CIT v. Walfort Share & Stock Brokers (P.) Ltd.

326 ITR 1Supreme Court of India2010#116 most cited

What is CIT v. Walfort Share & Stock Brokers (P.) Ltd. authority for?

For attracting Section 14A disallowance, there must be a proximate cause relating the expenditure to actual tax-exempt income, and such disallowance is not automatic but requires positive material. Additionally, Section 94(7) on dividend stripping only ignores losses to the extent of dividend received for assessment years post-April 1, 2002, allowing the remaining loss.

543

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Walfort Share & Stock Brokers P. Ltd. · 326 ITR 1 · Section 14A disallowance · proximate cause exempt income · not automatic disallowance · actual exempt income · Section 94(7) · dividend stripping · loss ignored to extent of dividend · tax-exempt income expenditure

Also reported as

192 Taxmann 21141 DTR 233

Sections most often in play

Section 14ASection 143(3)Section 94(7)Section 10(35)Section 133ASection 148Section 148ASection 48
Read the full judgment

Issues it is cited on

section 14a(1)strategic investmentsection 14a(2)section 10(34)disallowance under section 14adisallowance u/s 14asection 14asection 80iamercantile system of accountingsection 115jbsection 115jrevenue expenditure

Judgments citing CIT v. Walfort Share & Stock Brokers (P.) Ltd.

DCIT, Circle- 21(1), New Delhi vs. Religare Enterprises Ltd., New Delhi

In the result, revenue’s appeal is dismissed and cross-objection

ITA 7552/DEL/2018[2014-15]Status: HeardITAT Delhi29 Aug 2022AY 2014-15

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia:Assessment Year: 2014-15 Deputy Commissioner Of Vs. M/S. Religare Enterprises Income-Tax, Circle-21(1), Ltd., 2Nd Floor, Rajlok New Delhi Building, 24-Nehru Place, New Delhi-110019 Pan :Aaacv5888N (Appellant) (Respondent)

Section 14A

…t for the concept of 'real income'. It does not note that under s. 5 of the Act. the question of taxation of 'notional income' does not arise. As explained in CIT vs. Walfort Share & Stock Brokers (P) Ltd. (2010)233 CTR (SC) 42: (2010) 41 DTR (SC) 233 : (2010)326 ITR 1 (SC), the mandate of s. 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives byway of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Consequently, the Court i…

DCIT, New Delhi vs. M/S. R.J. Corp Ltd., New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 5311/DEL/2015[2012-13]Status: DisposedITAT Delhi25 Aug 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

…rovisions of Finance Bill, 2001 (introducing section 14A) as well as the Notes to the Clauses presented along with the said Bill, has been noted with approval by the Hon’ble Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd, [2010] 192 Taxman 211/326 ITR 1 (SC), holding as under: ITA Nos. 4971, 4972, 5310 & 5311/Del/2015 7 RJ Corp Ltd. "The insertion of section 14A with retrospective effect is the serious attempt on the part of Parliament not to allow deduction in respect of any expenditure incurred by the assessee in relation to income, which does not form part of the total income under the Act aga…

DCIT, New Delhi vs. M/S. R.J. Corp Ltd., New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 5310/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Aug 2022AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

…rovisions of Finance Bill, 2001 (introducing section 14A) as well as the Notes to the Clauses presented along with the said Bill, has been noted with approval by the Hon’ble Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd, [2010] 192 Taxman 211/326 ITR 1 (SC), holding as under: ITA Nos. 4971, 4972, 5310 & 5311/Del/2015 7 RJ Corp Ltd. "The insertion of section 14A with retrospective effect is the serious attempt on the part of Parliament not to allow deduction in respect of any expenditure incurred by the assessee in relation to income, which does not form part of the total income under the Act aga…

M/S. Rj Corp Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 4972/DEL/2015[2012-13]Status: DisposedITAT Delhi25 Aug 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

