How many judgments cite CIT v. Reliance Industries Ltd.?

501 judgments on BharatTax cite CIT v. Reliance Industries Ltd. (410 ITR 466), spanning 2016 to 2026.

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

It is most often cited in judgments turning on Section 36(1)(iii), Section 14A, Section 143(3), Section 1961, Section 40(a)(ia), Section 1962.

CIT v. Reliance Industries Ltd.

410 ITR 466Supreme Court of India2019#137 most cited

What is CIT v. Reliance Industries Ltd. authority for?

When mixed funds are available, interest-free advances are presumed to be made from the assessee's own interest-free funds, preventing disallowance of interest expenditure under section 36(1)(iii). This principle also applies to section 14A disallowance, where interest expenditure is not disallowed if surplus funds are available and no direct nexus is established with borrowed funds for investments earning exempt income.

501

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Reliance Industries Ltd. · 410 ITR 466 · section 36(1)(iii) · section 14A · interest free advances · disallowance of interest expenditure · mixed funds presumption · interest free funds · commercial expediency · disallowance for exempt income

Also reported as

102 Taxmann.com 52307 CTR 121261 Taxmann 165175 DTR 1

Sections most often in play

Section 36(1)(iii)Section 14A Section 143(3)Section 1961 Section 40(a)(ia)Section 1962 Section 143(2)Section 8D

Issues it is cited on

interest free advances section 36(1)(iii)disallowance of interest expenditure weighted deduction section 35(2ab)commercial expediency section 14a(2)disallowance under section 14a disallowance u/s 14a business expediency put to use section 36(1)

Judgments citing CIT v. Reliance Industries Ltd.

Excel Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 6(3), Mumbai

The appeal is allowed

ITA 915/MUM/2018[2014-15]Status: DisposedITAT Mumbai09 Jan 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Kirit Kamdar, ARFor Respondent: Shri Suresh Periasamy, DR

Section 115JSection 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM ITA Nos. 5431/Mum/2017 (Assessment Year 2010-11) ITA Nos. 5432/Mum/2017 (Assessment Year 2011-12) DCIT M/s Excel Industries Central Circle 6(3) Limited Room No.1926, 184/187, Excel Estate, 19th Floor, S.V. Road, Vs. Air India Building, Jogeshwari (West) Nariman Point, Mumbai-400 102 Mumbai-400 021 (Appellant) (Respondent) PAN No. AAACE2488F ITA Nos. 5473/Mum/2017 (Assessment Year 2011-12) ITA No. 914/Mum/2018 (Assessment Year 2013-14) ITA No. 6444/Mum/2018 (Assessment Year 2015-16) DCIT M/s E…

Excel Industries Limited, Mumbai vs. DCIT - CC- 6(3), Mumbai

The appeal is allowed

ITA 6444/MUM/2018[2015-16]Status: DisposedITAT Mumbai09 Jan 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Kirit Kamdar, ARFor Respondent: Shri Suresh Periasamy, DR

Section 115JSection 14A

Deputy Commissioner of Income Central Circle-6(3), Mumbai vs. M/S.Excel Industries Limited, Mumbai

The appeal is allowed

ITA 5432/MUM/2017[2011-12]Status: DisposedITAT Mumbai09 Jan 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Kirit Kamdar, ARFor Respondent: Shri Suresh Periasamy, DR

Section 115JSection 14A

Deputy Commissioner of Income Central Circle-6(3), Mumbai vs. M/S.Excel Industries Limited, Mumbai

The appeal is allowed

ITA 5431/MUM/2017[2010-11]Status: DisposedITAT Mumbai09 Jan 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Kirit Kamdar, ARFor Respondent: Shri Suresh Periasamy, DR

Section 115JSection 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM ITA Nos. 5431/Mum/2017 (Assessment Year 2010-11) ITA Nos. 5432/Mum/2017 (Assessment Year 2011-12) DCIT M/s Excel Industries Central Circle 6(3) Limited Room No.1926, 184/187, Excel Estate, 19th Floor, S.V. Road, Vs. Air India Building, Jogeshwari (West) Nariman Point, Mumbai-400 102 Mumbai-400 021 (Appellant) (Respondent) PAN No. AAACE2488F ITA Nos. 5473/Mum/2017 (Assessment Year 2011-12) ITA No. 914/Mum/2017 (Assessment Year 2013-14) ITA No. 6444/Mum/2018 (Assessment Year 2015-16) DCIT M/s E…

