CIT v. Walfort Share and Stock Brokers P. Ltd.

310 ITR 421High Court2009#3957 most cited

What is CIT v. Walfort Share and Stock Brokers P. Ltd. authority for?

Section 14A of the Income Tax Act requires a proximate cause between expenditure and earning tax-exempt income; simply earning exempt income or having investments does not automatically attract disallowance under this section. The payback or return of investment is not considered a proximate cause for disallowance.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2024.

Also referred to as

CIT v. Walfort Share and Stock Brokers P. Ltd. · 310 ITR 421 · Section 14A · proximate cause · exempt income · disallowance of expenditure · interest bearing funds · administrative expenditure · Wallfort Shares & Brokers Ltd

Judgments citing CIT v. Walfort Share and Stock Brokers P. Ltd.

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

ITA 741/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…lso. In addition the assessee must have incurred administrative expenditure and part of such expenditure is attributable to earning of exempt income. The Ld. AO has referred to the decision of Hon’ble Supreme Court in the case of Wallfort Shares & Brokers Ltd 310 ITR 421 and Godrej Boyce & Manufacturing Co. Ltd and observed that Rule 8D is applicable and he computed such disallowance at Rs.69,89,859/-. The above disallowance was confirmed by CIT(A) in para 13.2 of his order observing as follows: “13.2. I have carefully considered the facts on records and submission of the Ld. Authorized Representative. Undisputed…

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…lso. In addition the assessee must have incurred administrative expenditure and part of such expenditure is attributable to earning of exempt income. The Ld. AO has referred to the decision of Hon’ble Supreme Court in the case of Wallfort Shares & Brokers Ltd 310 ITR 421 and Godrej Boyce & Manufacturing Co. Ltd and observed that Rule 8D is applicable and he computed such disallowance at Rs.69,89,859/-. The above disallowance was confirmed by CIT(A) in para 13.2 of his order observing as follows: “13.2. I have carefully considered the facts on records and submission of the Ld. Authorized Representative. Undisputed…

COMMISSIONER OF INCOME TAX, KOLKATA - III vs. RUGUVALIKA TRADING PVT. LTD.

ITA/363/2009HC Calcutta17 Feb 2023

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 17Th February, 2023 Appearance : Mr. Smarajit Roychowdhury, Adv. …For The Appellant. The Court : This Appeal Filed By The Revenue Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated 17Th July, 2009 Passed By The Income Tax Appellate Tribunal, “D” Bench, Mumbai (The Tribunal) In Ita No.1346/Mum/2008 For The Assessment Year 2004-05. The Appeal Was Admitted On 7Th January, 2010 On The Following Substantial Question Of Law: “Whether On The Facts & In The Circumstances Of The Case, The Income-Tax Appellate Tribunal Has Erred In

Section 260A

…is allowable. The learned Tribunal after considering the facts of the case and as to how the CIT(A) proceeded, took note of the fact that the issue is covered by the decision of the High Court of Bombay in the case Walfort Share and Stock Brokers Pvt. Ltd., 310 ITR 421 (Bom). In the memorandum of grounds of appeal filed before this Court, the revenue does not dispute as regards the effect of the decision of the High Court of Bombay. On the second issue, with regard to the bonus units, the learned Tribunal has once again reappreciated the factual position and also held that the CIT(A) has relied on the decision…

DHNALAXMI BANK LIMITED,TRICHUR vs. THE PR CIT, THRISSUR

Appeal is allowed

ITA 56/COCH/2021[2016-17]Status: DisposedITAT Cochin19 Dec 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.Assessment Year : 2016-17

For Appellant: Shri Harikrishnanunny, CAFor Respondent: Smt. M. Rajasekhar, CIT(DR)
Section 10(33)Section 14Section 143Section 143(2)Section 14ASection 263

