CIT v. United General Trust Ltd.

200 ITR 488Supreme Court of India1993#3460 most cited

What is CIT v. United General Trust Ltd. authority for?

Administrative and interest expenses incurred for earning exempt dividend income are to be disallowed. This disallowance is permitted under Section 14A of the Income Tax Act.

34

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v United General Trust Ltd · 200 ITR 488 SC · Section 14A · disallowance of expenses · exempt dividend income · administrative expenses · interest expenses

Sections most often in play

Section 1961Section 10(34) of the Income Tax ActSection 10(38) of the Income Tax ActSection 143(1) of the Income Tax ActSection 143(3) of the Income Tax ActSection 144 of the Income Tax ActSection 14ASection 14A of the Income Tax Act

Issues it is cited on

section 80msection 18withholding taxinterest on securitiessection 41section 260section 260amercantile system of accountingmiscellaneous applicationchilddisallowance under section 14adisallowance u/s 14a

Judgments citing CIT v. United General Trust Ltd.

AGRASEN ENGINEERING INDUSTRIES PRIVATE LIMITED,JAIPUR vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

ITA 1085/JPR/2024[2018-19]Status: DisposedITAT Jaipur08 Jan 2025AY 2018-19

Bench: Him.

For Appellant: Sh. Vijay Goyal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 111ASection 115JSection 142(1)Section 143(2)Section 143(3)Section 14A

…mplementing the decision are also to be disallowed. The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt is also held/permitted by the Hon’ble Supreme Court in the case of CIT vs. United General Trust, 200 ITR 488 (SC). From view of the above finding, it is explicitly clear that the Ld. A.O. only gave a general finding and proceed to make the disallowance on the basis of such general finding which is sheer presumption and assumption and the same is 11 Agrasen Engineering Industries Pvt. Ltd. not in accordance with the provisions of the law. If the stateme…

STATE BANK OF INDIA,MUMBAI vs. DCIT CIR 2(2), MUMBAI

ITA 4105/MUM/2014[2007-08]Status: DisposedITAT Mumbai11 Oct 2024AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

Section 14Section 143Section 36Section 41

…ned assessing officer further considered the decisions of coordinate bench in Deputy Commissioner of income tax versus SG investment and industries Ltd [(2004) 89 ITD 44 (KOL)], honourable Supreme Court in case of CIT versus United Gen trust private limited [(200 ITR 488)], Distributors(Baroda) private limited versus Union of India [155 ITR 120] and the decision of the honourable Bombay High Court in case of CIT versus Magan Lal Chhaganlal private limited (236 ITR 456). 26) Assessee aggrieved with the order of the learned assessing officer challenged the same before the learned CIT – A who decided the above groun…

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

ITA 4952/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

Section 14Section 143Section 36Section 41

…` IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND MS KAVITHA RAJAGOPAL , JM A.Y.2006-07 [ by Assessee] & ITA No. 4952/MUM /2013 [By AO ] ITA No 4128/MUM /2014 A.Y.2007-08 [ By AO] & [By Assessee] Vs. State Bank of India The Additional 3rd Floor, Commissionerof Income tax Corporate Centre Circle 2 (2) Mumbai Madam Cama Road Room No 545, Aykar Bhavan Nariman Point Maharishi Karve Road Mumbai 400021 Mumbai 400020 (Appellant) (Respondent) PAN AAACS8577K Assessee by Shri Ketan Ved &Abdulkadir Jawad Wala Revenue by Shri P C Chhhotaray Special Counsel Shri Dr Kishor Dhule…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee for assessment

ITA 3868/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

Section 14Section 143Section 36Section 41

…ssessing officer further considered the decisions of coordinate bench in Deputy Commissioner of income tax versus SG investment and industries Ltd [(2004) 89 ITD 44 (KOL)], honourable Supreme Court in case of CIT versus United Gen trust private limited [(200 ITR 488)], Distributors(Baroda) private limited versus Union of India [155 ITR 120] and the decision of the honourable Bombay High Court in case of CIT versus Magan Lal Chhaganlal private limited (236 ITR 456). 26) Assessee aggrieved with the order of the learned assessing officer challenged the same before the learned CIT – A who decided the abov…

