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.

How many judgments cite CIT v. HDFC Bank Ltd.?

1,261 judgments on BharatTax cite CIT v. HDFC Bank Ltd. (366 ITR 505), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. HDFC Bank Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 143(3), Section 115JB, Section 37(1), Section 36(1)(iii), Section 8D.

CIT v. HDFC Bank Ltd. (366 ITR 505)

M/S P.M. Diesels Pvt. Ltd., Rajkot-Gujarat vs. The Asstt. Commr. Income Tax, Circle-2(1), Rajkot-Gujarat

In the result, appeal of the assessee is allowed

ITA 66/RJT/2020[2014-15]Status: HeardITAT Rajkot26 Jul 2022AY 2014-15

For Appellant: Shri Deepak Rindani, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R

Section 250Section 36(1)(iii)Section 40A

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT Before: Shri Waseem Ahmed, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member ITA No. 66 /Rjt/2020 Assessment Year 2014-15 M/s. P.M. Diesels Pvt. The ACIT, Ltd., Rajkot Circle-2(1), PAN: AABCN5691G Vs Rajkot (Appellant) (Respondent) Assessee by: Shri Deepak Rindani, A.R. Revenue by: Shri B.D. Gupta, Sr. D.R. Date of hearing : 29-06-2022 Date of pronouncement : 27-07-2022 आदेश/ORDER PER BENCH:- This assessee’s appeal for A.Y. 2014-15, arises from the order of the CIT(A), Rajkot-2 dated 17-01-2020, in proceedings under section 25…

M/S Meera Metal Industries, Mumbai vs. The ITO - 27(2)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 133/MUM/2021[2012-13]Status: DisposedITAT Mumbai26 Jul 2022AY 2012-13

Section 143(3)Section 36(1)(iii)

…free advances to the aforesaid two parties, hence, by placing reliance on the decision of the Hon’ble 3 M/s. Meera Metal Industries Jurisdictional High Court in the case of Reliance Power Utilities Ltd., reported in 313 ITR 340 and HDFC Bank Ltd reported in 366 ITR 505. We direct the ld. AO to delete the disallowance of interest u/s.36(1)(iii) made in the instant case. Accordingly, the grounds raised by the assessee are allowed. 4. In the result, appeal of the assessee is allowed. Order pronounced in open Court on 26/07/2022 (RAHUL CHAUDHARY) ACCOUNTANT MEMBER Mumbai; Dated 26/07/2022 KARUNA, sr.ps Copy of t…

DCIT, Corp Cir 3(1), Chennai vs. Tamilnadu Newsprint and Papers Ltd., Chennai

In the result, the appeals filed by the assessee in ITA

ITA 630/CHNY/2019[2013-14]Status: DisposedITAT Chennai22 Jul 2022AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:1048/Chny/2017 & 3499/Chny/2018 िनधा"रण वष" /Assessment Years: 2012-13 & 2014-15 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Papers Ltd., Vs. Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.:1077/Chny/2017 & 630/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 & 2013-14 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Vs. Papers Ltd., Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Vikram Vijayaraghavan, Advocate राज" की ओर से /Revenue By : Shri M. Rajan, Cit & Shri P. Sajit Kumar, Jcit सुनवाई क" तार"ख/Date Of Hearing : 19.07.2022 घोषणा क" तार"ख/Date Of Pronouncement : 22.07.2022

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri M. Rajan, CIT &

Section 10(34)Section 143(3)Section 14A

…ring funds are invested in the instruments giving rise to exempt income and once there is no such finding in the assessment order, the presumption go in favour of assessee, in view of the decision of Hon’ble Bombay High Court in the case of CIT vs. HDFC Ltd., 366 ITR 505. The ld.counsel for the assessee took us through the assessment order and the order of CIT(A). 2.3 When these facts were confronted to ld. Senior DR, he could not controvert the above fact situation but he argued that the formula prescribed under Rule 8D(2) is final and it has to be invoked in any eventuality because the assessee has earned exem…