…ds are generated from all activities which is common. There is no segregation of interest bearing and interest free funds. The assessee in this regard had relied on the decision of Bombay High Court in the case of CIT v. Walfort Share & Stock Brokers P. Ltd., 310 ITR 421 (Bom) where it was held that section 14A contemplates the real expenditure and not assumed on deemed expenditure. The AO did not accept the contentions of the assessee. The AO relying on the decision of Kerala High Court in the case of South Indian Bank, ITA 730/2009 dated 21.10.2010 wherein it was held that non-maintenance of separate accounts i…

VEDANTA LTD ,GURGAON vs. ACIT, CIRCLE- 26(2), NEW DELHI

ITA 12/DEL/2020[2014-15]Status: FixedITAT Delhi18 Sept 2020AY 2014-15

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2014-15]

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 143(3)Section 153

…e of CIT Vs Wallfort Shares &Stock Brokers Ltd., 233 CTR (SC) 42 was referred to. In this decision, we noted that the Hon"ble Supreme Court in that case upheld the view of the Hon"ble Mumbai High Court in the case of Wallfort Shares &Stock Brokers Ltd. Vs ITO 310 ITR 421. The Hon"ble Supreme Court in this decision, at page- 31 of the order held as under; ―To attract Sec.14A there has to be proximate cause for disallowance which has its relationship with the tax exempt. Pay back or return of investment is not such proximate cause. Hence, Sec.14A is not applicable in the present case. Thus, in the absence of such p…

M/S. AXIS AEROSPACE & TECHNOLOGIES P LTD.,,BANGALORE vs. COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 766/BANG/2017[2009-10]Status: DisposedITAT Bangalore20 Sept 2019AY 2009-10

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2009-10 M/S. Axis Aerospace & The Commissioner Of Technologies Pvt. Ltd., Income Tax 54, Richmond Road, Vs. (Appeals) – 14, Bangalore – 560 025. Bangalore. Pan: Aaccb1728K Appellant Respondent

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Smt. R. Premi, JCIT (DR)
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI ARUN KUMAR GARODIA, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER Assessment Year : 2009-10 M/s. Axis Aerospace & The Commissioner of Technologies Pvt. Ltd., Income Tax 54, Richmond Road, Vs. (Appeals) – 14, Bangalore – 560 025. Bangalore. PAN: AACCB1728K APPELLANT RESPONDENT Assessee by : Smt. Sheetal Borkar, Advocate Revenue by : Smt. R. Premi, JCIT (DR) Date of hearing : 09.09.2019 Date of Pronouncement : 20.09.2019 O R D E R Per Shri A.K. Garodia, Accountant Member This appeal is filed by the assessee and the same is di…

DY. COMMISSIONER OF INCOME TAX-6, KANPUR vs. COMMERCIAL ENGINEERS & BODY BUILDERS CO. LTD., KANPUR

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

ITA 658/LKW/2018[2014-15]Status: DisposedITAT Lucknow19 Jul 2019AY 2014-15

Bench: Shri. A. D. Jain & Shri T. S. Kapoor

For Appellant: Shri S. K. Maduk, CIT (DR)For Respondent: Shri B. L. Gupta, FCA
Section 143(3)Section 14ASection 32(1)(iia)

…of CIT Vs Wallfort Shares & Stock Brokers Ltd., 233 CTR (SC) 42 was referred to. In this decision, we noted that the Hon’ble Supreme Court in that case upheld the view of the Hon’ble Mumbai High Court in the case of Wallfort Shares & Stock Brokers Ltd. Vs ITO 310 ITR 421. The Hon’ble Supreme Court in this decision, at page-31 of the order held as under; ITA No.657 & 658/LKW/2018 Page 17 of 24 “To attract Sec.14A there has to be proximate cause for disallowance which has its relationship with the tax exempt. Pay back or return of investment is not such proximate cause. Hence, Sec.14A is not applicable in the pr…