…rovisions of Finance Bill, 2001 (introducing section 14A) as well as the Notes to the Clauses presented along with the said Bill, has been noted with approval by the Hon’ble Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd, [2010] 192 Taxman 211/326 ITR 1 (SC), holding as under: ITA Nos. 4971, 4972, 5310 & 5311/Del/2015 7 RJ Corp Ltd. "The insertion of section 14A with retrospective effect is the serious attempt on the part of Parliament not to allow deduction in respect of any expenditure incurred by the assessee in relation to income, which does not form part of the total income under the Act aga…

M/S. Rj Corp Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 4971/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Aug 2022AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

…rovisions of Finance Bill, 2001 (introducing section 14A) as well as the Notes to the Clauses presented along with the said Bill, has been noted with approval by the Hon’ble Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd, [2010] 192 Taxman 211/326 ITR 1 (SC), holding as under: ITA Nos. 4971, 4972, 5310 & 5311/Del/2015 7 RJ Corp Ltd. "The insertion of section 14A with retrospective effect is the serious attempt on the part of Parliament not to allow deduction in respect of any expenditure incurred by the assessee in relation to income, which does not form part of the total income under the Act aga…

DCIT, New Delhi vs. M/S Ntpc Ltd., New Delhi

ITA 156/DEL/2016[2011-12]Status: DisposedITAT Delhi05 Aug 2022AY 2011-12

Bench: Sh. A.D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. Bhavnesh Kulsheshtha, CIT-DR
Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. A.D. Jain, Vice President Dr. B. R. R. Kumar, Accountant Member ITA No. 5718/Del/2015 : Asstt. Year: 2007-08 ITA No. 4083/Del/2014 : Asstt. Year: 2008-09 ITA No. 2295/Del/2018 : Asstt. Year: 2008-09 ITA No. 7063/Del/2014 : Asstt. Year: 2010-11 ITA No. 5392/Del/2017 : Asstt. Year: 2010-11 ITA No. 298/Del/2016 : Asstt. Year: 2011-12 ITA No. 5393/Del/2017 : Asstt. Year: 2011-12 ITA No. 299/Del/2016 : Asstt. Year: 2012-13 ITA No. 5394/Del/2017 : Asstt. Year: 2012-13 NTPC Limited, Vs Addl. CIT, Core-7, SCOPE Complex, 7, Range-13/18, Ins…

Dcir, New Delhi vs. M/S Ntpc Ltd., New Delhi

ITA 5704/DEL/2015[2007-08]Status: DisposedITAT Delhi05 Aug 2022AY 2007-08

Bench: Sh. A.D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. Bhavnesh Kulsheshtha, CIT-DR
Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. A.D. Jain, Vice President Dr. B. R. R. Kumar, Accountant Member ITA No. 5718/Del/2015 : Asstt. Year: 2007-08 ITA No. 4083/Del/2014 : Asstt. Year: 2008-09 ITA No. 2295/Del/2018 : Asstt. Year: 2008-09 ITA No. 7063/Del/2014 : Asstt. Year: 2010-11 ITA No. 5392/Del/2017 : Asstt. Year: 2010-11 ITA No. 298/Del/2016 : Asstt. Year: 2011-12 ITA No. 5393/Del/2017 : Asstt. Year: 2011-12 ITA No. 299/Del/2016 : Asstt. Year: 2012-13 ITA No. 5394/Del/2017 : Asstt. Year: 2012-13 NTPC Limited, Vs Addl. CIT, Core-7, SCOPE Complex, 7, Range-13/18, Ins…

ACIT, Circle- 11(2), New Delhi vs. Hindustan Epc Company Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1421/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Jul 2022AY 2015-16

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri A.T. Panda, AdvFor Respondent: Shri Gurpreet Shah Singh, Sr.DR
Section 143(3)Section 14ASection 5

…it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in Commissioner of Income Tax V. Walfort Share and Stock Brokers Pvt. Ltd [2010] 326 ITR 1(SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred I.T.A. No.1421/Del/2019 4 in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt…