ASSOCIATED TECHNO PLASTIC P. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 1890/DEL/2014[2008-09]Status: DisposedITAT Delhi22 May 2024AY 2008-09

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year : 2008-09] Associated Techno Plastic P.Ltd., Vs Dcit, Elegence Level-2, Mathura Road, Circle-2(1), Jasola, New Delhi-110025. New Delhi. Pan-Aaaca2525K Appellant Respondent Appellant By None Respondent By Shri Kanv Bali, Sr. Dr Date Of Hearing 08.05.2024 Date Of Pronouncement 22.05.2024

Section 143(1)Section 144Section 14ASection 234BSection 40Section 68

…mplementing the decision are also to be disallowed. The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt is also held/permitted by the Hon'ble Supreme Court in the case of CIT vs. United General Trust, 200 ITR 488 (SC). 5.4 Keeping in view the provisions of Section 14A of the Act as also the decision of the Hon'ble Supreme Court in the case of CIT Vs. United General Trust Ltd. (supra) and many other following decisions of the Coordinate Benches of the Hon'ble ITAT viz. (a) Southern Petro Chemicals Industries (2005), 93 TTJ 161 (b) Harish Krishnakanta Bhatt…

PRINCIPAL COMMISSIONER OF INCOME TAX-04 vs. M/S IFCI LTD

ITA/499/2022HC Delhi04 Apr 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

Section 10(34)Section 14A

…the assessee company. (iv) The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt, is also held / permitted by the verdict of Hon‟ble Supreme Court in the case of CIT vs. United General Trust Ltd. 200 ITR 488 (SC). (v) Section 14A of the I.T. Act was inserted by the Finance Act, 2001 with retrospective effect from 01.04.1962 which provides as under:- "For the purpose of computing the total income under this chapter, no deduction shall be allowed in respect This is a digitally signed order. The authenticity of the order can be re-verified…

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. M/S MANGLAM BUILD DEVELOPERS LTD, JAIPUR

In the result, the appeal of the Revenue is dismissed

ITA 373/JPR/2022[2013]Status: DisposedITAT Jaipur24 Apr 2023

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

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri James Kurian (CIT) fu/kZkfjrh dh vksj ls@
Section 133ASection 14A

…nce of interest & other expenses u/s 14A read with rule 8D in respect of the investment made by the appellant in the subsidiary & associate companies by referring to the decision of the Hon'ble Supreme Court in the case of CIT Vs. United General Trust Limited 200 ITR 488, & CBDT's clarificatory Circular No.5 dated 11.02.2014. (xiv) As regards the reliance placed by the AO in the case of CIT Vs. United General Trust Limited, it is observed that the same was in context of section 80M of the Act where it was held that deduction would be made of net receipt from dividend and not the gross receipt. Thus this decision…

DCIT, CENTRAL CIRCLE , NOIDA vs. INTERNATIONAL CYLINDERS P. LTD., NEW DELHI

In the result, the appeal filed by the revenue is dismissed

ITA 3765/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Jul 2021AY 2013-14

Bench: Sh. N. K. Billaiya & Shri K.Narasimha Chary(Through Video Conferencing) Assessment Year: 2013-14

Section 14ASection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SH. N. K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER (THROUGH VIDEO CONFERENCING) Assessment Year: 2013-14 DCIT International Cylinders P. Sector-33 Vs Ltd. E-14, Preet Vihar, New Noida Delhi-110092 PAN No. AAACI7605J (RESPONDENT) Appellant by Ms. Anima Barnwal, SR. DR Respondent by Sh.Nipun Mittal, CA Date of hearing: 29/07/2021 Date of Pronouncement: 29/07/2021 ORDER PER N. K. BILLAIYA, AM: This appeal by the revenue is preferred against the order of the CIT(A)-4, Delhi dated 15.01.2018 pertaining to A.…