DY. COMMISSIONER OF INCOME TAX-6, KANPUR vs. COMMERCIAL ENGINEERS & BODY BUILDERS CO. LTD., KANPUR

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

ITA 657/LKW/2018[2013-14]Status: DisposedITAT Lucknow19 Jul 2019AY 2013-14

Bench: Shri. A. D. Jain & Shri T. S. Kapoor

For Appellant: Shri S. K. Maduk, CIT (DR)For Respondent: Shri B. L. Gupta, FCA
Section 143(3)Section 14ASection 32(1)(iia)

…of CIT Vs Wallfort Shares & Stock Brokers Ltd., 233 CTR (SC) 42 was referred to. In this decision, we noted that the Hon’ble Supreme Court in that case upheld the view of the Hon’ble Mumbai High Court in the case of Wallfort Shares & Stock Brokers Ltd. Vs ITO 310 ITR 421. The Hon’ble Supreme Court in this decision, at page-31 of the order held as under; ITA No.657 & 658/LKW/2018 Page 17 of 24 “To attract Sec.14A there has to be proximate cause for disallowance which has its relationship with the tax exempt. Pay back or return of investment is not such proximate cause. Hence, Sec.14A is not applicable in the pr…

ITC LIMITED,KOLKATA vs. ACIT, RG-8, KOLKATA, KOLKATA

Appeal is dismissed

ITA 685/KOL/2014[2009-2010]Status: DisposedITAT Kolkata28 Nov 2018AY 2009-2010

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ]

For Appellant: Shri Md. Usman, CIT DRFor Respondent: Shri J.P. Khaitan, Senior Counsel
Section 143(3)

…y relied on the decision in Walfort Share & Stock Brokers (P.) Ltd. (supra).In this decision we noted that the Hon'ble Supreme Court in that case upheld the view of the Hon'ble Mumbai High Court in the case of Walfort Shares & Stock Brokers Ltd. v. ITO [2009] 310 ITR 421 . The Hon'ble Supreme Court in this decision, at page-31 of the order held as under : "To attract Sec. l44' there has to be proximate cause for disallowance which has its relationship with the tax exempt. Pay back or return of investment is not such proximate cause. Hence, Sec. 14A is not applicable in the present case. Thus, in the absence of su…

DCIT, CIR-8, KOLKATA, KOLKATA vs. M/S ITC LIMITED, KOLKATA

Appeal is dismissed

ITA 1267/KOL/2014[2009-2010]Status: DisposedITAT Kolkata28 Nov 2018AY 2009-2010

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ]

For Appellant: Shri Md. Usman, CIT DRFor Respondent: Shri J.P. Khaitan, Senior Counsel
Section 143(3)

…y relied on the decision in Walfort Share & Stock Brokers (P.) Ltd. (supra).In this decision we noted that the Hon'ble Supreme Court in that case upheld the view of the Hon'ble Mumbai High Court in the case of Walfort Shares & Stock Brokers Ltd. v. ITO [2009] 310 ITR 421 . The Hon'ble Supreme Court in this decision, at page-31 of the order held as under : "To attract Sec. l44' there has to be proximate cause for disallowance which has its relationship with the tax exempt. Pay back or return of investment is not such proximate cause. Hence, Sec. 14A is not applicable in the present case. Thus, in the absence of su…

DCIT -1(3)(2), MUMBAI vs. TATA LOCKHEED MARTINAEROSTRUCTURES LTD., HYDERABAD

In the result , appeal of the Revenue is partly allowed as indicated above

ITA 2667/MUM/2016[2011-12]Status: DisposedITAT Mumbai08 Aug 2018AY 2011-12

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Ms. Arati VissanjiFor Respondent: Shri V. Justin,DR
Section 143(3)Section 14A