Tamilnadu Newsprint and Papers Ltd, Chennai vs. ACIT, Corp Cir -3(1), Chennai

In the result, the appeals filed by the assessee in ITA

ITA 3499/CHNY/2018[2014-15]Status: DisposedITAT Chennai22 Jul 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:1048/Chny/2017 & 3499/Chny/2018 िनधा"रण वष" /Assessment Years: 2012-13 & 2014-15 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Papers Ltd., Vs. Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.:1077/Chny/2017 & 630/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 & 2013-14 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Vs. Papers Ltd., Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Vikram Vijayaraghavan, Advocate राज" की ओर से /Revenue By : Shri M. Rajan, Cit & Shri P. Sajit Kumar, Jcit सुनवाई क" तार"ख/Date Of Hearing : 19.07.2022 घोषणा क" तार"ख/Date Of Pronouncement : 22.07.2022

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri M. Rajan, CIT &

Section 10(34)Section 143(3)Section 14A

…ring funds are invested in the instruments giving rise to exempt income and once there is no such finding in the assessment order, the presumption go in favour of assessee, in view of the decision of Hon’ble Bombay High Court in the case of CIT vs. HDFC Ltd., 366 ITR 505. The ld.counsel for the assessee took us through the assessment order and the order of CIT(A). 2.3 When these facts were confronted to ld. Senior DR, he could not controvert the above fact situation but he argued that the formula prescribed under Rule 8D(2) is final and it has to be invoked in any eventuality because the assessee has earned exem…

ACIT, Chennai vs. Tamil Nadu Newsprint & Papers Ltd., Chennai

In the result, the appeals filed by the assessee in ITA

ITA 1077/CHNY/2017[2012-13]Status: DisposedITAT Chennai22 Jul 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:1048/Chny/2017 & 3499/Chny/2018 िनधा"रण वष" /Assessment Years: 2012-13 & 2014-15 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Papers Ltd., Vs. Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.:1077/Chny/2017 & 630/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 & 2013-14 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Vs. Papers Ltd., Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Vikram Vijayaraghavan, Advocate राज" की ओर से /Revenue By : Shri M. Rajan, Cit & Shri P. Sajit Kumar, Jcit सुनवाई क" तार"ख/Date Of Hearing : 19.07.2022 घोषणा क" तार"ख/Date Of Pronouncement : 22.07.2022

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri M. Rajan, CIT &

Section 10(34)Section 143(3)Section 14A

…ring funds are invested in the instruments giving rise to exempt income and once there is no such finding in the assessment order, the presumption go in favour of assessee, in view of the decision of Hon’ble Bombay High Court in the case of CIT vs. HDFC Ltd., 366 ITR 505. The ld.counsel for the assessee took us through the assessment order and the order of CIT(A). 2.3 When these facts were confronted to ld. Senior DR, he could not controvert the above fact situation but he argued that the formula prescribed under Rule 8D(2) is final and it has to be invoked in any eventuality because the assessee has earned exem…

Tamilnadu Newsprint and Papers Ltd., Chennai vs. ACIT, Chennai

In the result, the appeals filed by the assessee in ITA

ITA 1048/CHNY/2017[2012-13]Status: DisposedITAT Chennai22 Jul 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:1048/Chny/2017 & 3499/Chny/2018 िनधा"रण वष" /Assessment Years: 2012-13 & 2014-15 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Papers Ltd., Vs. Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.:1077/Chny/2017 & 630/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 & 2013-14 The Acit, The Tamilnadu Newsprint & Corporate Circle -3(1), Vs. Papers Ltd., Chennai – 34. No.67, Tnpl Building, Mount Road, Chennai – 600 032. Pan: Aaact 2935J (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Vikram Vijayaraghavan, Advocate राज" की ओर से /Revenue By : Shri M. Rajan, Cit & Shri P. Sajit Kumar, Jcit सुनवाई क" तार"ख/Date Of Hearing : 19.07.2022 घोषणा क" तार"ख/Date Of Pronouncement : 22.07.2022