IFCI LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 2982/DEL/2015[2010-11]Status: DisposedITAT Delhi08 Oct 2020AY 2010-11

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 115JSection 143(3)Section 14A

…ned by the assessee company. (iv) The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt, is also held/ permitted by the verdict of Hon'ble Supreme Court in the case of CIT vs. United General Trust Ltd. 200 ITR 488 (SC). v) Section 14A of the I.T. Act was inserted by the Finance Act, 2001 with retrospective effect from 01.04.1962 which provides as under:- "For the purpose of computing the to tal income under this chapter, no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income which does not form part of the…

SHRI SANJAY PRAKASH KULSHRESTHA,JAIPUR vs. INCOME TAX OFFICER (T & J) O/O PR. CIT-2, JAIPUR

In the result, the ground No

ITA 312/JPR/2019[2014-15]Status: DisposedITAT Jaipur09 Mar 2020AY 2014-15
For Appellant: Akhilesh Kumar Jain (CA)For Respondent: Smt. Runi Pal (JCIT)
Section 10Section 14A

…king and implementing the decision are also to be disallowed. The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt is also held/permitted by the Hon’ble Supreme in case of CIT vs. United General Trust, 200 ITR 488 (SC). Accordingly, a show cause was issued to the assessee as to why disallowance u/s 14A should not be made. In response, it was submitted by the assessee that no amount of borrowing on which interest has been paid was utilized by the assessee in investments, income from which is either exempt or not includible in the total income. Thus Sanjay P…

SHRI SANJAY PRAKASH KULSHRESTHA,JAIPUR vs. INCOME TAX OFFICER (T & J) O/O PR. CIT-2, JAIPUR

In the result, the ground No

ITA 311/JPR/2019[2012-13]Status: DisposedITAT Jaipur09 Mar 2020AY 2012-13
For Appellant: Akhilesh Kumar Jain (CA)For Respondent: Smt. Runi Pal (JCIT)
Section 10Section 14A

…king and implementing the decision are also to be disallowed. The disallowance of administrative expenses and interest expenses on earning of dividend income claimed exempt is also held/permitted by the Hon’ble Supreme in case of CIT vs. United General Trust, 200 ITR 488 (SC). Accordingly, a show cause was issued to the assessee as to why disallowance u/s 14A should not be made. In response, it was submitted by the assessee that no amount of borrowing on which interest has been paid was utilized by the assessee in investments, income from which is either exempt or not includible in the total income. Thus Sanjay P…

VIC ENTERPRISES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, we hereby hold that (a) No disallowance on the interest is required when the assessee has got sufficient own funds at their disposal to lend/advance

ITA 2107/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Jan 2020AY 2013-14

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 2104/Del/2017 : Asstt. Year : 2010-11 Ita No. 2105/Del/2017 : Asstt. Year : 2011-12 Ita No. 2106/Del/2017 : Asstt. Year : 2012-13 Ita No. 2107/Del/2017 : Asstt. Year : 2013-14 Vic Enterprises Pvt. Ltd., Vs Deputy Commissioner Of 4Th Floor, Punjabi Bhawan, 10, Income Tax, Circle-26(1), Rouse Avenue, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacv0132B Assessee By : Sh. M. P. Rastogi Revenue By : Ms. Ashima Neb, Sr. Dr Date Of Hearing: 21.01.2020 Date Of Pronouncement: 29.01.2020

For Appellant: Sh. M. P. RastogiFor Respondent: Ms. Ashima Neb, Sr. DR
Section 14A

…t report u/s 44AB in form 3CB/3CD. Hence, 0.5% of average value of investments which comes to Rs.44,90,230/- was disallowed as against Rs.4,10,947/-. The Assessing Officer relied on the judgment of Hon’ble Supreme Court in the case of CIT vs. United Trust Ltd 200 ITR 488 on preposition that proportionate management expenses should be deducted from gross dividend for the purpose of the deduction. 14. The ld. CIT (A) finds that the assessee during the AY 2013-14 had earned tax free dividend of Rs.33,34,17,195/- on the various investments made by it in the equity shares and units. During the year, the assessee had…

