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 366,470 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.

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

In the result, appeals filed by the assessee in I

ITA 4246/MUM/2024[AY 2013-14]Status: DisposedITAT Mumbai17 Oct 2024

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said judgments, but do not think that there is any ground or reason to not follow the clear and categorical ratio of the decisions of the Delhi High Cour…

Pee Kay Vanijya Pvt. Ltd., Kolkata vs. DCIT, Cir. 7(1), Kolkata

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

ITA 851/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Sept 2024AY 2017-18

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2017-18

For Appellant: Akkal Dudhwewala, ARFor Respondent: S.B. Chakraborthy, JCIT, Sr. DR
Section 143(3)Section 14ASection 234BSection 250

…arned but the reply was not found tenable in view of the CBDT’s Circular No. 5/2014 [F.No. 225/182/2013-ITAII] dated 11.02.2014. The Ld.AO also relied upon the decision of the Hon’ble Supreme Court in the case of CIT Vs. Walfort Share and Stock Brokers P Ltd. 326 ITR 1(SC), Maxopp Investment Ltd. Vs. CIT [2018] 91 taxmann.com 154 and B. Laly Motors India P. Ltd. Vs. PCIT, Jalandhar of Amritsar ITAT reported in 93 taxmann.com 39. The AO considered the average total investment as on 31.03.2016 and 31.03.2017 and computed the disallowance of Rs. 35,22,568/-. The Ld. AO relied upon the decision of the CIT Vs. Goetze…

DCIT, New Delhi vs. M/S. Net 4 India Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed, in the terms indicated herein above

ITA 3657/DEL/2017[2010-11]Status: DisposedITAT Delhi09 Sept 2024AY 2010-11

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2010-11] Dcit, Vs M/S. Net 4 India Ltd., Circle-18(1), Ab-11, Community Centre, New Delhi. Safdarjung Enclave, New Delhi-110029. Pan-Aaact0291M Appellant Respondent Appellant By Shri Subhra Jyoti Chakraborty, Cit Dr Respondent By None Date Of Hearing 29.08.2024 Date Of Pronouncement 09.09.2024 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By Ld.Cit(A)-42, New Delhi Dated 17.03.2017 For The Assessment Year 2010-11. 2. The Revenue Has Raised Following Grounds Of Appeal:-

Section 14Section 145(3)

…tances of the case, the Ld.CIT(A) is legally justified in not upholding the disallowance u/s 14 A of the Act r.w. R SD of the Rule of Rs. 79,41,003/- without considering ratio decidendi as upheld in cases of CIT Vs Walfort Share and Stock Brokers P Ltd [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT [2012] 347 ITR 272 (Delhi) on application of provisions of section 14 A of the Act? 9. That the appellant craves leave to add, amend, alter or forgo any ground/(s) of appeal either before or at the time of hearing of the appeal.” 3. At the time of hearing, no one attended the proceedings on behalf of the assessee.…

Rashleela Enterprises Private Limited, Jaipur vs. The PCIT (Central), Jaipur

ITA 461/JPR/2024[2019-20]Status: DisposedITAT Jaipur05 Sept 2024AY 2019-20
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 153DSection 263

…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 vs. 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…

Balram Chainrai, Mumbai vs. Int Tax, Ward 2(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 2267/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Aug 2024AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Sunil Kumar Singh, Jm

For Appellant: Shri Ravikant Pathak, ARFor Respondent: Shri Anil Sant, Addl. CIT-DR
Section 144BSection 147Section 148Section 153Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS PADMAVATHY S, AM & SHRI SUNIL KUMAR SINGH, JM I.T.A. No. 2267/Mum/2024 (Assessment Year: 2016-17) Shri Balram Chainrai, Int. Tax, Ward-3(3(1) 1724, 17th Floor, Air India 304, Marine Chambers, New Marine Lines, Churchgate, Vs. Building, Nariman Point, Mumbai-400021. Mumbai-400021. PAN : AFRPC7389E Appellant) : Respondent) Appellant/Assessee by : Shri Ravikant Pathak, AR Revenue/Respondent by : Shri Anil Sant, Addl. CIT-DR : 22.08.2024 Date of Hearing : 27.08.2024 Date of Pronouncement O R D E R Per Padmavathy S, AM: This appeal by the assessee is…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 399/COCH/2023[2017-18]Status: DisposedITAT Cochin13 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 397/COCH/2023[2015-16]Status: DisposedITAT Cochin13 Aug 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 396/COCH/2023[2014-15]Status: DisposedITAT Cochin13 Aug 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 395/COCH/2023[2013-14]Status: DisposedITAT Cochin13 Aug 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 394/COCH/2023[2012-13]Status: DisposedITAT Cochin13 Aug 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Federal Bank Ltd, Kochi vs. ACIT Corp. Circle-1(1 ), Kochi

ITA 393/COCH/2023[2011-12]Status: DisposedITAT Cochin13 Aug 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Gopi, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144Section 147Section 14ASection 36Section 36(1)(viii)