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri M. Rajan, CIT &

Section 10(34)Section 143(3)Section 14A

…ring funds are invested in the instruments giving rise to exempt income and once there is no such finding in the assessment order, the presumption go in favour of assessee, in view of the decision of Hon’ble Bombay High Court in the case of CIT vs. HDFC Ltd., 366 ITR 505. The ld.counsel for the assessee took us through the assessment order and the order of CIT(A). 2.3 When these facts were confronted to ld. Senior DR, he could not controvert the above fact situation but he argued that the formula prescribed under Rule 8D(2) is final and it has to be invoked in any eventuality because the assessee has earned exem…

M/S. Time Technoplast Ltd., Mumbai vs. Pr. CIT-3, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 876/MUM/2021[2015-16]Status: DisposedITAT Mumbai14 Jul 2022AY 2015-16

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Time Technoplast Limited V. Pr.Cit -3 2Nd Floor, 55 Corporate Avenue Room No. 612, 6Th Floor Saki Vihar Road, Andheri (E) Aayakar Bhavan Mumbai- 400072 M.K. Road Mumbai - 400020 Pan: Aaact2783J (Appellant) (Respondent) Assessee By : Shri Gaurav Kabra Department By : Shri Rajesh Damor

For Appellant: Shri Gaurav KabraFor Respondent: Shri Rajesh Damor

Section 133ASection 143(2)Section 143(3)Section 14ASection 80I

….70,128.05 lakhs whereas the investments in the exempt income yielding security are Rs.9,063.06 lakhs. Thus the Ld. CIT(A) has rightly deleted the disallowance by following the decision of Jurisdictional High Court in the case of CIT vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom.). The Ld. CIT(A) also noted that assessee has made investments in various foreign companies that dividends whereof are taxable and therefore liable to be excluded while computing disallowance under section 14A read with rule 8D. In view of these facts, we are inclined to uphold the order of Ld. CIT(A) by dismissing the ground No.6 of the Re…

Carborundum Universal Ltd., Chennai vs. DCIT, Chennai

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

ITA 1739/CHNY/2014[2008-09]Status: DisposedITAT Chennai13 Jul 2022AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT

Section 143(3)Section 14A

…e instruments giving rise to exempt income out of interest free funds i.e., in the share of share capital, Reserves & Surplus. The ld.counsel for the assessee relied on the decision of Hon’ble High Court of Bombay in the case of CIT vs. HDFC Bank Ltd., (2014) 366 ITR 505. 5. On the other hand, the ld.Senior DR stated that the assessee has nowhere proved the nexus by filing cash flow statement that the assessee has invested the funds in the instruments giving rise to exempt income out of interest free funds. The ld.Senior DR further stated that the assessee has not taken this plea before AO or before CITA(). In co…

Indus City Scapes Constructions Pvt. Ltd., Chennai vs. ACIT, CC - 2 (2), Chennai

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

ITA 2130/CHNY/2019[2009-10]Status: DisposedITAT Chennai08 Jul 2022AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri T. Banusekar, CAFor Respondent: Shri D. Hema Bhupal, JCIT

Section 143(3)Section 36(1)(iii)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं "ी मनोज कुमार अ"वाल, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:2130/CHNY/2019 िनधा"रण वष"/Assessment Year: 2009-10 Indus Cityscapes Constructions The ACIT, Pvt. Ltd., Vs. Corporate Circle 2(2), No.5-C, Ega Trade Centre, Chennai – 34. 809, Poonamalle High Road, Kilpauk, Chennai – 600 010. PAN : AABCI 1257A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri T. Banusekar, CA ""यथ" क" ओ…