VIC ENTERPRISES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, we hereby hold that (a) No disallowance on the interest is required when the assessee has got sufficient own funds at their disposal to lend/advance

ITA 2106/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Jan 2020AY 2012-13

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 2104/Del/2017 : Asstt. Year : 2010-11 Ita No. 2105/Del/2017 : Asstt. Year : 2011-12 Ita No. 2106/Del/2017 : Asstt. Year : 2012-13 Ita No. 2107/Del/2017 : Asstt. Year : 2013-14 Vic Enterprises Pvt. Ltd., Vs Deputy Commissioner Of 4Th Floor, Punjabi Bhawan, 10, Income Tax, Circle-26(1), Rouse Avenue, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacv0132B Assessee By : Sh. M. P. Rastogi Revenue By : Ms. Ashima Neb, Sr. Dr Date Of Hearing: 21.01.2020 Date Of Pronouncement: 29.01.2020

For Appellant: Sh. M. P. RastogiFor Respondent: Ms. Ashima Neb, Sr. DR
Section 14A

…t report u/s 44AB in form 3CB/3CD. Hence, 0.5% of average value of investments which comes to Rs.44,90,230/- was disallowed as against Rs.4,10,947/-. The Assessing Officer relied on the judgment of Hon’ble Supreme Court in the case of CIT vs. United Trust Ltd 200 ITR 488 on preposition that proportionate management expenses should be deducted from gross dividend for the purpose of the deduction. 14. The ld. CIT (A) finds that the assessee during the AY 2013-14 had earned tax free dividend of Rs.33,34,17,195/- on the various investments made by it in the equity shares and units. During the year, the assessee had…

VIC ENTERPRISES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, we hereby hold that (a) No disallowance on the interest is required when the assessee has got sufficient own funds at their disposal to lend/advance

ITA 2105/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Jan 2020AY 2011-12

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 2104/Del/2017 : Asstt. Year : 2010-11 Ita No. 2105/Del/2017 : Asstt. Year : 2011-12 Ita No. 2106/Del/2017 : Asstt. Year : 2012-13 Ita No. 2107/Del/2017 : Asstt. Year : 2013-14 Vic Enterprises Pvt. Ltd., Vs Deputy Commissioner Of 4Th Floor, Punjabi Bhawan, 10, Income Tax, Circle-26(1), Rouse Avenue, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacv0132B Assessee By : Sh. M. P. Rastogi Revenue By : Ms. Ashima Neb, Sr. Dr Date Of Hearing: 21.01.2020 Date Of Pronouncement: 29.01.2020

For Appellant: Sh. M. P. RastogiFor Respondent: Ms. Ashima Neb, Sr. DR
Section 14A

…t report u/s 44AB in form 3CB/3CD. Hence, 0.5% of average value of investments which comes to Rs.44,90,230/- was disallowed as against Rs.4,10,947/-. The Assessing Officer relied on the judgment of Hon’ble Supreme Court in the case of CIT vs. United Trust Ltd 200 ITR 488 on preposition that proportionate management expenses should be deducted from gross dividend for the purpose of the deduction. 14. The ld. CIT (A) finds that the assessee during the AY 2013-14 had earned tax free dividend of Rs.33,34,17,195/- on the various investments made by it in the equity shares and units. During the year, the assessee had…

VIC ENTERPRISES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, we hereby hold that (a) No disallowance on the interest is required when the assessee has got sufficient own funds at their disposal to lend/advance

