CIT v. HDFC Bank Ltd.

366 ITR 505High Court2014#34 most cited

What is CIT v. HDFC Bank Ltd. authority for?

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

1,261

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v HDFC Bank Ltd · 366 ITR 505 · Section 14A disallowance · interest expenditure · exempt income · interest-free funds · own funds · presumption · sufficiency of funds · dividend income · Rule 8D

Also reported as

49 Taxmann.com 335226 Taxmann 132107 DTR 140

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 37(1)Section 36(1)(iii)Section 8DSection 10(34)Section 148

Issues it is cited on

disallowance of interest expendituredisallowance under section 14adisallowance u/s 14asection 14abook profitsrevenue expendituresection 115jsection 115jbsection 32capital expendituresection 37(1)section 36

Judgments citing CIT v. HDFC Bank Ltd.

DCIT-3(1)(1), MUMBAI, AAYAKAR BHAWAN vs. EXPORT IMPORT BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 9469/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Mar 2026AY 2020-21

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9469/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2020-21) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 10(34)Section 143(3)Section 14ASection 250

…rities were only Rs. 169,39,49,514/-. The case of the assessee is squarely covered by the decisions of the Jurisdictional High Court in the following cases: 1. CIT vs. Reliance Utilities and Power Ltd. (2009) 313 ITR 340 (Bom) 2. CIT vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) COM 3. HDFC Bank Ltd. vs. DCIT (2016) 383 ITR 529 (Bom) 8. We are, therefore, inclined to set aside the order of Ld. CIT(A) on this issue and delete the disallowance made by the AO under rule 8D2(ii) of Rs.7,93,07,972/-." Generally interest bearing borrowed funds had been invested in assets having potential of generating taxable income. Hen…

DCIT-3(1)(1), MUMBAI, AAYAKAR BHAWAN vs. EXPORT IMPORT BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 9468/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Mar 2026AY 2019-20

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9469/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2020-21) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 10(34)Section 143(3)Section 14ASection 250

…rities were only Rs. 169,39,49,514/-. The case of the assessee is squarely covered by the decisions of the Jurisdictional High Court in the following cases: 1. CIT vs. Reliance Utilities and Power Ltd. (2009) 313 ITR 340 (Bom) 2. CIT vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) COM 3. HDFC Bank Ltd. vs. DCIT (2016) 383 ITR 529 (Bom) 8. We are, therefore, inclined to set aside the order of Ld. CIT(A) on this issue and delete the disallowance made by the AO under rule 8D2(ii) of Rs.7,93,07,972/-." Generally interest bearing borrowed funds had been invested in assets having potential of generating taxable income. Hen…

DCIT-3(1)(1), MUMBAI, AAYAKAR BHAWAN vs. EXPORT IMPORT BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018–

ITA 9467/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9469/Mum/2025 (Assessment Year: 2018-19) (Assessment Year: 2020-21) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 10(34)Section 143(3)Section 14ASection 250

…rities were only Rs. 169,39,49,514/-. The case of the assessee is squarely covered by the decisions of the Jurisdictional High Court in the following cases: 1. CIT vs. Reliance Utilities and Power Ltd. (2009) 313 ITR 340 (Bom) 2. CIT vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) COM 3. HDFC Bank Ltd. vs. DCIT (2016) 383 ITR 529 (Bom) 8. We are, therefore, inclined to set aside the order of Ld. CIT(A) on this issue and delete the disallowance made by the AO under rule 8D2(ii) of Rs.7,93,07,972/-." Generally interest bearing borrowed funds had been invested in assets having potential of generating taxable income. Hen…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7855/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Mar 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR
Section 14A

…pt income yielding investment has not been disputed by the Departmental Authorities. Therefore, applying ratio laid down by the Hon'ble Jurisdictional High Court in HDFC Bank Ltd. v/s DCIT, [2016] 383 ITR 529 (Bom.) and CIT v/s HDFC Bank Ltd. v/s DCIT, [2014] 366 ITR 505 (Bom.), we hold that no disallowance of interest expenditure under rule 8D(2)(ii) can be made. As far as disallowance of administrative expenditure under rule 8D(2)(iii) is concerned, it is the contention of the assessee that one of the employee is looking after the investment activity. Therefore, the salary cost of the employee has already been…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7854/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Mar 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR
Section 14A