…hi High Court) (b) CIT v. Printers House Private Ltd. (2010) 188 Taxman 70 (Delhi High Court) (c) Swapna Murarka vs. ACIT [2015] 58 taxmann.com 369 (Mumbai - Tribunal) I.T.A. No.2667/Mum/2016 (d) CIT v. Walfort Share and Stock Brokers Private Limited (2009) 310 ITR 421 (Bom) [Affirmed in 326 ITR I (SC)] (e) CIT v. Reliance Industries Ltd. 339 ITR 632 (Bom) (f) CIT v. Metalman Auto P. Ltd. (2011) 336 ITR 434 (P&H) (g) CIT v. Hero Cycles Ltd. (2010) 323 ITR 518 (P&H) (h) CIT v. Winsome Textile Industries Ltd. 319 ITR 204 (P&H) (i) Godrej & Boyce Manufacturing Co Ltd, 328 ITR 81 (Bombay High Court) (j) Wimco Seedl…

M/S. FEDERAL MOGUL GOETZE INDIA LTD.,,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 3324/DEL/2015[2009-10]Status: DisposedITAT Delhi27 Jun 2018AY 2009-10

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

Section 14ASection 36(1)(ii)Section 36(1)(iii)

…ears, even before introduction of section 14A out of the assessee's own funds and all the expenditure has been incurred wholly and exclusively for the manufacturing operations of the assessee. Reference in this connection is made to the following judgements:- 310 ITR 421 Delhi High Court in the case of CIT v. Walfort Share & Stock Brokers Ltd. where at page 144 para 57 of the order the hon'ble Bombay High Court has observed that: "What Section 14A contemplates is the expenditure actually incurred for earning tax free income and not assumed expenditure or deemed expenditure. " It may be submitted that this judgeme…

ACIT 1(1), MUMBAI vs. BOMBAY GAS CO. LTD, MUMBAI

ITA 6212/MUM/2011[2008-09]Status: DisposedITAT Mumbai07 Mar 2018AY 2008-09

Bench: Shri G. S. Pannu, Am & Shri Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 6212/Mum/2011& 1187/Mum/2013 (निर्धारणवर्ा / Assessment Year: 2008-09& 2009-10)

For Appellant: Sh. Manish V. ShahFor Respondent: Sh. Suman Kumar, DR
Section 143(1)Section 143(2)

…m ‘in relation to’ means that the expenditure must have been actually incurred in earning exempt income. Ld. AR also submitted that as per the decisions of Hon’ble Bombay High Court in the case of CIT vrs. Walfort Share and Stock Brokers Pvt. Ltd (reported in 310 ITR 421) wherein it was held that ‘what section 14A contemplates is the expenditure actually incurred for earning tax free income and not assumed expenditure or deemed expenditure’. Apart from above, Ld. AR also submitted that the assessee was having own funds and no borrowed funds were used to earn exempt income and therefore the provision of section 14…

ADDL.C.I.T. RG.3(3), MUMBAI vs. AAVARAN TEXTILES PVT. LTD., MUMBAI

The appeal of the Revenue is dismissed

ITA 5971/MUM/2012[2008-09]Status: DisposedITAT Mumbai05 Mar 2018AY 2008-09

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2008 - 2009 Addl. Cit Range 3(3) Aavaram Textiles Pvt Ltd., Mumbai 81-A, Mittal Court, बनाम/ 224 Nariman Point, Vs. Mumbai 400 021 (राज"व /Revenue) ("नधा"रती /Assessee)

Section 115JSection 143(3)Section 25

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ,‘ए’,मुंबई। IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “A”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी जी. मंजूनाथ, लेखा सद"य, के सम" Before Shri JOGINDER SINGH, Judicial Member, and Shri G. MANJUNATHA, Accountant Member Assessment Year: 2008 - 2009 Addl. CIT Range 3(3) Aavaram Textiles Pvt Ltd., Mumbai 81-A, Mittal Court, बनाम/ 224 Nariman Point, Vs. Mumbai 400 021 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. AAACA3414D Shri Rajesh Damor CIT-DR राज"व क" ओर से / Revenue by "नधा"रती क" ओर से / Assessee by Shri J D Mistry सुनवाई क" तार"ख / Date of Hearing : 05/02/2…

