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 367,181 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.

The Karur Vysya Bank Ltd., Karur vs. ACIT, Trichy

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

ITA 54/CHNY/2018[2012-13]Status: DisposedITAT Chennai10 Jan 2020AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं/.Ita No. 54/Chny/2018 "नधा#रण वष# / Assessment Year : 2012-13 The Karur Vysya Bank Ltd., The Assistant Commissioner Of Registered & Central Office, V. Income Tax, Erode Road, Circle 2(1), Karur 639002. Tiruchirapalli. Pan : Aaact 3373J

For Appellant: Shri S. Ananthan, CAFor Respondent: Shri S. Bharath, CIT
Section 143(3)Section 14A

…t was to the tune of 0.99%, the disallowable portion under rule 8D(2)(i) worked out at Rs. 2,72,366/- and hence he directed the AO to disallowance this sum. Relying on the Supreme Court decision in the case of CIT vs Walfort Stock Brokers Pvt. Ltd., (2010) 326 ITR 1 (SC) and Godrej & Boyce Manufacturing Co. Ltd. vs DCIT and another (2017) 394 ITR 449 (SC), the CIT(A) held that section 14A is applicable in the assessee’s case and hence confirmed the disallowance made u/s.14A r.w.r. 8D(2)(ii) by the AO also. Thus, the Ld. CIT(A) has enhanced the disallowance. Thus, the Ld. DR supported the orders of the lower…

DCIT Circle 2(1), Trichy vs. The Karur Vysya Bank Ltd., Karur

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

ITA 3197/CHNY/2017[2012-13]Status: DisposedITAT Chennai10 Jan 2020AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं/.Ita No. 54/Chny/2018 "नधा#रण वष# / Assessment Year : 2012-13 The Karur Vysya Bank Ltd., The Assistant Commissioner Of Registered & Central Office, V. Income Tax, Erode Road, Circle 2(1), Karur 639002. Tiruchirapalli. Pan : Aaact 3373J

For Appellant: Shri S. Ananthan, CAFor Respondent: Shri S. Bharath, CIT
Section 143(3)Section 14A

…t was to the tune of 0.99%, the disallowable portion under rule 8D(2)(i) worked out at Rs. 2,72,366/- and hence he directed the AO to disallowance this sum. Relying on the Supreme Court decision in the case of CIT vs Walfort Stock Brokers Pvt. Ltd., (2010) 326 ITR 1 (SC) and Godrej & Boyce Manufacturing Co. Ltd. vs DCIT and another (2017) 394 ITR 449 (SC), the CIT(A) held that section 14A is applicable in the assessee’s case and hence confirmed the disallowance made u/s.14A r.w.r. 8D(2)(ii) by the AO also. Thus, the Ld. CIT(A) has enhanced the disallowance. Thus, the Ld. DR supported the orders of the lower…

M/S. Religare Securities Ltd., New Delhi vs. ACIT, New Delhi

The appeal of the assessee stands allowed in terms of our directions contained in the preceding

ITA 2282/DEL/2013[2008-09]Status: DisposedITAT Delhi13 Dec 2019AY 2008-09

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavaasstt. Year: 2008-09

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Smt. Sulekha Verma, CIT(DR)
Section 143(1)Section 14ASection 28Section 36Section 36(1)(ii)Section 37(1)

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER Asstt. Year: 2008-09 M/s. Religare Securities Ltd., Vs. ACIT D3, P3B, District Centre, Saket Circle-15(1), New Delhi. New Delhi. (Appellant) (Respondent) Assessee by: Shri Rohit Jain, Advocate Ms. Tejasvi Jain, Advocate Ms. Somya Jain, CA Department by : Smt. Sulekha Verma, CIT(DR) Date of Hearing 18/09/2019 Date of 13/12/2019 pronouncement O R D E R PER SUDHANSHU SRIVASTAVA, JM: This appeal by the assessee pertains to assessment year 2008-09 and challenges…

Modern Insulators Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is allowed

ITA 74/JPR/2019[2014-15]Status: DisposedITAT Jaipur05 Dec 2019AY 2014-15
For Appellant: Shri Madhukar Garg (CA)For Respondent: Smt. Runi Pal (JCIT)
Section 14A

