CIT v. Holcim India Pvt. Ltd.

272 CTR 282High Court2014#805 most cited

What is CIT v. Holcim India Pvt. Ltd. authority for?

No disallowance under Section 14A can be made when no exempt income has been earned by the assessee, and investments made for business purposes in subsidiaries do not warrant disallowance under Section 14A, even if no dividend income is earned.

128

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Holcim India Pvt. Ltd. · Section 14A · Rule 8D · exempt income · investment in subsidiary · business purpose · dividend income · disallowance

Also reported as

111 DTR 153

Sections most often in play

Section 14ASection 143(3)Section 253(3)Section 43BSection 8DSection 80-IASection 115BSection 10

Issues it is cited on

unabsorbed depreciationdisallowance u/s 14adisallowance under section 14asection 14asection 115jbsection 10section 37previous yearcompanyprescribedindiabusiness

Judgments citing CIT v. Holcim India Pvt. Ltd.

M/S Lamina Suspensions Products Ltd, Mangalore vs. The Joint Commissioner of Income Tax Range-2, Mangalore

In the result, the appeals of the assessee for Assessment Years 2012-13 and 2013-14 are partly allowed

ITA 336/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Jan 2019AY 2012-13

Bench: Shri N. V. Vasudevan & Shri Jason P Boazi.T. A. Nos.336 & 337/Bang/2018 (Assessment Years : 2012-13 & 2013-14) M/S. Lamina Suspensions Products Ltd., Vs. The Joint Commissioner Of #13-12-1394, 8Th Floor, Rambhavan Income Tax, Complex, Kokial Bail, Range -2, Mangaluru – 575 003. Mangaluru. Pan : Aaacl 3061 H Appellant Respondent Assessee By : Shri. Nagendra Sharma, Advocate Revenue By : Shri. R. N. Siddappaji, Addl. Cit Date Of Hearing : 03.01.2019 Date Of Pronouncement : 11.01.2019 O R D E R

For Appellant: Shri. Nagendra Sharma, AdvocateFor Respondent: Shri. R. N. Siddappaji, Addl. CIT
Section 10(34)Section 14A

…rt in the case of Joint Investments (P) Ltd. v. CIT, 372 ITR 694 has taken the view that disallowance u/s. 14A of the Act cannot exceed the exempt income. Similar view was expressed by the Hon'ble Delhi High Court in the case of CIT v. Holcim India Pvt. Ltd., 272 CTR 282 (Del). These decisions were considered by the Mumbai Bench of the Tribunal in the case of Future Corporate Resources Ltd v. ACIT, ITA No.4658/Mum/2015 dated 26.07.2017 relating to AY 2011-12 and it was held by the Tribunal Mumbai Bench that disallowance u/s. 14A of the Act cannot exceed the exempt income. Following the aforesaid decisions, we hol…

Pepsico India Holdings Pvt. Ltd., Gurgaon vs. ACIT, Central Circle- 7, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 6582/DEL/2017[2013-14]Status: DisposedITAT Delhi03 Dec 2018AY 2013-14

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

M/S Pepsico India Holdings Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4518/DEL/2016[2011-12]Status: DisposedITAT Delhi03 Dec 2018AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

M/S Pepsico India Holdings Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4517/DEL/2016[2010-11]Status: DisposedITAT Delhi03 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

M/S Pepsico India Holdings Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4516/DEL/2016[2010-11]Status: DisposedITAT Delhi03 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

M/S. Pepsi Foods Limited, Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 1044/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Dec 2018AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

Pepsi Foods Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 2511/DEL/2013[2008-09]Status: DisposedITAT Delhi03 Dec 2018AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…vant years in question, had directed the AO to compute the disallowance in accordance with the ratio laid down by the Hon’ble jurisdictional High Court in the case of Cheminvest Ltd vs. CIT [2015] 378 ITR 33 (Delhi High Court) and CIT vs. Holcim India (P) Ltd 272 CTR 282 (Del). 94. The learned counsel for the assessee submitted that the Hon’ble Delhi High Court in these cases had held that no disallowance under section 14A of the Act was warranted where investments were made with the objective of acquiring controlling interest in the company and not for the purposes of earning exempt income. The AO, however, did…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1392/KOL/2017[2011-12]Status: DisposedITAT Kolkata22 Nov 2018AY 2011-12

