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 366,459 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 14ASection 143(3)Section 1961Section 40(a)(ia)Section 1962Section 143(2)Section 8D

Issues it is cited on

interest free advancessection 36(1)(iii)disallowance of interest expenditureweighted deductionsection 35(2ab)commercial expediencysection 14a(2)disallowance under section 14adisallowance u/s 14abusiness expediencyput to usesection 36(1)

Judgments citing CIT v. Reliance Industries Ltd.

Dy. Commissioner of Income Tax- CC 3(4), Mumbai vs. Pasha Finance Pvt Ltd, Mumbai

In the result, both the appeals by the Revenue are dismissed

ITA 4317/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Devendra Jain, AdvocateFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 10(34)Section 143(3)Section 14ASection 36(1)(ii)Section 36(1)(iii)

…imilar set of facts, by applying the principles laid down by Hon'ble Jurisdictional High Court of Bombay in the case of Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) and Hon'ble Supreme Court in the case of CIT vs. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), relief was granted to the assessee. The law laid down in these judicial precedents is that there is legal presumption about interest free advances are made out of interest free funds available with the assessee. Ld. CIT(A) placed reliance on the decision of the Coordinate Bench in assessee’s own case for Assessment Year 2009-10 (supra) and…

Dy. Commissioner of Income Tax- CC 3(4), Mumbai vs. Pasha Finance Pvt Ltd, Mumbai

In the result, both the appeals by the Revenue are dismissed

ITA 4316/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Devendra Jain, AdvocateFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 10(34)Section 143(3)Section 14ASection 36(1)(ii)Section 36(1)(iii)

…imilar set of facts, by applying the principles laid down by Hon'ble Jurisdictional High Court of Bombay in the case of Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) and Hon'ble Supreme Court in the case of CIT vs. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), relief was granted to the assessee. The law laid down in these judicial precedents is that there is legal presumption about interest free advances are made out of interest free funds available with the assessee. Ld. CIT(A) placed reliance on the decision of the Coordinate Bench in assessee’s own case for Assessment Year 2009-10 (supra) and…

Sh. Shashank Poddar, Jaipur vs. ACIT, Circle-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 850/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 250Section 57

…ee was having both interest bearing funds and interest free funds, then it has to be presumed that interest free loans were given out of interest free funds. For this purpose reliance is placed on the following cases: - CIT Vs. Reliance Industries Ltd. (2019) 410 ITR 466/175 DTR 1 (SC) Tribunal having found that the interest free funds available to the assessee were sufficient to meet its investment, it could be presumed that funds were given to subsidiaries out of interest free funds and therefore, interest referable to funds given to subsidiaries is allowable as deduction under sec. 36(1)(iii). CIT Vs. Ram Kish…

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…her he submitted that interest expenditure cannot be disallowed under section 14A where the assessee had surplus funds and there was no finding by the assessing officer of any direct nexus of borrowed funds with investments:  CIT v. Reliance Industries Ltd.: 410 ITR 466 (SC)  Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 394 ITR 449 (SC)  HT Media v. PCIT: 399 ITR 576 (Del.)  CIT vs. Taikisha Engineering India Ltd: 370 ITR 338 (Del) 9. He submitted that no disallowance out of administrative expenditure can be made and relied on the following decisions :-  SIL Investment Ltd. v. ACIT: 148 TTJ 213 (Del. Trib.)  DCIT…

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…her he submitted that interest expenditure cannot be disallowed under section 14A where the assessee had surplus funds and there was no finding by the assessing officer of any direct nexus of borrowed funds with investments:  CIT v. Reliance Industries Ltd.: 410 ITR 466 (SC)  Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 394 ITR 449 (SC)  HT Media v. PCIT: 399 ITR 576 (Del.)  CIT vs. Taikisha Engineering India Ltd: 370 ITR 338 (Del) 9. He submitted that no disallowance out of administrative expenditure can be made and relied on the following decisions :-  SIL Investment Ltd. v. ACIT: 148 TTJ 213 (Del. Trib.)  DCIT…

JCIT(OSD) Central Circle 1, Jhandewalan vs. Sahara India Real Estate Corporation Ltd., Lucknow