Dy CIT CC 6(4), Mumbai vs. Arshiya Ltd., Mumbai

In the result, the present appeal by Revenue (ITA No

ITA 900/MUM/2020[2014-15]Status: DisposedITAT Mumbai05 Jul 2022AY 2014-15

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Sunil Jha

Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER & The Dy. Commissioner of Income Tax, Central Circle – 6(4), Mumbai, Room No. 1925, 19th Floor, Air India Building, Nariman Point, Mumbai - 400021 [PAN: AAACA6016F] ……………. Appellant Vs Arshiya Limited, 308, Level-3, F Block, Ceejay House, Shiv Sagar Estate, Dr. Annie Besant Road, Worli, Mumbai - 400021 ……………. Respondent Appearances For the Appellant/ Department : Shri Sunil Jha For the Respondent/Assessee : Shri Piyush Chhajed Date of conclusion of hearing : 06.04.2022 Date of…

M/S Atlanta Ltd, Mumbai vs. DCIT Circle- 9 (1)(2), Mumbai

In the result, Revenue‟s appeal (ITA No

ITA 7749/MUM/2019[2016-17]Status: DisposedITAT Mumbai04 Jul 2022AY 2016-17

For Appellant: Shri Vijay MehtaFor Respondent: Shri Sunil Jha

Section 115JSection 143(3)Section 14ASection 250

…y. As per the Balance Sheet, the Share Capital and Reserves of the Assessee stood at INR 373.02 Crores and INR 379.26 Crores as on 31.03.2015 and 31.03.2016, respectively. The jurisdictional High Court has in the case of HDFC Bank Ltd. Vs. DCIT-2(3), Mumbai : 366 ITR 505 (Bombay) held that where interest free funds and interest- bearing funds are available, and the interest free funds are more than the investments, the presumption is that such investments would been made from the interest free funds. The aforesaid view stands approved by the Hon‟ble Supreme Court in the case of South Indian Bank Ltd. Vs. Commissi…

Dy CIT 9 (1)(2), Mumbai vs. Atlanta Limited, Mumbai

In the result, Revenue‟s appeal (ITA No

ITA 7695/MUM/2019[2016-17]Status: DisposedITAT Mumbai04 Jul 2022AY 2016-17

For Appellant: Shri Vijay MehtaFor Respondent: Shri Sunil Jha

Section 115JSection 143(3)Section 14ASection 250

…y. As per the Balance Sheet, the Share Capital and Reserves of the Assessee stood at INR 373.02 Crores and INR 379.26 Crores as on 31.03.2015 and 31.03.2016, respectively. The jurisdictional High Court has in the case of HDFC Bank Ltd. Vs. DCIT-2(3), Mumbai : 366 ITR 505 (Bombay) held that where interest free funds and interest- bearing funds are available, and the interest free funds are more than the investments, the presumption is that such investments would been made from the interest free funds. The aforesaid view stands approved by the Hon‟ble Supreme Court in the case of South Indian Bank Ltd. Vs. Commissi…

The Asstt. Commr. of Income Tax, Circle-1(2), Rajkot-Gujarat vs. Shri Rajkot Distt. Co. Op. Bank Ltd., Rajkot-Gujarat

ITA 385/RJT/2016[2010-11]Status: DisposedITAT Rajkot29 Jun 2022AY 2010-11

Bench: Us.

For Appellant: Shri Ajay Atri, CIT/DRFor Respondent: Shri Deepak Rindani, A.R

Section 143(3)Section 250(6)Section 6(1)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT (Conducted Through Virtual Court) Before: Ms. Annapurna Gupta, Accountant Member And Shri TR Senthil Kumar, Judicial Member Assessment Year 2010-11 The Asstt. Commissioenr The Rajkot District Co- of Income Tax, Circle- op. Bank Ltd., Jilla 1(2), Rajkot Vs Bank Bhavan, Kasturba (Appellant) Road, Rajkot PAN No:AAAAR0564K (Respondent) Appellant by : Shri Ajay Atri, CIT/DR Respondent by : Shri Deepak Rindani, A.R. Date of hearing : 01-04-2022 Date of pronouncement : 29-06-2022 आदेश/ORDER PER : ANNAPURNA GUPTA, ACCOUNTANT MEMBER:- The present appea…