D.C.I.T. RG.3(3), MUMBAI vs. RELIANCE WELFARE ASSOCIATION, MUMBAI

ITA 5976/MUM/2012[2008-09]Status: DisposedITAT Mumbai15 Jan 2018AY 2008-09

Bench: D.T. Garasia & Shri Rajesh Kumarassessment Year: 2008-09 Asst. Commissioner Of Income M/S. Reliance Welfare Tax Circle 3(3) Association Circle Room No.609, 6Th Floor, Maker Chambers Iv, 3Rd Floor, Vs. Aayakar Bhavan, M.K.Road, Nariman Point, Mumbai - 400020 Mumbai - 400021 Pan:Aaacr6115N (Appellant) (Respondent)

For Appellant: Shri Jahangir Mistri, Sr. Advocate and Shri Madhur AgarwalFor Respondent: Shri B. Pruseth
Section 115JSection 143(3)Section 25

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE D.T. GARASIA, JUDICIAL MEMBER AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER Assessment Year: 2008-09 Asst. Commissioner of Income M/s. Reliance Welfare Tax Circle 3(3) Association Circle Room No.609, 6th Floor, Maker Chambers IV, 3rd Floor, Vs. Aayakar Bhavan, M.K.Road, Nariman Point, Mumbai - 400020 Mumbai - 400021 PAN:AAACR6115N (Appellant) (Respondent) Present for: Revenue by : Shri B. Pruseth Assessee by : Shri Jahangir Mistri, Sr. Advocate and Shri Madhur Agarwal Date of Hearing : 10.01.2018 Date of Pronouncement : 15.01.2018 O R D E R Per D…

TATA LOKHEED MARTIN AEROSTRUCTURES LTD.,HYDERABAD vs. DCIT - 1(3), MUMBAI

ITA 2144/MUM/2016[2011-12]Status: DisposedITAT Mumbai12 Jan 2018AY 2011-12

Bench: Sh. Shamim Yahya, Am & Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 2144/Mum/2016 (निर्धारणवर्ा / Assessment Year: 2011-12)

For Appellant: Ms. Aarati VisanjiFor Respondent: Sh. M. V. Rajguru
Section 10(34)Section 14A

…ited (2014) 360 hR 68 (Delhi High Court) (b) CIT v. Printers House Private Ltd. (2010) 188 Taxman 70 (Delhi High Court) (c) Swapna Murarka vs. ACIT [2015] 58 taxmann.com 369 (Mumbai - Tribunal) (d) CIT v. Walfort Share and Stock Brokers Private Limited (2009) 310 ITR 421 (Born) [Affirmed in 326 ITR I (SC)] (e) CIT v. Reliance Industries Ltd. 339 ITR 632 (Born) (f) CIT v. Metalman Auto P. Ltd. (2011) 336 ITR 434 (P&H) (g) CIT v. Hero Cycles Ltd. (2010) 323 ITR 518 (P&H) (h) CIT v. Winsome Textile Industries Ltd. 319 hR 204 (P&H) (i) Godrej & Boyce Manufacturing Co Ltd, 328 ITR 81 (Bombay High Court) (j) Wimco Seed…

BHARAT SERUMS AND VACCINES LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

Appeal of the AO stands dismissed

ITA 3091/MUM/2012[2008-09]Status: DisposedITAT Mumbai15 Feb 2017AY 2008-09
For Appellant: S/Shri Nitesh Joshi & Vipul Mody -ARFor Respondent: Shri Saurabh Kumar Rai-DR
Section 115Section 115JSection 143(3)Section 14ASection 254(1)