M/S. Maxivision Eye Hospital Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-4(1), Chennai

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

ITA 139/CHNY/2020[2012-13]Status: DisposedITAT Chennai22 Jul 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri AR. V. Sreenivasan, Addl.CIT
Section 1Section 14Section 143(3)Section 14A

…year from the same investments. In view of the same, it is held that the decision of the Hon'ble Madras High Court in M/s. Redington India Ltd is held as overruled by the decisions of the Apex Court on section 14 in M/s Walfort Share and Stock Brokers P Ltd. (326 ITR 1) (SC), M/s. Godrej & Boyce Manufacturing Co. Ltd. (394 TR 449 (SC) as well as M/s. Maxopp Investments Ltd (Taxsutra 115 SC. 2018), which have had similar facts of tax exempt assets not yielding any income in the respective AYrs. Considering the same, the action of the Assessing Officer in disallowing an amount of Rs.35,56,906/- u/s 14A is sustained…

ACIT - CC-3(3), Mumbai vs. M/S.Welspun India Ltd., Mumbai

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

ITA 2551/MUM/2021[2016-17]Status: DisposedITAT Mumbai11 Jul 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleacit, Cc-3(3), Vs. M/Swelspun India Ltd Room No. 1923, 19Th B Wing, 9Th Floor, Floor, Air India Bldg, Trade Worldcentere, Nariman Point, Senapati Bapat Marg, Mumbai-400021. Kamala Mills Compound, Lower Parel, Mumbai - 400013 Pan/Gir No. : Aaacw1259N Appellant .. Respondent Appellant By : Shri Jasbir Chouhan.Cit.Dr Respondent By : Shri Rajiv Khandelwal.Ar Date Of Hearing 12.07.2022 Date Of Pronouncement 25.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Shri Jasbir Chouhan.CIT.DRFor Respondent: Shri Rajiv Khandelwal.AR
Section 115JSection 132Section 143Section 143(2)Section 143(3)Section 14ASection 153A

…n relation to” has been judiciously explained to mean some real and dominant relationship. 4.9. In this regard ld. counsel has relied on the decision of Hon’ble Supreme Court in the case of CIT Vs. Walford M/s. Welspun Ind Ltd., Mumbai. Share & Stock Brokers 326 ITR 1, wherein it has been held by the Apex Court that there must be proximate relationship of expenditure with the exempt income for the purpose of making disallowance u/s 14A of the Act. This decision was followed by the Hon’ble Bombay High Court in the case of Godrej & Boyce Mfg. Co. Ltd. Vs. CIT 328 ITR 81 . 4.10. He further referred to the decisio…

DCIT Circle-25(2), New Delhi vs. Transcend Infrastructure Pvt. Ltd., Gurgaon

In the result, appeal of the Revenue is dismissed

ITA 5178/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Jun 2022AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmadcit Vs. Transcend Infrastructure Circle – 25(2) Pvt. Ltd. New Delhi - 110002 Plot No. B-15, Ff, Sec-32, Gurgaon-122 001 Pan No. Aacct 7115 Q (Appellant) (Respondent)

Section 115JSection 143(3)Section 14A

…pect of assessment years prior to 2007 when this rule was inserted. (iv) Theory of Apportionment of Expenditure between taxable and non taxable income has in principle, which was widened by the SC in the case of Walfort Share & Stock Brokers Pvt Ltd. ( 2010)(326 ITR 1), has now been upheld by the SC in the above case of Maxopp. 3. Crux of the issue - Section 14A (1) says that no deduction shall be allowed in respect of expenditure incurred in relation to income which does not form part of total income. Following main points need to be considered:- (i) Whether section 14A (1) would stand attracted even if such…

ACIT- CC - 4(2), Mumbai vs. K.Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2527/MUM/2021[2017-18]Status: DisposedITAT Mumbai17 Jun 2022AY 2017-18

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT- CC- 4(2), Mumbai vs. K. Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2526/MUM/2021[2018-19]Status: DisposedITAT Mumbai17 Jun 2022AY 2018-19