ACIT, New Delhi vs. M/S. India Bulls Power Ltd., New Delhi

The appeals are dismissed in regard to the first question

ITA 2013/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Jan 2023AY 2011-12

Bench: Shri Anil Chaturvedi & Ms. Astha Chandraasstt. Year: 2011-12 Acit, Vs. India Bulls Power Ltd. (Now Known Circle-21(1), As Rattan India Power Ltd.) New Delhi. 5Th Floor, Tower-B, Worldmark-1, Aerocity, New Delhi- 110 037 Pan Aalcs2063D (Appellant) (Respondent)

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Anuj Garg, Sr. DR

Section 10Section 143(3)Section 14ASection 154

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI BEFORE SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year: 2011-12 ACIT, Vs. India Bulls Power Ltd. (Now known Circle-21(1), as Rattan India Power Ltd.) New Delhi. 5th Floor, Tower-B, Worldmark-1, Aerocity, New Delhi- 110 037 PAN AALCS2063D (Appellant) (Respondent) Assessee by: Shri Ajay Wadhwa, Advocate Ms. Ragini Handa, CA Department by : Shri Anuj Garg, Sr. DR Shri Abhishek Kumar, Sr. DR Date of Hearing 29.11.2022 Date of 05.01.2023 pronouncement O R D E R PER ASTHA CHANDRA, JM The appeal by the Revenue is direc…

Shyamm Mariwala, Mumbai vs. ITO Ward -6(3)(3), Mumbai

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

ITA 2494/MUM/2021[2010-11]Status: DisposedITAT Mumbai22 Dec 2022AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2010-11 Shyamm Mariwala, Ito Ward-6(3)(3), 216, Vasan Udyog Bhavan, Aayakar Bhavan, Vs. Senapati Bapat Marg, Mumbai-400013. Lower Parel, Mumbai-400013. Pan No. Advpm 4940 K Appellant Respondent Assessee By : Mr. Subhash Chhajed, Ar : Revenue By Mr. R.N. D’Souza, Dr Date Of Hearing : 01/11/2022 Date Of Pronouncement : 22/12/2022

For Appellant: Mr. Subhash Chhajed, AR

Section 14ASection 68

…nds available available available with with with assessee. assessee. assessee. In In In such such such situation Section 14A Section 14A of the Act would not be applicable. Similar of the Act would not be applicable. Similar views have been expressed 3 (2019) 410 ITR 466 SC/ (2019) 20 views have been expressed 3 (2019) 410 ITR 466 SC/ (2019) 20 views have been expressed 3 (2019) 410 ITR 466 SC/ (2019) 20 SCC 478. 4 (2 4 (2016) 383 ITR 529 (Bom) / 2016 SCC Online Bom 016) 383 ITR 529 (Bom) / 2016 SCC Online Bom Shyamm Mariwala. 9 1109 by other High Courts in CIT Vs. Suzlon Energy Ltd.5, CIT Vs. by other High Cou…

M/S Ranwa Land Developers Pvt. Ltd., 4, D-Villa, Station Road, Jaipur vs. ITO, Ward-3(2), Jaipur

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 329/JPR/2022[2014-15]Status: DisposedITAT Jaipur21 Dec 2022AY 2014-15

For Appellant: Shri P.C. Parwal, CAFor Respondent: Smt. Monisha Choudhary, JCIT

Section 142(1)Section 143(1)Section 143(2)

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC’’ JAIPUR Jh lanhi xkslkbZ] U;kf;d lnL; ds le{k BEFORE: Hon’ble SHRI SANDEEP GOSAIN, JUDICIAL MEMBER vk;dj vihy la-@ITA No. 329/JP/2022 fu/kZkj.k o"kZ@Assessment Year : 2014-15 M/s. Ranwa Land Developers (P) Ltd. cuke The ITO Vs. 4-D, Villa, Station Road Ward 3(2) Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCR 8315 H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri P.C. Parwal, CA jktLo dh vksj ls@ Revenue by: Smt. Monisha Choudhary, JCIT lquokbZ dh rkjh[k@ Date…

