For Appellant: Shri N. Arjunraj, C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl. CIT
Section 10(34)Section 115JSection 14A
…essment years and the entire interest expenditure on borrowing fund was incurred in connection with the operating revenue which had been offered to tax, no disallowance is required to be made under section 14A of the Act [CIT v. Bharti Televenture Ltd. (2011) 331 ITR 502 (Del), CIT v. Reliance Utilities & Power Ltd. (2009) 313 ITR 340 (Bom), PCIT v. Sintex Industries Ltd. (2018) 403 ITR 418 (Guj), etc.]. 7.3 In view of the above facts and circumstances, we are of the considered opinion that the Assessing Officer cannot make disallowance under section 14A r.w. Rule 8D in any count. Accordingly, we direct the Asse…