…tion shall be allowable in respect of expenditure incurred in relation to the earning of income exempt from taxation. As observed by the Supreme Court in the judgment in the case of Commissioner of Income-tax v. Walfort Share and Stock Brokers (P) Ltd. [2010] 326 ITR 1 '.... The mandate of s.14A is clear. It desires to curb the practice to claim deduction of expenses incurred in relation to exempt income against taxable income and at the same time avail of the tax incentive by way of an exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income.' 10. The provisio…

M/S. Unitech Infra- Con Ltd., New Delhi vs. DCIT, New Delhi

The appeal is allowed

ITA 6679/DEL/2015[2010-11]Status: DisposedITAT Delhi15 Nov 2019AY 2010-11

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

Section 14ASection 14A(2)Section 250

…d CIT(A), which included the following decisions:- 1. Wimco Seedings Ltd. Vs. DCIT. 107 ITD 267 (Del) 2. Impulse (India) (P) Ltd. vs. ACIT, 22 SOT 368(Del). 3. Maruti Udyog Ltd. vs. DCIT, 92 ITD 119 (Del). 4. CIT vs. Walfort Share and Stock Brokers (P) Ltd. 326 ITR 1 (SC). 5. CIT vs. Calcutta Agency Ltd. [195] 19 ITR 191. 6. Saraswati Industrial Syndicate Ltd. vs. CIT [1982] 136 ITR 361. 7. The Printers House Pvt. Ltd. in ITA No. 227/2009 dated 16.04.2009. 8. CIT vs. Hindustan Tin Works Limited in ITA No. 55/2009 dated 13.02.2009. 9. Design Co. Ltd. (presently known as PBC Ventures Ltd.) in ITA No. 803/2008 dat…

I.T.O., Ward-8(1), Kolkata vs. M/S Caravan Creation Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 99/KOL/2019[2014-15]Status: DisposedITAT Kolkata13 Nov 2019AY 2014-15

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.99/Kol/2019 ("नधा"रणवष" / Assessment Year: 2014-15)

For Appellant: NoneFor Respondent: Smt. Ranu Biswas, Addl. CIT
Section 143(3)Section 14A

…providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of income exempt from taxation. As observed by the Supreme Court in the judgment in the case of CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211." The M/s Caravan Creation Pvt. Ltd. Assessment Year:2014-15 mandate of s. 14A is clear. It desires to curb the practice to claim deduction of expenses incurred in relation to exempt income against taxable income and at the same time avail of the tax incentive by way of an exemption of exempt income without making any apportionment o…

ITO, New Delhi vs. M/S. Pushpanjli Fincon Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 2216/DEL/2017[2012-13]Status: DisposedITAT Delhi01 Oct 2019AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Smt. Sulekha Verma, CIT-D.RFor Respondent: Shri Gautam Jain, Adv
Section 143(3)Section 14ASection 36Section 57

…and could not have been made applicable in respect of assessment years prior to 2007 when this rule was inserted.” 7. She also referred to judgment of Hon’ble Supreme Court in the case of CIT vs. Walfort Share and Stock Brokers P. Ltd., as reported in (2010) 326 ITR 1 (SC) on the issue of disallowance u/s.57(iii) and 36(1)(iii) made by the Assessing Officer. She strongly relied upon the order of the Assessing Officer whereas assessee is not a NBFC and how the interest expenditure cannot be treated as business expenditure and therefore, Assessing Officer has rightly disallowed the same. 9 I.T.A. No.2216/DEL/2017…

DCIT (Ltu), New Delhi vs. M/S. Rasandik Engineering Industries India Ltd., New Delhi

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

ITA 1526/DEL/2013[2009-10]Status: DisposedITAT Delhi20 Sept 2019AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Shri Surender Pal, Sr. DR
Section 14A