S. Vinodkumar Diamonds P.Ltd, Mumbai vs. DCIT Cir 5(3), Mumbai

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

ITA 5710/MUM/2016[2010-11]Status: DisposedITAT Mumbai14 Dec 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm M/S S. Vinodkumar Diamonds Dy. Commissioner Of Income Pvt. Ltd. Tax, Office No. Bw-3010 Circle 5(3), Vs. Bharat Diamond Bourse, Mumbai Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaics5514N Assessee By : Shri Fenil Bhatt & Shri Sankit Chordia, Ars’ Revenue By : Shri Samuel Pitta, Dr Date Of Hearing: 13.12.2022 Date Of Pronouncement : 14.12.2022

For Appellant: Shri Fenil Bhatt &For Respondent: Shri Samuel Pitta, DR

Section 92Section 92BSection 92CSection 92C(3)

…of the Act. We find that assessee has interest free funds available which were more than the amount of advance for capital asset. Therefore, the issue is squarely covered by the decision of the Hon'ble Supreme Court in case of CIT VS. Reliance Industries Ltd. 410 ITR 466. In view of this, we direct the learned Assessing Officer to delete the disallowance and accordingly, we reverse the orders of the lower authorities. Ground no. 1.1 of the appeal is allowed. 016. No other grounds were argued, hence, same were dismissed. 017. In the result, appeal filed by the assessee is partly allowed. Order pronounced in the…

Shri Shri Deepak Kumar Patel, Raipur (Cg) vs. The Dy. Commissioner of Income Tax 1(1), Raipur (Cg)

In the result, appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 336/BIL/2016[2010-2011]Status: DisposedITAT Raipur12 Dec 2022AY 2010-2011

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita No.336/Rpr/2016 "नधा"रण वष" / Assessment Year :2010-11 Shri Deepak Kumar Patel, Hind Pipe Industries, New Timber Market, Fafadih, Raipur (C.G.)-492 009 Pan : Akgpp0868F .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri B. Subramanyam, CAFor Respondent: Shri G.N Singh, Sr. DR

Section 143(2)Section 143(3)

…आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI G D PADMAHSHALI, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.336/RPR/2016 "नधा"रण वष" / Assessment Year :2010-11 Shri Deepak Kumar Patel, Hind Pipe Industries, New Timber Market, Fafadih, Raipur (C.G.)-492 009 PAN : AKGPP0868F .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent Assessee by :Shri B. Subramanyam, CA Revenue by :Shri G.N Singh, Sr. DR सुनवाई क" तार"ख / Date of Hearing : 28.10.2022 घोषणा क" त…

Lok Prakashan Ltd., Ahmedabad vs. DCIT, Central Circle-1(3), Ahmedabad

In the result the appeal Revenue is hereby dismissed

ITA 1842/AHD/2019[2016-17]Status: DisposedITAT Ahmedabad09 Dec 2022AY 2016-17

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Lumarआयकर अपील सं./Ita No.1842/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2016-2017

For Appellant: Shri Biren Shah, with Shri Dhrunal Bhatt, A.RsFor Respondent: Shri Rakesh Jha, Sr. D.R

Section 14A

…1306.16 crores respectively whereas the investment as on 1 April 2015 and 31 March 2015 stands at Rs. 871.10 crores & Rs. 1093.54 crores respectively. In this regard we note that the Hon’ble Supreme Court in case of CIT vs. Reliance Industries Ltd reported in 410 ITR 466 held that if interest free fund available with the assessee are sufficient to meet the investment then it could be presumed that the investment was made out of interest free fund available with the assessee. The relevant finding of the Hon’ble Supreme court is extracted as under: 7. Insofar as the first question is concerned, the issue raises a p…

Wns Global Services P. Ltd., Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, Nationa Faceless Assessment Centre, Dilhi

In the result, appeal filed by the assessee is allowed

ITA 1259/MUM/2021[2016-17]Status: DisposedITAT Mumbai09 Dec 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyalwns Global Services Pvt. Ltd., Pl 10, Gate No.4, Godrej & Boyce Complex, Pirojshanagar, Lbs Marg, Vikhroli (West), Mumbai-400079. Pan: Aaacw2598L ...... Appellant Vs.. Addl./Jt/Dy./Acit/Ito/Nfac, Room No. 455, Circle-14(3)(1), Mumbai. ..... Respondent Appellant/Assessee By : Sh. Porus Kaka, Sr. Adv. & Sh. Manish Kant Respondent/Revenue By : Sh. Jasdeep Singh, Cit-Dr