Yes Bank Limited, Mumbai vs. DCIT 2 (2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3500/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jun 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

Yes Bank Ltd., Mumbai vs. DCIT 2(2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3499/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Jun 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

Yes Bank Limited, Mumbai vs. DCIT - 2(2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3498/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Jun 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3238/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jun 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3237/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Jun 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

DCIT 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3236/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Jun 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT

Section 14ASection 35DSection 40

…d for acquisition of held to maturity securities. 094. The learned authorised representative stated that that this issue is now squarely covered in favour of the assessee by the decision of the honourable Bombay High Court in case of CIT versus HDFC bank Ltd 366 ITR 505 wherein loss on revaluation of securities classified as held till maturity is a revenue expenditure. 095. The learned departmental representative vehemently supported the order of the learned assessing officer. 096. We have carefully considered the rival contention and perused the orders of the lower authorities. We fully agree with the learned…

Addi. CIT., Spl Range- 9, New Delhi vs. Tourism Finance Corporation of India Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3755/DEL/2019[2016-17]Status: DisposedITAT Delhi27 Jun 2022AY 2016-17

Bench: Dr. B. R. R. Kumarshri Yogesh Kumar Us

For Appellant: Sh. Sanjay Kumar, Sr. DRFor Respondent: None

Section 14ASection 14A(1)

…pared to investment. Hence, there is no case of apportioning the interest expenditure for the purpose of disallowance u/s 14A r.w. Rule 8D(2)(i)&(ii). 12. We are in agreement with the decision of the ld. CIT(A) who relied on the case of CIT v. HDFC Bank Ltd. 366 ITR 505 (Bombay) wherein Hon’ble Court has: “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 IT AT in the present case is that the Assessee's own funds and other non-interest bearing funds were more than the investment in the tax-fre…

CIT v. HDFC Bank Ltd.

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

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. HDFC Bank Ltd.

M/S P.M. Diesels Pvt. Ltd., Rajkot-Gujarat vs. The Asstt. Commr. Income Tax, Circle-2(1), Rajkot-Gujarat

M/S Meera Metal Industries, Mumbai vs. The ITO - 27(2)(3), Mumbai

DCIT, Corp Cir 3(1), Chennai vs. Tamilnadu Newsprint and Papers Ltd., Chennai

Tamilnadu Newsprint and Papers Ltd, Chennai vs. ACIT, Corp Cir -3(1), Chennai

ACIT, Chennai vs. Tamil Nadu Newsprint & Papers Ltd., Chennai

Tamilnadu Newsprint and Papers Ltd., Chennai vs. ACIT, Chennai

M/S. Time Technoplast Ltd., Mumbai vs. Pr. CIT-3, Mumbai

Carborundum Universal Ltd., Chennai vs. DCIT, Chennai

Indus City Scapes Constructions Pvt. Ltd., Chennai vs. ACIT, CC - 2 (2), Chennai

Dy CIT CC 6(4), Mumbai vs. Arshiya Ltd., Mumbai

M/S Atlanta Ltd, Mumbai vs. DCIT Circle- 9 (1)(2), Mumbai

Dy CIT 9 (1)(2), Mumbai vs. Atlanta Limited, Mumbai

The Asstt. Commr. of Income Tax, Circle-1(2), Rajkot-Gujarat vs. Shri Rajkot Distt. Co. Op. Bank Ltd., Rajkot-Gujarat

Yes Bank Limited, Mumbai vs. DCIT 2 (2)(2), Mumbai

Yes Bank Ltd., Mumbai vs. DCIT 2(2)(2), Mumbai

Yes Bank Limited, Mumbai vs. DCIT - 2(2)(2), Mumbai

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

DCIT 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

Addi. CIT., Spl Range- 9, New Delhi vs. Tourism Finance Corporation of India Ltd., New Delhi