…आयकर आयकर अपीलीय आयकर आयकर अपीलीय अपीलीय अिधकरण अपीलीय अिधकरण अिधकरण, मुंबई अिधकरण मुंबई मुंबई “बी मुंबई बी बी” ” ” ” खंडपीठ बी खंडपीठ खंडपीठ खंडपीठ Income-tax Appellate Tribunal -“B”Bench Mumbai सव"ी राजे"",लेखा सद"य एवं अमरजीत "सह, "याियक सद"य Before S/Sh.Rajendra,Accountant Member and Amarjit Singh,Judicial Member आयकर अपील सं./I.T.A./3091/Mum/2012,िनधा"रण िनधा"रण वष" वष" /Assessment Year: 2008-09 िनधा"रण िनधा"रण वष" वष" M/s. Bharat Serums & Vaccines Ltd. ACIT, Range-3(1) 27th Floor, Hoechst House, Nariman Point Aayakar Bhavan, M.K. Marg Vs. Mumbai-21. Mumbai-400 020. PAN:AAACB 2431 M (अपीलाथ" /Appellant)…

AISHWARYA RAI BACHCHAN,MUMBAI vs. DCIT CEN CIR 2, MUMBAI

In the result, appeals of the Revenue are dismissed, whereas appeal of assessee is allowed for statistical purposes

ITA 3873/MUM/2013[2004-05]Status: DisposedITAT Mumbai18 Jan 2017AY 2004-05

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm

Section 143(1)Section 143(2)Section 143(3)Section 154Section 220(2)Section 44ASection 80RSection 90Section 94(7)

…ld that the interest expenditure directly or indirectly was attributable for earning the dividend income, the decision of the Tribunal in deleting the disallowance of interest made u/s 14A cannot be faulted. iv. Wallfort Shares & Stock Brokers Ltd- vs- I.T.O. 310 ITR 421 (Bom) In this case, the assessee purchased units of a mutual fund in response to a public advt. on which it earned tax free dividend income of Rs.1.82 cr. Within few days, it also sold the said units by way of redemption which resulted in loss of Rs.2.09 cr. While computing the total income, it claimed exemption in respect of dividend income u/s…

DCIT CC 2, MUMBAI vs. AISHWARYA RAI BACHCHAN, MUMBAI

In the result, appeals of the Revenue are dismissed, whereas appeal of assessee is allowed for statistical purposes

ITA 3816/MUM/2013[2009-10]Status: DisposedITAT Mumbai18 Jan 2017AY 2009-10

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm

Section 143(1)Section 143(2)Section 143(3)Section 154Section 220(2)Section 44ASection 80RSection 90Section 94(7)

…ld that the interest expenditure directly or indirectly was attributable for earning the dividend income, the decision of the Tribunal in deleting the disallowance of interest made u/s 14A cannot be faulted. iv. Wallfort Shares & Stock Brokers Ltd- vs- I.T.O. 310 ITR 421 (Bom) In this case, the assessee purchased units of a mutual fund in response to a public advt. on which it earned tax free dividend income of Rs.1.82 cr. Within few days, it also sold the said units by way of redemption which resulted in loss of Rs.2.09 cr. While computing the total income, it claimed exemption in respect of dividend income u/s…

DCIT CC 2, MUMBAI vs. AISHWARYA RAI BACHCHAN, MUMBAI

In the result, appeals of the Revenue are dismissed, whereas appeal of assessee is allowed for statistical purposes

ITA 3815/MUM/2013[2007-08]Status: DisposedITAT Mumbai18 Jan 2017AY 2007-08

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm

Section 143(1)Section 143(2)Section 143(3)Section 154Section 220(2)Section 44ASection 80RSection 90Section 94(7)

…ld that the interest expenditure directly or indirectly was attributable for earning the dividend income, the decision of the Tribunal in deleting the disallowance of interest made u/s 14A cannot be faulted. iv. Wallfort Shares & Stock Brokers Ltd- vs- I.T.O. 310 ITR 421 (Bom) In this case, the assessee purchased units of a mutual fund in response to a public advt. on which it earned tax free dividend income of Rs.1.82 cr. Within few days, it also sold the said units by way of redemption which resulted in loss of Rs.2.09 cr. While computing the total income, it claimed exemption in respect of dividend income u/s…

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