For Appellant: Sh. Porus Kaka, Sr. Adv. &For Respondent: Sh. Jasdeep Singh, CIT-DR

Section 143(3)Section 144C(13)Section 92B

…rred on borrowed funds amounting to Rs 50.75 Crores was incurred for a specific purpose; Reliance in this regard is placed on the following judicial precedents: PCIT v Sintex Industries Ltd (2018) (93 taxmann.com 24) (SC) CIT v Reliance Industries Ltd (2019) (410 ITR 466)(SC) CIT v Reliance Utilities & Power Ltd (2009) (313 ITR 340) (Bom) HDFC Bank Ltd v DCIT (2016) (383 ITR 529)(Bom) CIT v HDFC Bank Ltd (2014)(366 ITR 105)(Bom) (f) Without prejudice to previous submission -Scientific apportionment of administrative expenses As mentioned, the Assessee has earned a dividend income of INR 32.99 crs. And the disall…

Mahesh Bikhchand Karda, Ahmedabad vs. The ACIT, Circle-7(2), Ahmedabad

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

ITA 92/AHD/2021[2017-18]Status: DisposedITAT Ahmedabad07 Dec 2022AY 2017-18

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.92/Ahd/2021 िनधा"रण वष"/Asstt. Year: 2017-2018 Mahesh Bikhchand Karda, The A.C.I.T., Block No.24/A, Vs. Circle-7(2), Sindhi Colony, Ahmedabad. Nr. Airport Road, Sardarnagar, Ahmedabad.

For Appellant: Ms Urvashi Shodhan, with Shri Parin Shah, A.RsFor Respondent: Shri Rakesh Jha, Sr. D.R

Section 36(1)(iii)

…ain buy the same piece of land to use it for the business and the interest on the loan will be allowed as the business expense. This is not feasible. So to avoid this confusion, the A.Y. 2017-18 5 Hon’ble Apex Court in case of Reliance Industries reported in 410 ITR 466 held as under: Insofar as the first question is concerned, the issue raises a pure question of fact. The High Court has noted the finding of the Tribunal that the interest free funds available to the assessee were sufficient to meet its investment. Hence, it could be presumed that the investments were made from the interest free funds available w…

Shro Chetankumar Raojibhai Patel, Vadodara vs. The DCIT, Circle-1(2), Vadodara

In the result, the appeal of the assessee is allowed

ITA 533/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad02 Dec 2022AY 2014-15

Bench: Smt.Annapurna Guptaasstt.Year : 2014-15 Chetankumar Raojibhai Patel Dcit, Cir.1(2) Amba Prabhu, Vishram Nagar Vs Vadodara. Saiyad Vasna Road Vadodara 390 015 Pan : Acupp 3382 N

For Appellant: Shri Parimalsingh B. Parmar, ARFor Respondent: Shri Mukesh Thakwani, DR

Section 250(6)Section 36(1)(iii)Section 36(1)(vii)

…e assessee was more than the interest bearing funds, and the interest free funds were almost 2.69 times more than the advances. He contended that the law in this regard had been settled by the Hon’ble Apex Court in the case of CIT Vs. Reliance Industries Ltd. 410 ITR 466 (SC) that presumption in such cases was that interest free advances had been made out of interest free funds, warranting no disallowance of interest under section 36(1)(vii) of the Act. 5. The ld.DR was unable to controvert the factual contentions made by the ld.counel for the assessee before us, nor was he able to distinguish the decision relie…

M/S United Spirits Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-7, Bangalore

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR

Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

…which had in turn followed the Tribunal’s order for assessment year 2012-2013. The Tribunal had directed the A.O. to examine the issue in the light of the judgment of the Hon’ble Apex Court in the case of CIT v. Reliance Industries Limited reported in (2019) 410 ITR 466 (SC). The Tribunal directed the A.O. to examine whether the own funds of the assessee is in excess of the aggregate amount of interest free advances and in such event, the Tribunal held that no disallowance is called for. With the above said directions, the matter was restored to the files of the AO for de novo consideration. The relevant finding…