ITA 1085/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Oct 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Ajay Vohra, Sr. Adv. &For Respondent: Sh. Mahesh Kumar, CIT-DR
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. S. Rifaur Rahman, Accountant Member ITA No. 1085 & CO No. 36/Del/2024 : Asstt. Year: 2017-18 JCIT(OSD), Vs Sahara India Real Estate Central Circle-1, Corporation Ltd., 1, Sahara India New Delhi-110055 Bhawan, Kapoorthala, Complex Aliganj, Lucknow-226024 (APPELLANT) (RESPONDENT) PAN No. AAJCS7265F Assessee by : Sh. Ajay Vohra, Sr. Adv. & Sh. Aditya Vohra, Adv. Revenue by : Sh. Mahesh Kumar, CIT-DR Date of Hearing: 10.07.2025 Date of Pronouncement: 07.10.2025 ORDER Per Satbeer Singh Godara, Judici…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1763/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Sept 2025AY 2014-15

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1762/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Sept 2025AY 2013-14

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1678/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Sept 2025AY 2020-21

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1677/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Sept 2025AY 2018-19

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1676/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Sept 2025AY 2017-18

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal of revenue for AY 2018-19 is dismissed

ITA 1675/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Sept 2025AY 2016-17

Bench: Shri Pawan Singh& Smt.Renu Jauhri

Section 115JSection 14ASection 254(1)Section 40

…allowance under Rule 8D(2)(ii) by CIT(A) cannot be disturbed. Without prejudice, both on facts as well as on law, no interference is called for. The Ld.AR of the assessee further submits that this issue is well settledin CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom) and CIT v. HDFC Bank Ltd [2014] 366 ITR 505 (Bom), HDFC Bank Ltd. v. DCIT [2016] 383 ITR 529 (Bom) and several others.The Ld.AR of the assessee submitted that the consistent view taken by our courts is that if the funds available with the assessee are both interest free and int…

Kapil Foods and Structures Private Limited, Warangal vs. DCIT., Circle-3(1), Hyderabad

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

ITA 206/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Sept 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/S. Kapil Foods & Structures Dy. Commissioner Of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. Pan: Aacck2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 26/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By M/S. Kapil Foods & Structures Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Both Dated 09.12.2024 For The A.Ys. 2016-17 & 2017-18. Since The Issues Involved In Both These Appeals Are Identical & Belong To The Same Assessee, One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 36(1)(iii)

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad श्री रविश सूद, न् याययक सदस् य एवं श्री मिुसूदन सावडिया, लेखा सदस् य के समक्ष । BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/s. Kapil Foods and Structures Dy. Commissioner of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. PAN: AACCK2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee by: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue by: Dr. Sachin Kumar, SR-DR…

Kapil Foods and Structures Private Limited, Warangal vs. DCIT., Circle-3(1), Hyderabad

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

ITA 205/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Sept 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/S. Kapil Foods & Structures Dy. Commissioner Of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. Pan: Aacck2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 26/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By M/S. Kapil Foods & Structures Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Both Dated 09.12.2024 For The A.Ys. 2016-17 & 2017-18. Since The Issues Involved In Both These Appeals Are Identical & Belong To The Same Assessee, One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 36(1)(iii)

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad श्री रविश सूद, न् याययक सदस् य एवं श्री मिुसूदन सावडिया, लेखा सदस् य के समक्ष । BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/s. Kapil Foods and Structures Dy. Commissioner of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. PAN: AACCK2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee by: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue by: Dr. Sachin Kumar, SR-DR…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…2012-13, 2013-14, 2014- 15, and as such, said decision does not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. 015 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

…2012-13, 2013-14, 2014- 15, and as such, said decision does not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. 015 ITA No. 1090, 1097 ΤΟ 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…2012-13, 2013-14, 2014- 15, and as such, said decision does not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee wer…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…2012-13, 2013-14, 2014- 15, and as such, said decision does not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee wer…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…2012-13, 2013-14, 2014- 15, and as such, said decision does not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee wer…

G R N Finsec Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 5341/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Aug 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary
Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “G” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP GOSAIN, JUDICIAL MEMBER ITA No. A.Y. Appellant Respondent Deputy Commissioner of Income Tax, 5329/Mum/2024 2015-16 Circle-1(1)(2), GRN Finsec Private 533, 5th Floor, Limited, Aayakar Bhavan, 815, Tulsiani Chambers, Maharshi Karve Road, 212, Nariman Point, Mumbai-400020. Mumbai-400021. Asst. [PAN: AAFCM2069R] Commissioner of 5341/Mum/2024 2016-17 Income Tax, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400020. Assessee by : Shri Madhur Agrawal & Shri Fenil Bhatt Revenue by : Shri Swapn…