ITA 2104/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Jan 2020AY 2010-11

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 2104/Del/2017 : Asstt. Year : 2010-11 Ita No. 2105/Del/2017 : Asstt. Year : 2011-12 Ita No. 2106/Del/2017 : Asstt. Year : 2012-13 Ita No. 2107/Del/2017 : Asstt. Year : 2013-14 Vic Enterprises Pvt. Ltd., Vs Deputy Commissioner Of 4Th Floor, Punjabi Bhawan, 10, Income Tax, Circle-26(1), Rouse Avenue, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacv0132B Assessee By : Sh. M. P. Rastogi Revenue By : Ms. Ashima Neb, Sr. Dr Date Of Hearing: 21.01.2020 Date Of Pronouncement: 29.01.2020

For Appellant: Sh. M. P. RastogiFor Respondent: Ms. Ashima Neb, Sr. DR
Section 14A

…t report u/s 44AB in form 3CB/3CD. Hence, 0.5% of average value of investments which comes to Rs.44,90,230/- was disallowed as against Rs.4,10,947/-. The Assessing Officer relied on the judgment of Hon’ble Supreme Court in the case of CIT vs. United Trust Ltd 200 ITR 488 on preposition that proportionate management expenses should be deducted from gross dividend for the purpose of the deduction. 14. The ld. CIT (A) finds that the assessee during the AY 2013-14 had earned tax free dividend of Rs.33,34,17,195/- on the various investments made by it in the equity shares and units. During the year, the assessee had…

TATA CHEMICALS LTD,MUMBAI vs. DCIT 2(3), MUMBAI

ITA 2965/MUM/2015[2002-03]Status: DisposedITAT Mumbai22 Apr 2019AY 2002-03

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2002-03 Tata Chemicals Ltd. Deputy Commissioner Of Bombay House, Vs. Income Tax-2(3)(1), 5Th 24 Homi Mody Street, Floor, Aayakar Bhavan, Fort, Mumbai-400001 M.K. Road, Mumbai- 400020 Pan No. Aaact4059M Appellant Respondent Assessment Year: 2002-03 Deputy Commissioner Tata Chemicals Ltd. Of Income Tax-2(3)(1), Vs. Bombay House, 5Th Floor, Aayakar 24 Homi Mody Street, Bhavan, M.K. Road, Fort, Mumbai-400001 Mumbai-400020 Pan No. Aaact4059M Appellant Respondent Assessee By : Mr. Nitesh Joshi, Ar Revenue By : Mr. Choudhary Arun Kumar Singh, Date Of Hearing : 25/01/2019 Date Of Pronouncement: 22/04/2019

For Appellant: Mr. Nitesh Joshi, ARFor Respondent: Mr. Choudhary Arun Kumar Singh
Section 115JSection 143(3)Section 14A

…ained earnings in the nature of reserves. Then referring to the decision in Rajasthan State Warehousing Corporation v. CIT (159 CTR 132), Tata Unisys Ltd. (47 TTJ 8). CIT v. Magan Lal Chhagan Lal Pvt. Ltd. (236 ITR 456), CIT v. United General Trust Pvt. Ltd. (200 ITR 488) and K Somasundaram & Brothers v. CIT 238 ITR 939 (Mad), the AO disallowed an amount of Rs.14.49 crores u/s 14A as interest expense towards investment in shares and securities, income from which is exempt from tax. 2.2 In appeal, the Ld. CIT(A) directed the AO to verify whether own funds were utilized for making the investments or otherwise. If t…

ACIT, NEW DELHI vs. M/S. HOUSING & URBAN DEVELOPMENT CORPORATION LTD., NEW DELHI

In the result, Assessee’s appeal vide ITA No

ITA 6151/DEL/2014[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Gagan Kumar, Adv. &For Respondent: Sh. K.J. Singh, CIT (DR)
Section 143(3)Section 14ASection 263

…Fit for Publication ITA Nos.-5705 & 6151/Del/2014. (AM) (JM) Housing & Urban Development Corporation Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘C’: NEW DELHI) BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER ITA No:- 5705/Del/2014 (Assessment Year: 2007-08) M/s Housing & Urban Development Addl. Commissioner of Income Corporation Ltd., Vs. Tax, (HUDCO), Hudco Bhawan, Range-12, New Delhi. Lodhi Road, New Delhi-110003. PAN No: AAACH0632A APPELLANT RESPONDENT ITA No:- 6151/Del/2014 (Assessment Year: 2007-08) ACIT, M/s Housing & Urban Circle 12(1), Vs. Developme…