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…. 260A, the jurisdictional Calcutta High Court upheld the order of the hon'ble ITA, Kolkata and dismissed the Department’s appeal. The same view has been expressed by the High Courts at Delhi, Gujarat & Allahabad in the cases of CIT vs. Holcim India Pvt. Ltd (272 CTR 282), CIT vs. Cortech Energy Pvt Ltd. (223 taxman 130) and CIT vs. Shivam Motors (P) Ltd (230 Taxman 63) respectively. 8. In the course of appellate proceedings, the Ld. AR was therefore directed to file statement of amount disallowable as per the ratio laid down by the Calcutta High Court in the case of CIT vs. REI Agro Ltd (supra). On perusal of th…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1391/KOL/2017[2010-11]Status: DisposedITAT Kolkata22 Nov 2018AY 2010-11

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…. 260A, the jurisdictional Calcutta High Court upheld the order of the hon'ble ITA, Kolkata and dismissed the Department’s appeal. The same view has been expressed by the High Courts at Delhi, Gujarat & Allahabad in the cases of CIT vs. Holcim India Pvt. Ltd (272 CTR 282), CIT vs. Cortech Energy Pvt Ltd. (223 taxman 130) and CIT vs. Shivam Motors (P) Ltd (230 Taxman 63) respectively. 8. In the course of appellate proceedings, the Ld. AR was therefore directed to file statement of amount disallowable as per the ratio laid down by the Calcutta High Court in the case of CIT vs. REI Agro Ltd (supra). On perusal of th…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1390/KOL/2017[2009-10]Status: DisposedITAT Kolkata22 Nov 2018AY 2009-10

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…. 260A, the jurisdictional Calcutta High Court upheld the order of the hon'ble ITA, Kolkata and dismissed the Department’s appeal. The same view has been expressed by the High Courts at Delhi, Gujarat & Allahabad in the cases of CIT vs. Holcim India Pvt. Ltd (272 CTR 282), CIT vs. Cortech Energy Pvt Ltd. (223 taxman 130) and CIT vs. Shivam Motors (P) Ltd (230 Taxman 63) respectively. 8. In the course of appellate proceedings, the Ld. AR was therefore directed to file statement of amount disallowable as per the ratio laid down by the Calcutta High Court in the case of CIT vs. REI Agro Ltd (supra). On perusal of th…

Pr. Commissioner of Income Tax Delhi -7 vs. M/S. Planman Consulting Pvt. Ltd

ITA/1221/2018HC Delhi02 Nov 2018

Bench: The Due Date Of The Filing Of The Return. Accordingly, This Issue Is Covered By Decision Of This Court In Ita No.1063/2008, Commissioner Of Income Tax Vs. Aimil Ltd. Dated 23Rd December, 2009.

Section 14ASection 260A

…Tax-6, New Delhi Vs. McDonalds India Pvt. Ltd. and two decisions of this High Court quoted therein, namely, Cheminvest Ltd. Vs. Commissioner of Income-tax IV [2015] 378 ITR 33 (Delhi) and Commissioner of Income-tax –IV Vs. Holcim India Pvt. Ltd. (2014) 272 CTR 282 (Delhi). Decision of the Supreme Court in Maxopp Investment Ltd. Vs. Commissioner of Income tax, (2018) 402 ITR 640 (SC) also affirms the said view. The second issue/question relates to late deposit of Provident Fund, share of Employees State Insurance and professional tax. It is accepted that the said payments were made before the due d…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 467/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Oct 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…disallowance under section 14A of the Act is only to be made only if there is exempt income and not otherwise: . Cheminvest Ltd. v. CIT : 379 ITR 33 (Del.) • PCIT v. IL & FS Energy Development Company Ltd. : 297 CTR 452 (Del.) CIT v. Holcim India (P) Ltd.: 272 CTR 282 (Del.)"' • CIT v. Corrtech Energy Pvt. Ltd.: 372 ITR 97 (Guj.) • • CIT v. Winsome Textile Industries Ltd.: 319 ITR 204 (P&H) • CIT v. M/s Lakhani Marketing: 272 CTR 265 (P&H) • CIT v. M/s. Shivam Motors (P) Ltd.: 272 CTR 277 (All) • Redington (India) Ltd vs. ACIT: 392 ITR 633 (Mad.) • SInterglobe Enterprises v. DCIT: ITA No.1362 & 1032/Del./2013…