M/S Jaipur Zila Dugdh Utpadak Sahkari Sangh Ltd., Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

In the result, the appeals of the assessee are allowed for A

ITA 512/JPR/2019[2011-12]Status: DisposedITAT Jaipur09 Nov 2022AY 2011-12

For Appellant: Shri P.C. Parwal, CAFor Respondent: Smt. Runi Pal, Addl. CIT-DR

Section 147Section 80PSection 80P(2)(d)

…AIPUR FDR was placed with JCCB Ltd. over a period of time and when the assessee has demonstrated that interest free funds are more than interest bearing funds, in view of the decision of Hon’ble Supreme Court in case of CIT Vs. Reliance Industries Ltd. (2019) 410 ITR 466, it is to be presumed that investment has been made out of interest free funds more particularly when it is demonstrated by the assessee that even after excluding the interest received from JCCB Ltd., the remaining interest receipt is more than the interest payment. 11. We have considered the rival submission and perused the material available on…

DCIT-Ltu - 2, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2958/MUM/2019[2010-11]Status: DisposedITAT Mumbai07 Nov 2022AY 2010-11

Section 143(3)Section 14A

…st appellate authority as affirmed by the Tribunal which is identical in the present case. 7.1 We also note that the said decision of this Court has been affirmed by the Supreme Court in CIT v. Reliance Industries Ltd. [2019] 102 taxmann.com 52/261 Taxman 165/410 ITR 466. 6. Accordingly, while disallowance of the assessee is upheld in principle, the quantum shall stand reduced, upon verification of necessary facts, in the light of the above legal position. To this extent, this ground of appeal is allowed for statistical purposes. As regards the question of adjustment of book profits under section 15JB for the 14A…

DCIT (Ltu) 1, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is thus dismissed

ITA 3307/MUM/2015[2008-09]Status: DisposedITAT Mumbai07 Nov 2022AY 2008-09

Section 115JSection 14Section 143(3)Section 14A

Ambuja Cements Ltd ( Formerly Known As Gujarat Ambuja Cements Ltd), Mumbai vs. Addl CIT 3(1), Mumbai

In the result, the appeal of the revenue is thus dismissed

ITA 2428/MUM/2013[2006-07]Status: DisposedITAT Mumbai07 Nov 2022AY 2006-07

Section 115JSection 14Section 143(3)Section 14A

Smt. Aneesha Baid, Jaipur vs. ITO, Ward-6(1), Jaipur

In the result, this appeal of the assessee is allowed for statistical purposes only

ITA 1313/JPR/2019[2016-17]Status: DisposedITAT Jaipur19 Oct 2022AY 2016-17

For Appellant: Shri Rohan Sogani ( C.A.)For Respondent: Smt. Monisha Choudhary (JCIT)a

Section 142(1)Section 143(1)(a)Section 143(2)Section 57

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR MkWa- ,l-lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 1313/JP/2019 fu/kZkj.k o"kZ@Assessment Years : 2016-17 cuke Smt. Aneesha Baid, ITO, B-114A, Dayanand Marg, Tilak Nagar, Vs. Ward-6(1), Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAXPM 4028 M vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rohan Sogani ( C.A.) jktLo dh vksj ls@ Revenue b…

Deputy Commissioner of Income-Tax, Circle - 1(1), Pune vs. M/S. Associated Blenders Pvt.Ltd, Pune

In the result, the appeal is allowed for statistical purposes

ITA 2922/PUN/2017[2014-15]Status: DisposedITAT Pune18 Oct 2022AY 2014-15

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.2922/Pun/2017 "नधा"रण वष" / Assessment Year : 2014-15

…eeded the interest free loan advanced to the sister concern, disallowance of part of interest out of total interest paid by the assessee to the bank was not justified. More recently, the Hon’ble Supreme Court in CIT(LTU) Vs. Reliance Industries Ltd. (2019) 410 ITR 466 (SC) has reiterated the same view. In view of the above enunciation of law by the Hon’ble Supreme Court and the other Hon’ble High Courts, it is clear that where interest free funds are available with the assessee and there is net availability of funds, a presumption has to be drawn that the advance made for non-business purposes were advanced…