…e total income and is exempt from tax. Hence, the expenditure incurred in acquiring those shares will have to be apportioned, based on the facts of each case, between taxable and non-taxable income as held in the case of Walfort Share and Stock Brokers P Ltd. 326 ITR 1 (SC). The ruling seems to suggest that expenditure needs to be apportioned between these two sources, though it is silent on the manner thereon. It was submitted that the Delhi Bench of the ITAT in the case of Punjab National Bank Ltd. Vs. DCIT ITA No. 1519/Del/2016 for AY: 2012-13 by order dated 28.11.2018 held that in the case of Banks investment…

Shiv Nadar and Sanjay Kalra Associates LLP, Bengaluru vs. Assistant Commissioner of Income-Tax, Circle 1(2)(2), Bangalore, Bengaluru

In the result, we don to find any merit in this appeal, the same fails and is hereby dismissed

ITA 890/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Jul 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadavassessment Year : 2017-18

For Appellant: Shri Ravishankar S., AdvocateFor Respondent: Shri V. Parithivel, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14ASection 234ASection 234BSection 234CSection 37(1)

…of exemption of exempt income without making any apportionment of expenses incurred in relation to exempt income. The High Court of Madras has relied on the decision of the Supreme Court in Commissioner of Income Tax v. Walfort Share and Stock Brokers (2010) 326 ITR 1 wherein it has been held that Section 14A is relatable to income of actual income or not notional or anticipated income. Therefore, the conclusion arrived at by us in Novel Software India (P.) Ltd. is affirmed but for different reasons. It is also clarified by us that while recording the conclusion in Kingfisher Finvest Ltd. that disallowance under…

JCIT (OSD) Circle- 16(2), New Delhi vs. Mayar Health Resorts Pvt. Ltd., New Delhi

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is partly allowed

ITA 3548/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Jul 2024AY 2011-12

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Raghav Sharma, CA &For Respondent: Sh. Anshul, Sr. DR
Section 143(3)Section 145(2)Section 145(3)Section 209Section 35D(2)(c)

…ditional upon the earning of the income as upheld by Hon'ble Supreme Court in the case of CIT vs. Rajendra Prasad Moody [1978] 115 ITR 519 and without considering ratio decidendi as upheld in the cases of CIT Vs. Walfort Share and Stock Brokers P. Ltd. [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT[2012] 347 ITR 272 (Delhi) on application of provisions of section 14A of the Act? 3. Whether on the facts and circumstances of the case, fid, CIT(A) is legally justified in deleting the addition of Rs.1,33,83,324/-on account of undisclosed membership fee by not considering the fact that the assessee company is foll…

Mayar Health Resorts Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is partly allowed

ITA 326/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jul 2024AY 2010-11

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Raghav Sharma, CA &For Respondent: Sh. Anshul, Sr. DR
Section 143(3)Section 145(2)Section 145(3)Section 209Section 35D(2)(c)

…ditional upon the earning of the income as upheld by Hon'ble Supreme Court in the case of CIT vs. Rajendra Prasad Moody [1978] 115 ITR 519 and without considering ratio decidendi as upheld in the cases of CIT Vs. Walfort Share and Stock Brokers P. Ltd. [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT[2012] 347 ITR 272 (Delhi) on application of provisions of section 14A of the Act? 3. Whether on the facts and circumstances of the case, fid, CIT(A) is legally justified in deleting the addition of Rs.1,33,83,324/-on account of undisclosed membership fee by not considering the fact that the assessee company is foll…

Mayar Health Resorts Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is partly allowed

ITA 6228/DEL/2013[2009-10]Status: DisposedITAT Delhi29 Jul 2024AY 2009-10

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Raghav Sharma, CA &For Respondent: Sh. Anshul, Sr. DR
Section 143(3)Section 145(2)Section 145(3)Section 209Section 35D(2)(c)

…ditional upon the earning of the income as upheld by Hon'ble Supreme Court in the case of CIT vs. Rajendra Prasad Moody [1978] 115 ITR 519 and without considering ratio decidendi as upheld in the cases of CIT Vs. Walfort Share and Stock Brokers P. Ltd. [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT[2012] 347 ITR 272 (Delhi) on application of provisions of section 14A of the Act? 3. Whether on the facts and circumstances of the case, fid, CIT(A) is legally justified in deleting the addition of Rs.1,33,83,324/-on account of undisclosed membership fee by not considering the fact that the assessee company is foll…

Mayar Health Resorts Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is partly allowed

ITA 5109/DEL/2012[2008-09]Status: DisposedITAT Delhi29 Jul 2024AY 2008-09

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Raghav Sharma, CA &For Respondent: Sh. Anshul, Sr. DR
Section 143(3)Section 145(2)Section 145(3)Section 209Section 35D(2)(c)