Asst CIT Cir 6(1)(2), Mumbai vs. Ask Investment Managers P.Ltd, Mumbai

The appeal of the Revenue is allowed for statistical

ITA 534/MUM/2017[2012-13]Status: DisposedITAT Mumbai09 Oct 2018AY 2012-13

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year 2012-13 Acit M/S Ask Investment Circle-6(1)(2), Managers Pvt. Ltd. बनाम/ R. No.536, 5Th Floor, 1St Floor Bandbox House, Vs. Aayakar Bhavan, Dr. Ab Road, Worli, M. K. Road, Churchgate, Mumbai-400030 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aafca2302P Shri Nitin Waghmode-Dr राज"व क" ओर से / Revenue By "नधा"रती क" ओर से / Assessee By Shri J.D. Mistri Sr. Advocate

Section 115JSection 14A

…at Hon’ble Delhi High Court vide order dt.02.09.2015 in the case of Cheminvest Limited v. CIT in ITA No. 749/2014 reversed the decision of Special Bench and, following the earlier decision of the Hon’ble High Court in the case of CIT v. Holcim India (P) Ltd.: 272 CTR 282, held that where no exempt income has been received by the assessee in the previous year, disallowance under section 14A of the Act is not warranted.The Hon’ble High Court has further held that reliance placed by the Special bench on the decision of the Hon’ble Supreme Court in the case of Rajendra Prasad Moody: 115 ITR 519 was misplaced. It has…

Lodha Builders Private Limited, Mumbai vs. ACIT, Cir- 6(3), Mumbai

In the result, the appeal of the assessee is partly allowed and appeal filed by

ITA 1572/MUM/2015[2008-09]Status: DisposedITAT Mumbai23 Jul 2018AY 2008-09

Bench: Shri Pawan Singh, Jm & Shri N.K. Pradhan, Am

For Appellant: Shri Vijay Mehta-ARFor Respondent: Sh. N.S. Jangpangi CIT-DR
Section 139Section 14ASection 201Section 40

…vest Ltd. vs. CIT (378 ITR 33)(Del.); 281 CTR 447 (Del.); 4. CIT vs. Shivam Motors (P.) Ltd. (272 CTR 277)(All.); 5. CIT vs. Cortech Energy (P) Ltd. (272 CTR 265)( Guj.); 6. CIT vs. Lakhani Marketing Incl. (271 CTR 265)(P&H); 7. CIT vs. Holcim India (P) Ltd. (272 CTR 282) (Del.); 8. CIT vs. Winsome Textile Industries Ltd. (319 ITR 204)(P&H); 9. CIT vs. Delite Enterprises (ITA No.110 of 2009 Bom) and 10.Vakrangee Ltd. vs. ACIT being ITA No.6988/Mum/2014 dated 10/08/2016 3 I.T.A. No.1572/Mum/2015 Assessment Year: 2008-09 ; I.T.A. No.1748/Mum/2015 Assessment Year: Lodha Builders Private Limited 2.2. On the other h…