…tion shall be allowable in respect of expenditure incurred in relation to the earning of income exempt from taxation. As observed by the Supreme Court in the judgment in the case of Commissioner of Income-tax v. Walfort Share and Stock Brokers (P) Ltd. [2010] 326 ITR 1 '.... The mandate of s.14A is clear. It desires to curb the practice to claim deduction of expenses incurred in relation to exempt income against taxable income and at the same time avail of the tax incentive by way of an exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income.' 10. The provis…

M/S Rasandik Enginnering Industries India Ltd., New Delhi vs. ACIT, New Delhi

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

ITA 1158/DEL/2013[2009-10]Status: DisposedITAT Delhi20 Sept 2019AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Shri Surender Pal, Sr. DR
Section 14A

…tion shall be allowable in respect of expenditure incurred in relation to the earning of income exempt from taxation. As observed by the Supreme Court in the judgment in the case of Commissioner of Income-tax v. Walfort Share and Stock Brokers (P) Ltd. [2010] 326 ITR 1 '.... The mandate of s.14A is clear. It desires to curb the practice to claim deduction of expenses incurred in relation to exempt income against taxable income and at the same time avail of the tax incentive by way of an exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income.' 10. The provis…

Nanda Exim Pvt Ltd, Chennai vs. ACIT, Corp Ward -4(2), Chennai

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

ITA 408/CHNY/2019[2015-16]Status: DisposedITAT Chennai08 Aug 2019AY 2015-16

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Raoआयकर अपील सं./Ita No.408/Chny/2019 "नधा"रण वष" /Assessment Year : 2015-16 M/S Nanda Exim Pvt. Ltd., The Assistant Commissioner Of No.33, Bharathidasan Street, V. Income Tax, Nethaji Avenue Extension, Corporate Ward – 4(2), Nerkundram, Chennai - 600 107. Chennai - 600 034. Pan : Aaccn 9282 C (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri S. Bharath, CIT
Section 14A

…आयकर अपील"य अ"धकरण, ‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एन.आर.एस. गणेशन, "या"यक सद"य एवं "ी इंटूर" रामा राव, लेखा सद"य केसम" BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.408/Chny/2019 "नधा"रण वष" /Assessment Year : 2015-16 M/s Nanda Exim Pvt. Ltd., The Assistant Commissioner of No.33, Bharathidasan Street, v. Income Tax, Nethaji Avenue Extension, Corporate Ward – 4(2), Nerkundram, Chennai - 600 107. Chennai - 600 034. PAN : AACCN 9282 C (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by :…

ACIT, New Delhi vs. M/S Theolia Wind Power Pvt. Ltd., New Delhi

ITA 503/DEL/2012[2008-09]Status: DisposedITAT Delhi29 Jul 2019AY 2008-09

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: Shri Anil Kumar Chopra, FCAFor Respondent: Smt. Naina Soin Kapil, Senior DR
Section 14A

…iture incurred to earn exempt income can be disallowed and any business loss is not covered u/s 14A; that exchange fluctuation loss is not an expenditure under the mandate of section 14A and relied upon CIT vs. Walfort Share & Stock Brokers (P.) Ltd. (2010) 326 ITR 1 (SC), Vishnu Anant Mahajan vs. ACIT (2012) 22 taxmann.com 88 (Ahd.)(SB), Hoshand D Nanvati vs. ACIT (2012) 25 taxmann.com 141 9 ITA No.503/Del./2012 ITA No.134/Del./2014 (Mum.), DCIT vs. Af-Taab Investment Co. Ltd. ITA No.6573/Mum/2014 dated 16.11.2017, Navin Bharat Industries Ltd. vs. DCIT (2004) 90 ITD 1 (Mum.)(TM) and Woodward Governor India…

M/S. Theolia Wind Power Pvt. Ltd., New Delhi vs. ACIT, New Delhi

ITA 134/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jul 2019AY 2009-10

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: Shri Anil Kumar Chopra, FCAFor Respondent: Smt. Naina Soin Kapil, Senior DR
Section 14A