…pt income yielding investment has not been disputed by the Departmental Authorities. Therefore, applying ratio laid down by the Hon'ble Jurisdictional High Court in HDFC Bank Ltd. v/s DCIT, [2016] 383 ITR 529 (Bom.) and CIT v/s HDFC Bank Ltd. v/s DCIT, [2014] 366 ITR 505 (Bom.), we hold that no disallowance of interest expenditure under rule 8D(2)(ii) can be made. As far as disallowance of administrative expenditure under rule 8D(2)(iii) is concerned, it is the contention of the assessee that one of the employee is looking after the investment activity. Therefore, the salary cost of the employee has already been…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7853/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR
Section 14A

…pt income yielding investment has not been disputed by the Departmental Authorities. Therefore, applying ratio laid down by the Hon'ble Jurisdictional High Court in HDFC Bank Ltd. v/s DCIT, [2016] 383 ITR 529 (Bom.) and CIT v/s HDFC Bank Ltd. v/s DCIT, [2014] 366 ITR 505 (Bom.), we hold that no disallowance of interest expenditure under rule 8D(2)(ii) can be made. As far as disallowance of administrative expenditure under rule 8D(2)(iii) is concerned, it is the contention of the assessee that one of the employee is looking after the investment activity. Therefore, the salary cost of the employee has already been…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7852/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Mar 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR
Section 14A

…pt income yielding investment has not been disputed by the Departmental Authorities. Therefore, applying ratio laid down by the Hon'ble Jurisdictional High Court in HDFC Bank Ltd. v/s DCIT, [2016] 383 ITR 529 (Bom.) and CIT v/s HDFC Bank Ltd. v/s DCIT, [2014] 366 ITR 505 (Bom.), we hold that no disallowance of interest expenditure under rule 8D(2)(ii) can be made. As far as disallowance of administrative expenditure under rule 8D(2)(iii) is concerned, it is the contention of the assessee that one of the employee is looking after the investment activity. Therefore, the salary cost of the employee has already been…

M/S. BANK OF AMERICAN , N.A,MUMBAI vs. THE JT DIT (I.T)3, MUMBAI

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

ITA 4154/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001
For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

…bonds, as noted in the foregoing paragraphs, it is sufficiently evident that\nthe assessee's own funds were more than the investments for earning exempt\nincome. We find that the Hon'ble Jurisdictional High Court in CIT v/s HDFC\nBank Ltd., reported in [2014] 366 ITR 505 (Bom.), held that where assessee's\nown funds and other non-interest bearing funds were more than the\ninvestment in tax-free securities, no disallowance under section 14A of the\nAct can be made. We further find that the Hon'ble Supreme Court in South\nIndian Bank Ltd. v/s CIT, reported in [2021] 438 ITR 001 (SC) held that\ndisallowance under se…

THE DY DIT (I.T) 1(1), MUMBAI vs. M/S. BANK OF AMERICA N.A., MUMBAI

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

ITA 4090/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001
For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

…bonds, as noted in the foregoing paragraphs, it is sufficiently evident that\nthe assessee's own funds were more than the investments for earning exempt\nincome. We find that the Hon'ble Jurisdictional High Court in CIT v/s HDFC\nBank Ltd., reported in [2014] 366 ITR 505 (Bom.), held that where assessee's\nown funds and other non-interest bearing funds were more than the\ninvestment in tax-free securities, no disallowance under section 14A of the\nAct can be made. We further find that the Hon'ble Supreme Court in South\nIndian Bank Ltd. v/s CIT, reported in [2021] 438 ITR 001 (SC) held that\ndisallowance under se…

BOMBAY MINERALS LIMITED,KHAMBHALIA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue

ITA 5410/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

…herefore, no disallowance for interest on proportionate basis was roportionate basis was called for. The Ld. called for. The Ld. CIT(A) relied on the decision of the Hon’ble relied on the decision of the Hon’ble Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 and CIT v. Reliance U and CIT v. Reliance Utilities and Power Ltd. 313 ITR 340 and ilities and Power Ltd. 313 ITR 340 and accordingly accordingly deleted deleted the the disallowance disallowance for for indirect indire interest…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CICLE-3(3), MUMBAI, MUMBAI vs. BOMBAY MINERALS LIMITED, GUJARAT

In the result, appeal of the Revenue

ITA 5409/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

…herefore, no disallowance for interest on proportionate basis was roportionate basis was called for. The Ld. called for. The Ld. CIT(A) relied on the decision of the Hon’ble relied on the decision of the Hon’ble Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 Bombay High Court in the case of HDFC Bank Ltd. 366 ITR 505 and CIT v. Reliance U and CIT v. Reliance Utilities and Power Ltd. 313 ITR 340 and ilities and Power Ltd. 313 ITR 340 and accordingly accordingly deleted deleted the the disallowance disallowance for for indirect indire interest…