Rose Financiers & Commercials Pvt. Ltd., Kolkata vs. ITO, Ward - 12(4), Kolkata

In the result the appeal of the assessee is allowed

ITA 753/KOL/2018[2012-13]Status: DisposedITAT Kolkata13 Jul 2018AY 2012-13

Bench: Hon’Ble Shri N.S.Saini, Am ] Assessment Year : 2012-13

For Appellant: Shri M.Satnaliwala, ARFor Respondent: Shri Sanjoy Mukherjee, Addl. CIT
Section 14A

…wing judgements that section 14A is not applicable where no dividend income was received. CIT Vs. Cortech Energy (P) Ltd. 223 Taxman I 30 (Gujarat High Court) ClT Vas. Shivam Motors (P) Ltd. 240 Taxman 63 (Allahabad High Court). CIT Vs. Holcin India (P) Ltd.(272 CTR 282) Delhi High Court. Chemin vest Ltd. Vs. CIT (61 Taxman.com 118) Delhi High Court CIT Vs. IL &. FS energy development Co. Ltd. (2017) 84 Taxman.com. 186 (Delhi)” 6. On the other hand, the Learned Departmental Representative submitted that as per CBDT Circular No.5/2014 dated 11.02.2014 relied on by the Assessing Officer ITA No.753/Kol/2018 Rose…

DCIT, Circle-2, Kolkata vs. M/S. Infinity Infotech Parks Ltd, Kolkata

In the result, the appeal of revenue is dismissed

ITA 1317/KOL/2012[2009-10]Status: DisposedITAT Kolkata14 May 2018AY 2009-10

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

Section 14A

…eive dividend income or exempt income during the relevant previous year, the disallowance u/s. 14A of the Act read with Rule 8D of the Rules is not warranted. For the aforesaid proposition, we rely on the decision in the case of CIT Vs. Holcim India Pvt. Ltd. 272 CTR 282 (Del), CIT Vs. Cartech Energy Pvt. Ltd. 223 Taxman 130 (Guj), CIT Vs. Shivam Motors 230 Taxman 63 (All), Redington India ltd. Vs. Addl. CIT 392 ITR 663 (Mad). We note that in the appeal preferred by the revenue, the assessee did not earn any exempt income during the relevant AY 2009-10, therefore, Ld. CIT(A) was justified in deleting the disallow…

Dciat 14(3)(2), Mumbai vs. Sundaram Multipap Ltd, Mumbai

In the result, the appeal of the revenue is dismissed and the cross objection filed by the assessee is allowed

ITA 5327/MUM/2015[2012-13]Status: DisposedITAT Mumbai20 Apr 2018AY 2012-13

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 14A

…392 ITR 633 (Mad)] 3. Cheminvest Ltd. v. CIT [281 CTR 447 (Del)] 4. CIT v. Shivam Motors (P) Ltd. [272 CTR 277 (All)] 5. CIT v. Corrtech Energy (P) Ltd. [272 CTR 262 (Guj)] 6. CIT v. Lakhani Marketing Incl. [272 CTR 265 (P&H)] 7. CIT v. Holcim India (P) Ltd, [272 CTR 282 (Del)] 8. CIT v. Winsome Textile Industries Ltd. (319 ITR 204 P&H) 9. CIT v. Delite Enterprises [ITA No. 110 of 2009 (Bombay High Court)] 13. He submitted that an identical issue was considered by Hon'ble Hon'ble Jurisdictional Bombay High Court in the case of Principal CIT Vs. Ballarpur Industries Limited (supra), wherein Hon'ble Bombay High Co…

DCIT Cir 3(3)(2), Mumbai vs. Tulip Hotels P.Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 5151/MUM/2015[2011-12]Status: DisposedITAT Mumbai14 Mar 2018AY 2011-12

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm Dcit Cir 3(3)(2) Vs. M/S. Tulip Hotels Pvt.Ltd., R.No.609, 6Th Floor Chandermukhi Building Aayakar Bhavan (Basement), Behind The M.K.Road, Oberoi Nariman Point Mumbai – 400 020 Mumbai – 400 021 Pan/Gir No. Aaact9446Q Appellant) .. Respondent)