…iture incurred to earn exempt income can be disallowed and any business loss is not covered u/s 14A; that exchange fluctuation loss is not an expenditure under the mandate of section 14A and relied upon CIT vs. Walfort Share & Stock Brokers (P.) Ltd. (2010) 326 ITR 1 (SC), Vishnu Anant Mahajan vs. ACIT (2012) 22 taxmann.com 88 (Ahd.)(SB), Hoshand D Nanvati vs. ACIT (2012) 25 taxmann.com 141 9 ITA No.503/Del./2012 ITA No.134/Del./2014 (Mum.), DCIT vs. Af-Taab Investment Co. Ltd. ITA No.6573/Mum/2014 dated 16.11.2017, Navin Bharat Industries Ltd. vs. DCIT (2004) 90 ITD 1 (Mum.)(TM) and Woodward Governor India…

Smt Ruchika Agarwal, Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is allowed

ITA 270/JPR/2019[2011-12]Status: DisposedITAT Jaipur23 Jul 2019AY 2011-12
For Appellant: Shri Vijay Goyal (CA)For Respondent: Shri K.C. Meena (Addl.CIT)
Section 143(3)Section 147Section 148Section 14ASection 3

…ts in support of the proposition that no disallowance is warranted when there is no exempt income earned by the assessee: (i) CIT (Central)-1 Vs Chettinad Logistics Pvt. Ltd. (2018) 95 taxmann.com 250 (SC). (ii) CIT Vs Walfort Shares & Stock Brokers Pvt. Ltd. 326 ITR 1. 5 ITA 270/JP/2019_ Ruchika Agarwal Vs DCIT (iii) Pr.CIT Vs Shri Prakash Gwalera (2018) (11) TMI 877. (iv) CU Vs Hero Cycles Ltd. 323 ITR 518. (v) ACIT Vs M. Baskaran (2015) 152 ITD 844 (Chennai Trib). 6. On the other hand, it was argued by the ld DR that the assessee has not disclosed exempt income earned and also the expenditure attributable to…

Tulsi Extrusions Ltd., Jalgaon vs. Joint Commisssioner of Income-Tax

In the result, appeal of the Revenue in ITA No

ITA 1434/PUN/2014[2010-11]Status: DisposedITAT Pune19 Jul 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.1434/Pun/2014 नििाारण वषा / Assessment Year : 2010-11 Tulsi Extrusions Ltd. N-99 & 100, Midc Area, Ajantha Road, Jalgaon, Dist. Jalgaon, Pin-425 003 Pan : Aaact8441P .......अऩीऱाथी / Appellant बिाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Jalgaon. ……प्रत्यथी / Respondent

For Appellant: Shri Sunil GanooFor Respondent: Ms. Kesang Y Sherpa
Section 14A

…the assessee during the year, question of disallowance u/s.14A of the Act does not arise. For this proposition, the assessee has relied on the decision of the Hon‟ble Apex Court in the case of CIT Vs. Walfort Share & Stock Brokers (P) Ltd. reported in (2010) 41 DTR 233 wherein it was held that “ for attracting section 14A, there has to be a proximate cause for disallowance which is its relationship with the tax exempted income. In absence of proximate cause for disallowance u/s.14A cannot be invoked. Further, We observe, the Hon‟ble Gujarat High Court in the case of CIT Vs. Corrtech Energy P. Ltd. reported in (2…

Bank of Maharashtra, Pune vs. Deputy Commissioner of Income Tax, Pune

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

ITA 635/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri S. Ananthan with Mrs. Lalitha RFor Respondent: Mrs. Kesang Y. Sherpa

…ct of expenditure in earning exempt income from shares held as stock in trade. The Hon‟ble High Court after placing reliance on the decision of Hon‟ble Apex Court in the case of Commissioner of Income Tax Vs. Walfort Share & Stock Brokers (P) Ltd. reported as 326 ITR 1 held that that no disallowance u/s. 14A is to be made where the shares are held as stock in trade. For the sake of completeness relevant extract of the judgment is reproduced here-in-below : “26. What is of vital importance in the above judgment are the observations emphasised by us. Each of them expressly states that what is disallowed is expendit…

Bank of Maharashtra, Pune vs. Deputy Commissioner of Income Tax, Pune

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

ITA 634/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri S. Ananthan with Mrs. Lalitha RFor Respondent: Mrs. Kesang Y. Sherpa