BOMBAY MINERALS LIMITED,KHAMBHALIYA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue for AY 2016-17 is\ndismissed whereas appeal of the assessee for AY 2016-17 is partly\nallowed and appeal for AY 2018-19 is dismissed

ITA 5408/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17
Section 143(3)Section 14ASection 35Section 35(1)(i)Section 36(1)(iii)

…g sufficient own\nfunds for investment in exempted income earning shares and\ntherefore, no disallowance for interest on proportionate basis was\ncalled for. The Ld. CIT(A) relied on the decision of the Hon'ble\nBombay High Court in the case of HDFC Bank Ltd. 366 ITR 505\nand CIT v. Reliance Utilities and Power Ltd. 313 ITR 340 and\naccordingly deleted the disallowance for indirect interest\nexpenditure.\n5.3 But in respect of administrative expenses, the Ld. CIT(A)\nsustained the disallowance at the rate of 0.5% of the average\ninvestment. Following the decision of the Special Bench in Vireet\nInvestment Ltd. re…

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. VASCON ENGINEERS LIMITED, PUNE

In the result, Appeal of the Revenue is Dismissed

ITA 1105/PUN/2025[2013-14]Status: DisposedITAT Pune27 Jan 2026AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1105/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 Deputy Commissioner Vs. Vascon Engineers Limited, Of Income Tax, Pune. Vascon Weikfileld Chamber, Opposite Hyatt Hotel, Nagar Road, Pune – 411014. Pan: Aaacv1249F Appellant/ Revenue Respondent /Assessee Assessee By Shri Ajit Tolani & Darpan Kriplani Revenue By Smt. Indira R. Adakil – Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 05.02.2025Emanating From The Assessment Order Under Section 143(3) R.W.S 144C(3/4) Of The Act, 1961 Dated 23.01.2017 For The A.Y.2013-14. The Revenue Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 14ASection 14A(2)Section 250Section 36(1)(u)

…d arise that investments would be out of the interest- free fund generated or available with the company, if the interest-free funds were sufficient to meet the investments.” Unquote. 2.5) Hon’ble Bombay High Court in the case of CIT Vs. HDFC Bank Ltd [2014] 366 ITR 505 (Bombay), following the earlier decision in the case of Reliance Utilities & Power Ltd has held as under : Quote, “5. We find that the facts of the present case are squarely covered by the judgment in the case of Reliance Utilities & Power Ltd. (supra). The finding of fact given by the ITAT in the present case is 5 that the Assessee's own funds a…

WARANA INDUSRIES LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1, , KOLHAPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Cross Objection filed by the assessee is dismissed

ITA 1285/PUN/2019[2014-15]Status: DisposedITAT Pune22 Jan 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

For Appellant: None (written submissions filed)For Respondent: Shri Manish Mehta, Addl.CIT
Section 143(3)Section 36(1)Section 36(1)(iii)

…02 taxmann.com 52 (SC) iv) PCIT vs. Reebok India Company (2018) 103 CCH 28 (Del) v) M/s. Garuda Plant Product Ltd. Vs. DCIT vide ITA Nos.1539/PUN/2016 and 2966/PUN/2016 order dated 27.06.2019 for assessment years 2012-13 and 2013-14 vi) HDFC Bank Ltd vs. DCIT 366 ITR 505 11. The Ld. DR on the other hand heavily relied on the order of the Ld. CIT(A). 12. We have perused the written submissions filed by the Ld. Counsel for the assessee and heard the Ld. DR. So far as the first issue i.e. disallowance of interest to the tune of Rs.27,01,163/- is concerned, it is the case of the assessee that the same is paid again…

ACIT CIRCLE-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

ITA 302/RAN/2017[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M Vs. Acit, Circle-1, Dhanbad & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / Order Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

For Appellant: Shri M.K.ChowdharyFor Respondent: Shri Rajib Jain, CIT-DR
Section 143(3)Section 14ASection 300Section 32(2)

…n that sufficient fund was available with the assessee and thus, no disallowance is called for under Rule 8D(2) of the Rules. Ld. CIT(A) relied on various decisions to reach the said conclusion namely, in the cases of CIT Vs. HDFC Bank Ltd. reported in [2014] 366 ITR 505 (Bombay), CIT Vs. Hero Cycles Ltd. reported in [2010] 323 ITR 518 (Punjab & Haryana), CIT Vs. Walfort Share & Stock Brokers (P.) Ltd. reported in [2010] 326 ITR 1 (SC) and CIT Vs. Reliance Utilities & Power Ltd. reported in [2009] 313 ITR 340 (Bombay). Considering these facts and the ratio laid down in the various decisions, we are inclined to up…

ACIT CIR-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

ITA 300/RAN/2017[09-10]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Hon'Ble Itat - By It Department Si No.