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

…R 33 (Del) / 281 CTR 447 (Del)] * 3) CIT v. Shivam Motors (P) Ltd. [272 CTR 277 (All)] 12 M/s.Tulip Hotels Pvt.Ltd., 4) CIT v. Corrtech Energy (P) Ltd. [272 CTR 262 (Guj)] 5) CIT v. Lakhani Marketing Incl. [272 CTR 265 (P&H)] 6) CIT v. Holcim India (P) Ltd. [272 CTR 282 (Del)] 7) CIT v. Delite Enterprises [ITA No. 110 of 2009 Bombay High Court) 10. Only strategic investments were made by assessee, therefore, same requires to be excluded from average investment and not be considered for disallowance u/s.14A in view of the following judicial pronouncements. 1) Cheminvest Ltd. v CIT [378 ITR 33 (Del)/ 281 CTR 447 (…

Shri Viren Shantilal Shah, Ahmedabad vs. The Dy.CIT, Circle-1(2), Baroda

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

ITA 3306/AHD/2015[2012-13]Status: DisposedITAT Ahmedabad02 Feb 2018AY 2012-13

Bench: Shri Rajpal Yadav, Jm & Shri Amarjit Singh, Am

For Appellant: Prasoon Kabra, Sr. D.RFor Respondent: 10-01-2018
Section 10(34)Section 143(2)Section 14A

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘C’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JM AND SHRI AMARJIT SINGH, AM आयकर अपील सं./ITA.No. 3306/AHD/2015 ("नधा"रण वष" / Asstt Year :2012-13) Shri Viren Shantilal Shah Vs. The Dy. CIT Circle-1(2), A-58, Kunj Society, Akapuri, Baroda-390007 Vadodara-390007 (Appellant) (Respondent) Kinjal V. Shah, A.R. अपीलाथ" ओर से / Appellant by: Prasoon Kabra, Sr. D.R. ""यथ" क" ओर से/Respondent by: 10-01-2018 सुनवाई क" तार"ख / Date of Hearing 02 -02-2018 घोषणा क" तार"ख /Date of Pronouncement आदेश/O R D E R PER AMARJIT SINGH,…

ACIT, New Delhi vs. M/S. Modi Rubber Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 105/DEL/2014[2008-09]Status: DisposedITAT Delhi10 Nov 2017AY 2008-09

Bench: Smt Diva Singh & Shri B.P. Jain, [Assessment Year: 2008-09] The A.C.I.T Vs. M/S Modi Rubber Ltd Circle – 5(1) 4 – 7C, Dda Shopping Centre New Delhi New Friends Colony New Delhi Pan : Aaacm 2062 R [Appellant] [Respondent] Date Of Hearing : 18.10.2017 Date Of Pronouncement : 10.11.2017 Assessee By : Shri Rohit Jain Ms. Tejasvi Jain, Advocates Revenue By : Shri Atiq Ahmed, Sr. Dr

For Appellant: Shri Rohit JainFor Respondent: Shri Atiq Ahmed, Sr. DR
Section 14ASection 37(1)

…ted hereinbelow: 23 a) CIT Vs. Oriental Structural Engineers Pvt. Ltd 216 Taxman 92 b) Eicher Goodearth Ltd Vs. CIT 378 ITR 28 c) Intergloble Enterprises VS. DCIT ITA No. 1362 & 1032/DEL/2013 d) Cheminvest Ltd Vs. CIT 378 ITR 33 e) CIT Vs. Holcim India P Ltd 272 CTR 282 f) REI Agro Ltd Vs. DCIT 160 TTJ 107 g) ACB India Ltd Vs. ACIT 374 ITR 108 h) CIT Vs. Givo Ltd ITA No. 941/2010 i) Friends Clearing Agency P Ltd Vs. CIT 332 ITR 269 26. In that view of the matter, we do not find any infirmity in the order of the CIT(A) who has rightly deleted the disallowance to the extent as mentioned hereinabove, Thus, Ground…