CIT v. Catholic Syrian Bank

9 Taxmann.com 148High Court2011#4087 most cited

What is CIT v. Catholic Syrian Bank authority for?

Section 14A disallowance is applicable even in a year where exempt income was claimed, distinguishing it from cases where no exempt income was claimed.

29

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2024.

Also referred to as

CIT v. Catholic Syrian Bank · Section 14A · Rule 8D · exempt income · disallowance · indirect expenses · business expenditure

Also reported as

344 ITR 25

Issues it is cited on

rule 8d disallowancesection 61section 36(1)(viii)infrastructure facilitysection 10(34)section 14a(2)interest on securitiessection 36(1)(vii)section 251(1)eligible businesssection 251(1)(a)section 80p(2)(a)

Judgments citing CIT v. Catholic Syrian Bank

The ACIT, Gnr Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar

Appeal of the Revenue is dismissed

ITA 419/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

The ACIT, Gnr Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar

Appeal of the Revenue is dismissed

ITA 2556/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2009-10

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar vs. The Jt.CIT., Gnr Range, Gandhinagar

Appeal of the Revenue is dismissed

ITA 2473/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2009-10

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar vs. The Addl.CIT., Gandhinagar Circle, Gandhinagar

Appeal of the Revenue is dismissed

ITA 208/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

M/S. Gujarat Industrial Investment Corporation, Gandhinagar vs. The Dy.CIT., Gandhinagar Circle, Gandhinagar

Appeal of the Revenue is dismissed

ITA 1170/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2007-08

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

The Dcitgandhinagar Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation, Gandhinagar

Appeal of the Revenue is dismissed

ITA 1115/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2007-08

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ IN THE INCOME TAX APPELLATE TRIBUNAL, ‘’ B ’’BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER Sr. ITA No(s) Asst. Appeal(s) by No Year(s) Appellant vs. Respondent Appellant Respondent 1. Income Tax Appeal 2007-08 DCIT, Gandhinagar M/s. Gujarat Industrial No.1115/Ahd/2011 Circle, Block – 14, Investment Corp. Ltd., 4th Floor, Udhyog Block – 14, 6th Floor, Bhavan, Sector-11, Udhyog Bhavan, Gandhinagar – 382 Sector-11, 011. Gandhinagar – 382 011 PAN:AAACG 5304 Q 2. Income Tax Appeal 2007-08 M/s. Gujarat DCIT, No.1170/Ahd/2011 I…

M/S.Hll Lifecare Ltd(Previously Known As Hindustan Latex Ltd), Trivandrum vs. The ACIT, Trivandrum

ITA 32/COCH/2016[2011-12]Status: DisposedITAT Cochin23 Nov 2017AY 2011-12

Bench: Shri Abraham P.George, Am & Shri George George K, Jm

For Appellant: Sri. Govind ShastriFor Respondent: Sri. A.Dhanaraj, Sr.DR

…. v. ITO (121 ITD 318) while holding that the disallowance us/ 14A could be made even in an year where there was no exempt income. Learned CIT(A) had also relied on the judgments of Hon’ble jurisdictional High Court in the case of CIT v. Catholic Syrian Bank (344 ITR 25). What we find is that in the case before the Hon’ble jurisdictional High Court there was a claim of exempt income. As against this, here assessee had not claimed any exempt income. Hon’ble Delhi High Court in the case of IL&FS Energy Development Corporation Ltd. (supra), held as under:- “11. At the outset, it requires to be noticed that we are c…

M/S.Hll Lifecare Ltd(Previously Known As Hindustan Latex Ltd), Trivandrum vs. The ACIT, Trivandrum

ITA 31/COCH/2016[2010-11]Status: DisposedITAT Cochin23 Nov 2017AY 2010-11

Bench: Shri Abraham P.George, Am & Shri George George K, Jm

For Appellant: Sri. Govind ShastriFor Respondent: Sri. A.Dhanaraj, Sr.DR

…. v. ITO (121 ITD 318) while holding that the disallowance us/ 14A could be made even in an year where there was no exempt income. Learned CIT(A) had also relied on the judgments of Hon’ble jurisdictional High Court in the case of CIT v. Catholic Syrian Bank (344 ITR 25). What we find is that in the case before the Hon’ble jurisdictional High Court there was a claim of exempt income. As against this, here assessee had not claimed any exempt income. Hon’ble Delhi High Court in the case of IL&FS Energy Development Corporation Ltd. (supra), held as under:- “11. At the outset, it requires to be noticed that we are c…

M/S.Hll Lifecare Ltd(Previously Known As Hindustan Latex Ltd), Trivandrum vs. The ACIT, Trivandrum

ITA 30/COCH/2016[2009-10]Status: DisposedITAT Cochin23 Nov 2017AY 2009-10

Bench: Shri Abraham P.George, Am & Shri George George K, Jm

For Appellant: Sri. Govind ShastriFor Respondent: Sri. A.Dhanaraj, Sr.DR

…. v. ITO (121 ITD 318) while holding that the disallowance us/ 14A could be made even in an year where there was no exempt income. Learned CIT(A) had also relied on the judgments of Hon’ble jurisdictional High Court in the case of CIT v. Catholic Syrian Bank (344 ITR 25). What we find is that in the case before the Hon’ble jurisdictional High Court there was a claim of exempt income. As against this, here assessee had not claimed any exempt income. Hon’ble Delhi High Court in the case of IL&FS Energy Development Corporation Ltd. (supra), held as under:- “11. At the outset, it requires to be noticed that we are c…