Section 1Section 143(3)Section 14ASection 32(2)

…n that sufficient fund was available with the assessee and thus, no disallowance is called for under Rule 8D(2) of the Rules. Ld. CIT(A) relied on various decisions to reach the said conclusion namely, in the cases of CIT Vs. HDFC Bank Ltd. reported in [2014] 366 ITR 505 (Bombay), CIT Vs. Hero Cycles Ltd. reported in [2010] 323 ITR 518 (Punjab & Haryana), CIT Vs. Walfort Share & Stock Brokers (P.) Ltd. reported in [2010] 326 ITR 1 (SC) and CIT Vs. Reliance Utilities & Power Ltd. reported in [2009] 313 ITR 340 (Bombay). Considering these facts and the ratio laid down in the various decisions, we are inclined to up…

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

ITA 294/RAN/2017[12-13]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Hon'Ble Itat - By It Department Si No.

Section 1Section 143(3)Section 14ASection 32(2)

…n that sufficient fund was available with the assessee and thus, no disallowance is called for under Rule 8D(2) of the Rules. Ld. CIT(A) relied on various decisions to reach the said conclusion namely, in the cases of CIT Vs. HDFC Bank Ltd. reported in [2014] 366 ITR 505 (Bombay), CIT Vs. Hero Cycles Ltd. reported in [2010] 323 ITR 518 (Punjab & Haryana), CIT Vs. Walfort Share & Stock Brokers (P.) Ltd. reported in [2010] 326 ITR 1 (SC) and CIT Vs. Reliance Utilities & Power Ltd. reported in [2009] 313 ITR 340 (Bombay). Considering these facts and the ratio laid down in the various decisions, we are inclined to up…

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

ITA 293/RAN/2017[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (Α.Υ :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

For Appellant: Shri M.K.ChowdharyFor Respondent: Shri Rajib Jain, CIT-DR
Section 1Section 143(3)Section 14ASection 32(2)

…n that sufficient fund was available with the assessee and thus, no disallowance is called for under Rule 8D(2) of the Rules. Ld. CIT(A) relied on various decisions to reach the said conclusion namely, in the cases of CIT Vs. HDFC Bank Ltd. reported in [2014] 366 ITR 505 (Bombay), CIT Vs. Hero Cycles Ltd. reported in [2010] 323 ITR 518 (Punjab & Haryana), CIT Vs. Walfort Share & Stock Brokers (P.) Ltd. reported in [2010] 326 ITR 1 (SC) and CIT Vs. Reliance Utilities & Power Ltd. reported in [2009] 313 ITR 340 (Bombay). Considering these facts and the ratio laid down in the various decisions, we are inclined to up…

M/S BHARAT COOKING COAL LIMITED ,DHANBAD vs. ACIT CIR-1 , DHANBAD

In the result, both appeals of revenue and the cross objections of the assessee are dismissed and appeals of assessee in ITA No

ITA 291/RAN/2017[09-10]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011-

For Appellant: Shri M.K.ChowdharyFor Respondent: Shri Rajib Jain, CIT-DR
Section 32(2)

…n that sufficient fund was available with the assessee and thus, no disallowance is called for under Rule 8D(2) of the Rules. Ld. CIT(A) relied on various decisions to reach the said conclusion namely, in the cases of CIT Vs. HDFC Bank Ltd. reported in [2014] 366 ITR 505 (Bombay), CIT Vs. Hero Cycles Ltd. reported in [2010] 323 ITR 518 (Punjab & Haryana), CIT Vs. Walfort Share & Stock Brokers (P.) Ltd. reported in [2010] 326 ITR 1 (SC) and CIT Vs. Reliance Utilities & Power Ltd. reported in [2009] 313 ITR 340 (Bombay). Considering these facts and the ratio laid down in the various decisions, we are inclined to up…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…43(1) for the purpose of\ncalculation of depreciation etc.\"\n\nNo question of law, therefore, arises in this respect.\n\n12.\nQuestion No.3 itself records that the issue at hand is\ncovered by the decision of this Court in case of HDFC_v/s.\nDCIT reported in 366 ITR 505 but that, the department has not\naccepted the decision of the High Court. In that view, this\nquestion also is not required to be entertained.”\n\n18. Now once it has been clearly held in the decision of this\nTribunal in assessee's own case for A.Y. 2015-16 that the\nsubsidy received by assessee is not relatable either directly or\nindirectly t…

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CIT v. HDFC Bank Ltd. (366 ITR 505) — Cited in 1,261 Judgments | BharatTax