M/S. HOUSING & URBAN DEVELOPMENT CORPORATION LTD. (HUDCO),NEW DELHI vs. DCIT, NEW DELHI

In the result, Assessee’s appeal vide ITA No

ITA 5705/DEL/2014[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Gagan Kumar, Adv. &For Respondent: Sh. K.J. Singh, CIT (DR)
Section 143(3)Section 14ASection 263

…Fit for Publication ITA Nos.-5705 & 6151/Del/2014. (AM) (JM) Housing & Urban Development Corporation Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘C’: NEW DELHI) BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER ITA No:- 5705/Del/2014 (Assessment Year: 2007-08) M/s Housing & Urban Development Addl. Commissioner of Income Corporation Ltd., Vs. Tax, (HUDCO), Hudco Bhawan, Range-12, New Delhi. Lodhi Road, New Delhi-110003. PAN No: AAACH0632A APPELLANT RESPONDENT ITA No:- 6151/Del/2014 (Assessment Year: 2007-08) ACIT, M/s Housing & Urban Circle 12(1), Vs. Developme…

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, both set of cross appeals for the respective assessment years are disposed off with above directions

ITA 380/JPR/2017[2013-14]Status: DisposedITAT Jaipur29 Mar 2018AY 2013-14
For Appellant: Shri P C ParwalFor Respondent: Shri Varindar Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 115JSection 14ASection 80I

…o note no.3. He further held that assessee holds equity shares of only 45 companies and therefore, assessee is an investor in shares & securities and not a dealer. He thereafter by referring to the decision of the Supreme Court in CIT Vs. United General Trust 200 ITR 488, proceeded to compute the disallowance as per Rule 8D(2)(iii) at Rs.71,75,575/- as per the working given at pages 30-31 of the assessment order. On appeal, the Ld. CIT(A), relying on the decision of his predecessor in assessee’s own case for AY 2012-13, upheld the disallowance of Rs. 71,75,575/- made under Rule 8D(2)(iii). He further held that su…

TWINSTAR JUPITER CO-OP HSG SOC LTD,MUMBAI vs. ITO 12(2)(4), MUMBAI

In the result, appeal filed by the assessee for the assessment year 2009-

ITA 675/MUM/2014[2009-10]Status: DisposedITAT Mumbai26 Apr 2017AY 2009-10

Bench: Shri D. Karunakara. Rao (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-2010 M/S Twinstar Jupiterco-Op. The Income Tax Officer Society Ltd., Ward 12 (2) (4), Jupiter Apartments, Room No. 123-B, 41, Cuffe Parade, Vs. 1St Floor, Aayakar Bhavan, Mumbai- 400020 M.K. Road, Mumbai- 4000020 Pan: Aaabt0015E

For Appellant: Sh. Ashok Patil (AR)For Respondent: Sh. A. Jaikaran (DR)
Section 143Section 143(3)Section 24

…d ITA No. 7843/Mum/03 for the A.Ys. 1998-99 to 2001-02 by setting aside the issue to the file of the AO with the direction to re-compute the total income in accordance with the decision of the Hon’ble Supreme Court passed in CIT Vs. United General Trust Ltd., 200 ITR 488 (SC) and Sabarkantha Zilla Kharid V Sang Ltd. Vs. CIT 203 ITR 1027 (SC). The Ld. Counsel further submitted that the issue involved in this appeal may be restored back to the file of the assessee to compute the income of the assessee as per the directions given by the ITAT in the assessee’s own appeals for the A.Y. 1998-99 to 2001-02. 7. The Ld. d…

Showing 1–20 of 34 · Page 1 of 2

CIT v. United General Trust Ltd. (200 ITR 488) — Cited in 34 Judgments | BharatTax