…ditional upon the earning of the income as upheld by Hon'ble Supreme Court in the case of CIT vs. Rajendra Prasad Moody [1978] 115 ITR 519 and without considering ratio decidendi as upheld in the cases of CIT Vs. Walfort Share and Stock Brokers P. Ltd. [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT[2012] 347 ITR 272 (Delhi) on application of provisions of section 14A of the Act? 3. Whether on the facts and circumstances of the case, fid, CIT(A) is legally justified in deleting the addition of Rs.1,33,83,324/-on account of undisclosed membership fee by not considering the fact that the assessee company is foll…

ITO, New Delhi vs. M/S Ansal Housing & Construction Ltd., New Delhi

In the result, the cross-objection filed by the assessee is dismissed

ITA 2731/DEL/2010[2007-08]Status: DisposedITAT Delhi26 Jul 2024AY 2007-08

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2007-08] Dcit, Vs Ansal Housing & Construction Ltd., Central Circle-20, Ugf-15, Indraprastha Building, 21, New Delhi. Barakhamba Road, New Delhi. Pan-Aaaca0377R Appellant Respondent

Section 143(3)Section 14ASection 80Section 80I

…income. In the absence of such nexus being established, it is not open to the assessing officer to disallow any part of the expenditure on proportionate basis. Reliance in this regard is placed on following decisions: - CIT vs. Walfort Share & Stock Brokers: 326 ITR 1 (SC) - Godrej & Boyce Mfg. Co. Ltd. v. CIT: 394 ITR 449 (SC) - Maxopp Investment Ltd. v. CIT: 402 ITR 640 (SC) affirming decision of the Delhi High Court in Maxopp Investment Ltd. vs. CIT: 347 ITR 272 (Del.) - CIT vs. Hero Cycles: 323 ITR 518 (P&H) - CIT v. Metalman Auto P. Ltd.: 336 ITR 434 (P&H) - CIT v. Reliance Utilities and Power Ltd.: 313 ITR…

Mahadev Enclave Pvt. Ltd., Jaipur vs. PCIT(Central), Jaipur

In the result, the appeal of the assessee is allowed

ITA 636/JPR/2024[2019-20]Status: DisposedITAT Jaipur22 Jul 2024AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Anil Dhaka (CIT)
Section 10Section 143(3)Section 14ASection 263

…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 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. Consequently, the C…

Praveen Ranjan Sinha, Gurgaon vs. DCIT, Circle-3(1), Gurgaon

In the result, the appeal of the assessee is allowed and Stay Application of the assessee is dismissed as infructuous

ITA 399/DEL/2024[2015-16]Status: DisposedITAT Delhi08 Jul 2024AY 2015-16

Bench: Shri Kul Bharat & Shri M. Balaganeshpraveen Ranjan Sinha, Vs. Dcit, Icb 141, The Icon, Dlf Circle-3(1), City, Phase-V, Gurgaon, Gurgaon Haryana (Appellant) (Respondent) Pan: Ardps3000N Sa No. 57/Del/2024 (In Ita No. 399/Del/2024) (Assessment Year: 2015-16) Praveen Ranjan Sinha, Vs. Dcit, Icb 141, The Icon, Dlf Circle-3(1), City, Phase-V, Gurgaon, Gurgaon Haryana (Appellant) (Respondent) Pan: Ardps3000N Assessee By : Shri Sudesh Garg, Adv Ms. Bhavya Garg, Adv Revenue By: Shri Dharambir Singh, Cit Dr Date Of Hearing 08/04/2024 Date Of Pronouncement 08/07/2024

For Appellant: Shri Sudesh Garg, AdvFor Respondent: Shri Dharambir Singh, CIT DR
Section 143(3)Section 145Section 2Section 250Section 55(2)(aa)Section 94(8)

…s of the transactions and that at best the transaction can be termed as a 'use of the provisions of law' and it cannot be said to be 'a abuse of law', as was observed by the Hon'ble Supreme Court in the case of CIT vs. Walfort Share & Stock Brokers (P.) Ltd., 326 ITR 1 (SC) in a somewhat similar situation. 28. On the other hand, the Ld. Departmental Representative appearing for the Revenue has reiterated that the magnitude and frequency of the transactions in the HCL Technologies Ltd. shares was quite substantial which reflects that the intention of the assessee was to trade in such shares. With regard to assesse…

Subramanya Construction and Development Company Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bangalore

In the result, we don to find any merit in this appeal, the same fails and is hereby dismissed

ITA 892/BANG/2024[2014-15]Status: DisposedITAT Bangalore02 Jul 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15

For Appellant: Shri T.S. Rajan, CAFor Respondent: Shri `Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment year : 2014-15 Subramanya Constructions & Vs. The Deputy Commissioner of Development Company Ltd., Income Tax, No.42, 2nd Stage, 3rd Cross, Circle 6(1)(2), Industrial Suburb, Yeshwanthpur, Bangalore. Bangalore – 560 022. PAN : AADCS 1525J APPELLANT RESPONDENT Appellant by : Shri T.S. Rajan, CA Respondent by : Shri `Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 12.06.2024 Date of Pronouncement : 02.07.2024 O R D E R Per Laxmi Prasad Sahu,…