…ct of expenditure in earning exempt income from shares held as stock in trade. The Hon‟ble High Court after placing reliance on the decision of Hon‟ble Apex Court in the case of Commissioner of Income Tax Vs. Walfort Share & Stock Brokers (P) Ltd. reported as 326 ITR 1 held that that no disallowance u/s. 14A is to be made where the shares are held as stock in trade. For the sake of completeness relevant extract of the judgment is reproduced here-in-below : “26. What is of vital importance in the above judgment are the observations emphasised by us. Each of them expressly states that what is disallowed is expendit…

Deputy Commissioner of Income Tax, Pune vs. Bank of Maharashtra, Pune

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

ITA 581/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri S. Ananthan with Mrs. Lalitha RFor Respondent: Mrs. Kesang Y. Sherpa

…ct of expenditure in earning exempt income from shares held as stock in trade. The Hon‟ble High Court after placing reliance on the decision of Hon‟ble Apex Court in the case of Commissioner of Income Tax Vs. Walfort Share & Stock Brokers (P) Ltd. reported as 326 ITR 1 held that that no disallowance u/s. 14A is to be made where the shares are held as stock in trade. For the sake of completeness relevant extract of the judgment is reproduced here-in-below : “26. What is of vital importance in the above judgment are the observations emphasised by us. Each of them expressly states that what is disallowed is expendit…

Deputy Commissioner of Income Tax, Pune vs. Bank of Maharashtra, Pune

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

ITA 579/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri S. Ananthan with Mrs. Lalitha RFor Respondent: Mrs. Kesang Y. Sherpa

…ct of expenditure in earning exempt income from shares held as stock in trade. The Hon‟ble High Court after placing reliance on the decision of Hon‟ble Apex Court in the case of Commissioner of Income Tax Vs. Walfort Share & Stock Brokers (P) Ltd. reported as 326 ITR 1 held that that no disallowance u/s. 14A is to be made where the shares are held as stock in trade. For the sake of completeness relevant extract of the judgment is reproduced here-in-below : “26. What is of vital importance in the above judgment are the observations emphasised by us. Each of them expressly states that what is disallowed is expendit…

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Mercury Projects Private Limited, Hyderabad

In the result, appeal of the revenue is dismissed

ITA 2242/HYD/2018[2014-15]Status: DisposedITAT Hyderabad31 May 2019AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Appellant: Date of hearingFor Respondent: Shri Y.V.S.T. Sai
Section 143(1)Section 143(2)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH “A”, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA Nos. 2242 & 2226/Hyd/2018 Assessment Years: 2013-14 & 2014-15 Dy. Commissioner of Income- vs. Mercury Projects Pvt. Ltd., tax, Circle – 16(2), Hyderabad. Hyderabad. PAN – AADCM 9019R (Appellant) (Respondent) Revenue by : Shri Y.V.S.T. Sai Shri P. Murali Mohan Rao Assessee by : Date of hearing : 08/05/2019 Date of pronouncement : 31/05/2019 O R D E R PER S. RIFAUR RAHMAN, A.M.: Both these appeals filed by the Revenue are directed against the orders o…

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Mercury Projects Private Limited, Hyderabad

In the result, appeal of the revenue is dismissed

ITA 2226/HYD/2018[2013-14]Status: DisposedITAT Hyderabad31 May 2019AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Appellant: Date of hearingFor Respondent: Shri Y.V.S.T. Sai
Section 143(1)Section 143(2)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH “A”, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA Nos. 2242 & 2226/Hyd/2018 Assessment Years: 2013-14 & 2014-15 Dy. Commissioner of Income- vs. Mercury Projects Pvt. Ltd., tax, Circle – 16(2), Hyderabad. Hyderabad. PAN – AADCM 9019R (Appellant) (Respondent) Revenue by : Shri Y.V.S.T. Sai Shri P. Murali Mohan Rao Assessee by : Date of hearing : 08/05/2019 Date of pronouncement : 31/05/2019 O R D E R PER S. RIFAUR RAHMAN, A.M.: Both these appeals filed by the Revenue are directed against the orders o…