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT-CC -4(2), Mumbai vs. K . Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2525/MUM/2021[2013-14]Status: DisposedITAT Mumbai17 Jun 2022AY 2013-14

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT- CC- 4(2), Mumbai vs. K. Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2524/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 Jun 2022AY 2016-17

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT- CC- 4 (2), Mumbai vs. K. Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2523/MUM/2021[2015-16]Status: DisposedITAT Mumbai17 Jun 2022AY 2015-16

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT- CC- 4 (2), Mumbai vs. K. Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2522/MUM/2021[2014-15]Status: DisposedITAT Mumbai17 Jun 2022AY 2014-15

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

ACIT - CC 4(2), Mumbai vs. K. Raheja Corporate Services Pvt. Ltd., Mumbai

In the result, the appeals filed by the revenue are hereby dismissed

ITA 2521/MUM/2021[2012-13]Status: DisposedITAT Mumbai17 Jun 2022AY 2012-13

Bench: Shri Aby T. Varkey () & Shri Gagan Goyal ()

Section 132Section 132(4)Section 143(2)Section 143(3)Section 14ASection 153ASection 69Section 69C

…revious year'. Further, it does not account for the concept of 'real income'. It does not note that under Section 5 of the Act, the question of taxation of 'notional income' does not arise. As explained in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 (SC), the mandate of Section 14A of the Act is to curb the practice of claiming deduction of expenses incurred in relation to exempt income being taxable income and at the same time avail of the tax incentives by way of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. Cons…

M/S. Syngene International Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range- 6, Bangalore

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

ITA 147/BANG/2020[2010-11]Status: DisposedITAT Bangalore13 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2010-11

For Appellant: Sri Padamchand Khincha, A.RFor Respondent: Sri Sumer Singh Meena, DR
Section 10ASection 10BSection 14ASection 250Section 32(1)(iia)Section 80

…income (c) The AO should indicate cogent reasons for rejecting the claim of the assessee with regard to expenditure or no expenditure as the case may be in relation to exempt income (d) The Supreme Court in CIT v Walfort Share and Stock Brokers P. Ltd [2010] 326 ITR 1 has held that for attracting section 14A there has to be a proximate cause for disallowance, which is in relationship with the tax exempt income. In the present case, there being no expenditure incurred for earning dividend and no proximate cause in relationship with the tax-free dividend, no disallowace under section 14A is warranted. The aforesa…

ACIT, New Delhi vs. M/S. Ntpc Ltd., New Delhi

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 3194/DEL/2016[2006-07]Status: DisposedITAT Delhi04 May 2022AY 2006-07

Bench: Sh. A.D. Jaindr. B. R. R. Kumar(Through Video Conferencing) Ita No. 3590/Del/2014 : Asstt. Year: 2006-07 Ita No.3194 /Del/2016 : Asstt. Year: 2006-07 Dcit, Vs Ntpc Limited, Circle-18(2), Ntpc Bhawan, Scope Complex, New Delhi-110002 7, Institutional Area, Lodi Road, New Delhi-110003 (Appellant) (Respondent) Pan No. Aaacn0255D

For Appellant: Sh. Ved Jain, AdvFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 14ASection 27Section 271(1)(c)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI Before Sh. A.D. Jain, Vice President Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 3590/Del/2014 : Asstt. Year: 2006-07 ITA No.3194 /Del/2016 : Asstt. Year: 2006-07 DCIT, Vs NTPC Limited, Circle-18(2), NTPC Bhawan, Scope Complex, New Delhi-110002 7, Institutional Area, Lodi Road, New Delhi-110003 (APPELLANT) (RESPONDENT) PAN No. AAACN0255D ITA No. 3535/Del/2014 : Asstt. Year: 2006-07 ITA No. 2972/Del/2016 : Asstt. Year: 2006-07 NTPC Limited, Vs DCIT, NTPC Bhawan, Scope Complex, Circle-18(2), 7, Institutional Area, Lo…