CIT v. Essar Tele

3 SCC 253Reported decision2018#2452 most cited

What is CIT v. Essar Tele authority for?

Rules and notifications issued under fiscal statutes apply prospectively unless expressly stated otherwise. This principle was affirmed in the context of disallowance under Section 14A of the Income Tax Act.

48

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2025.

Also referred to as

CIT v. Essar Teleholdings Limited · Essar Tele · 3 SCC 253 · 300 CTR 561 · Section 14A disallowance · Rule 8D · prospective application of rules · fiscal statutes notifications · no exempt income disallowance · Supreme Court 2018

Also reported as

300 CTR 561

Sections most often in play

Section 142(1)Section 132Section 153ASection 234BSection 271(1)(c)Section 69Section 143(2)Section 163

Issues it is cited on

section 90(3)section 65(b)section 65b(4)section 9(1)(ii)section 163section 276section 80absection 134section 108section 153b(1)section 73azadi bachao andolan

Judgments citing CIT v. Essar Tele

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5350/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16
Section 115JSection 143(3)Section 14ASection 250

…il Industry Development Board (SLP (Civil) No.\n2755/2019) has dismissed the SLP filed by the Revenue against the judgement of the\nHon'ble Delhi High Court dated 16.02.2018 by relying upon its decision in the case of\nCIT vs Essar Teleholdings Limited (2018) 3 SCC 253. The Hon'ble Delhi High Court had\nruled that, in absence of any exempt income, disallowance u/s 14A of the Act of any\namount was not permissible. In arriving at this conclusion, the Hon'ble Delhi High Court\nhad relied upon its earlier decision in the case of Cheminvest Ltd. vs CIT (378 ITR 33).\nThe relevant extracts of the judgement are as unde…

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5349/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, SR DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 250

…s Oil Industry Development Board (SLP (Civil) No. 2755/2019) has dismissed the SLP filed by the Revenue against the judgement of the Hon’ble Delhi High Court dated 16.02.2018 by relying upon its decision in the case of CIT vs Essar Teleholdings Limited (2018) 3 SCC 253. The Hon’ble Delhi High Court had ruled that, in absence of any exempt income, disallowance u/s 14A of the Act of any amount was not permissible. In arriving at this conclusion, the Hon'ble Delhi High Court had relied upon its earlier decision in the case of Cheminvest Ltd. vs CIT (378 ITR 33). The relevant extracts of the judgement are as under: 1…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7760/DEL/2017[2012-13]Status: DisposedITAT Delhi12 Jun 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7759/DEL/2017[2011-12]Status: DisposedITAT Delhi12 Jun 2024AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7758/DEL/2017[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7757/DEL/2017[2009-10]Status: DisposedITAT Delhi12 Jun 2024AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7756/DEL/2017[2008-09]Status: DisposedITAT Delhi12 Jun 2024AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6769/DEL/2017[2007-08]Status: DisposedITAT Delhi12 Jun 2024AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6767/DEL/2017[2006-07]Status: DisposedITAT Delhi12 Jun 2024AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6744/DEL/2017[2007-08]Status: DisposedITAT Delhi12 Jun 2024AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6743/DEL/2017[2006-07]Status: DisposedITAT Delhi12 Jun 2024AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3627/DEL/2016[2012-13]Status: DisposedITAT Delhi12 Jun 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3626/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Jun 2024AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3625/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3624/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Jun 2024AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3623/DEL/2016[2008-09]Status: DisposedITAT Delhi12 Jun 2024AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

ACIT, NEW DELHI vs. SH. RAJINDER KUMAR, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3368/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…n'ble Bombay High Court in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, [2010] 328 ITR 81, dated 12.08.2010 (Relevant para 65, 66 & 67, Page 638-676 of case law compendium, Volume 3.2) and the ruling of Hon'ble Supreme Court in CIT v. Essar Teleholdings Ltd., [2018] 300 CTR 561 dated 31.01.2018 (Relevant para: 23 & 48, Page 677-692 of case law compendium, Volume 3.2. These judgements were no doubt in the context of Rule 8D and Section 14A of the Act and not in the context of Notification 91/2008 dated 28.8.2008. However, these judgements have held that the Rules/notifications issued under the fiscal statutes will be, un…

M/S MFAR DEVELOPERS PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(3) , BANGALORE

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

ITA 385/BANG/2023[2017-18]Status: DisposedITAT Bangalore06 Sept 2023AY 2017-18

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: S/Shri C.R. Krishna & Sachin Mehta, CAsFor Respondent: Shri Saravanan B., CIT(DR)(ITAT), Bengaluru
Section 14ASection 32Section 36(1)Section 36(1)(iii)Section 37(1)

…ubmitted copy of Supreme Court's judgment in Oil Industry Development Board v. PCIT in support of his claim. It is seen that in this order Supreme Court has simply refused to grant special leave in view of its earlier judgment in CIT v. Essar Teleholdings Ltd 3 SCC 253. As stated in Para 2 and 3 of the judgment Page 10 of 13 in CIT vs. Essar Teleholdings Ltd (2018) 3 SCC 253, the only two questions answered in the judgment were: (i) "Whether sub section (2) and sub section (3) of Section 14A inserted with effect from 01.04.2007 will apply to all pending assessments? (ii) Whether Rule 8D is retrospectively applic…

ELARA CAPITAL (INDIA) PRIVATE LIMITED,MUMBAI vs. ACIT- CIRCLE 6(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 1569/MUM/2023[2017-18]Status: DisposedITAT Mumbai31 Jul 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Elara Capital (India) Pvt. Ltd., The Acit-Circle 6(2)(2), Tower 3, 21St Floor, One Room No. 506, 5Th Floor, Vs. International Center, Senapati Aayakar Bhavan, Maharshi Bapat Marg, Elphinstone Karve Road, Mumbai- Road (West), Mumbai-400013. 400020. Pan No. Aabce 6487 B Appellant Respondent

For Appellant: Mr. Milind DattaniFor Respondent: Mr. P.D. Chogule (Addl. CIT)
Section 14A

…rt dated 16 ble Delhi High Court dated 16.02.2018 by relying 2018 by relying upon its decision in the case of CIT vs Essar Teleholdings s decision in the case of CIT vs Essar Teleholdings s decision in the case of CIT vs Essar Teleholdings Limited (2018 2018) 3 SCC 253. The Hon’ble Delhi High Court had ble Delhi High Court had ruled that, in absence of any exempt income, disallowance u/s ruled that, in absence of any exempt income, disallowance u ruled that, in absence of any exempt income, disallowance u 14A of the Act of any amount was not permissible. In arriving 14A of the Act of any amount was not permissibl…

PR. COMMISSIONER OF INCOME TAX-7 vs. M/S RHC HOLDINGS PRIVATE LIMITED (EARLIER KNOWN AS M/S RANBAXY HOLDING COMPANY)

ITA - 108 / 2023HC Delhi23 Feb 2023
Section 10(34)Section 14A

…1 In this context, Mr Zoheb Hossain, who appears on behalf of the appellant/revenue, does not dispute this aspect of the matter, in view of the judgment rendered by the Supreme Court in Commissioner of Income Tax 5 Mumbai Vs. Essar Teleholdings Ltd. (2018) 3 SCC 253. 17. Given the aforesaid position, we are not inclined to interfere with the impugned order, as according to us, no substantial question of law arises for consideration. 18. This appeal is, accordingly, dismissed. Digitally Signed By:PREM MOHAN CHOUDHARY Signing Date:24.03.2023 20:19:53 Signature Not Verified NEUTRAL CITATION NO:2023:DHC:2…

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