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.

How many judgments cite CIT v. Walfort Share & Stock Brokers (P.) Ltd.?

543 judgments on BharatTax cite CIT v. Walfort Share & Stock Brokers (P.) Ltd. (326 ITR 1), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. Walfort Share & Stock Brokers (P.) Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 143(3), Section 94(7), Section 10(35), Section 133A, Section 148.

CIT v. Walfort Share & Stock Brokers (P.) Ltd. (326 ITR 1)

DCIT, C-11(1), New Delhi vs. Hero Motocorp Ltd., New Delhi

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

…lowance followed by the assessee. In the absence of any satisfaction recorded in the assessment order, the disallowance as per Rule 8D needs to be deleted. Reliance in this . regard is placed on the following decisions: - CIT vs. Walfort Share & Stock Brokers 326 ITR 1(SC) - Godrej & Boyce Manufacturing Company Ltd. VS. DCIT: 394 ITR 449(SC) Maxopp Investment Ltd: 347 ITR 272 (Del.)- Affirmed by the Hon’ble Supreme Court in 402 ITR 640 - CIT v. Essar Teleholdings Ltd.: 401 ITR 445 (SC) - PCIT v. Vedanta Ltd.: [2019] 261 Taxman 179 (Delhi) 32 - H.T. Media Limited v. PCIT: 399 ITR 576 (Del) - Eicher Motors Ltd. vs…

ITO 3(3)(2), Mumbai vs. Satya Securities Ltd, Mumbai

In the result, the present appeal is partly allowed

ITA 3175/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Jan 2023AY 2012-13

For Appellant: Shri A.K. Tibrewal & Saurabh GuptaFor Respondent: Shri A.K. Das

Section 143(3)Section 14ASection 68

…riggers the provisions of Section 14A of the Act. Therefore, based upon the theory of apportionment of expenditure between taxable and non-taxable income as held by the Hon'ble Supreme Court in the case of CIT Vs. Walfort Share and Stock Brokers P. Ltd [2010] 326 ITR 1 (SC), the expenditure incurred in acquiring such shares which are held as stock-in-trade would have to be apportioned. The Hon'ble Supreme Court discarded the theory of dominant intention adopted by the Hon'ble Punjab & Haryana High Court. However, the Hon'ble Supreme Court held that the decision arrived at by the Hon'ble Punjab & Haryana High Cour…

DCIT 3(3)(1), Mumbai vs. Satya Securities Ltd, Mumbai

In the result, the present appeal is partly allowed

ITA 6674/MUM/2016[2010-11]Status: DisposedITAT Mumbai31 Jan 2023AY 2010-11

For Appellant: Shri A.K. Tibrewal &For Respondent: Shri A.K. Das

Section 14ASection 68

…iggers the provisions of Section 14A of the Act. Therefore, based upon the theory of apportionment of expenditure between taxable and non- taxable income as held by the Hon'ble Supreme Court in the case of CIT Vs. Walfort Share and Stock Brokers P. Ltd [2010] 326 ITR 1 (SC), the expenditure incurred in acquiring such shares which are held as stock-in-trade would have to be apportioned. 21. We note that the total exempt dividend income earned by the Appellant during the relevant previous year of INR 7,44,000/- Assessing Officer made a disallowance of INR 12,98,886/- under Section 14A of the Act read with Rule 8D…

S N Tradelink Private Limited, Surat vs. Pr. Commissioner of Income Tax-1, Surat

In the result, appeal filed by the assessee is allowed

ITA 77/SRT/2022[2017-18]Status: DisposedITAT Surat24 Jan 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.77/Srt/2022 िनधा"रणवष"/Assessment Year: (2017-18) (Physical Court Hearing) S. N. Tradelink Private Limited, Principal Commissioner Of 3010-3011 Momai Complex, Income Tax-1, Room No. 114, 1St Kadodra Road, Umarvada, Surat – Vs. Floor, Aaykar Bhawan, 395010. Majura Gate, Opp New Civil Hospital, Surat-395001 (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakcs0060R

Section 115BSection 131Section 133ASection 139Section 143(3)Section 263Section 271ASection 69C

…duct of mankind is to be regulated when introduced for the first time to deal with future acts ought not to change the character of past transactions carried on upon the faith of the then existing law." • CIT v. Walfort Shares & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211(SC) It has been held by Honourable Supreme Court that "Retrospective operation of law should not be given so as to effect, alter or destroy an existing right and to create new liability or obligation. New liability cannot be created by a subsequent amendment in respect of a transaction when such law was not in the Statute book." • CI…

The Assisstant Commissioner of Income Tax-15(1)(1), Mumbai vs. Gauri Tandon, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1846/MUM/2022[2015-2016]Status: DisposedITAT Mumbai18 Jan 2023AY 2015-2016

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleacit – 15(1)(1) V. Gauri Tandon Aayakar Bhavan, M.K. Road Tandon Beach House Mumbai - 400020 Plot No. 35(Pt), Aajad Road Juhu Koliwada, Santacruz (W) Mumbai - 400049 Pan: Aaapb4013C (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta Department Represented By : Shri Smiti Samant

Section 133(6)Section 54Section 54BSection 90

…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…

Assistant Commissioner of Income Tax 1(3)(2), Mumbai vs. Varsity Education Management Private Limited, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1109/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Jan 2023AY 2014-15

Bench: Shri Kuldip Singh & Shri Gagan Goyalacit-1(3)(2), Room No. 540, 5Th Floor, Aayakar Bhavan, M.K. Road, Mumbai-400020 ...... Appellant Vs. M/S Varsity Education Mgt. Pvt. Ltd. 6A/1, Court Chambers, 35, New Marine Lines, Mumbai-400020. Pan: Aadcv6100E ..... Respondent Appellant By : Vranda U Matkarni, Sr.-Dr Respondent By : None Date Of Hearing : 17/10/2022 Date Of Pronouncement : 13/01/2023 Order Per Gagan Goyal, A.M: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-3, Mumbai [For Short ‘Cit(A)’] Dated 25.10.2017 Under Section 143(3) Of The Income Tax Act, 1961 (For Short ‘The Act’) For A.Y. 2014-15. The Revenue Has Raised The Following Ground Of Appeal:

For Appellant: Vranda U Matkarni, Sr.-DRFor Respondent: None

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ACIT-1(3)(2), Room No. 540, 5th Floor, Aayakar Bhavan, M.K. Road, Mumbai-400020 ...... Appellant Vs. M/s Varsity Education Mgt. Pvt. Ltd. 6A/1, Court Chambers, 35, New Marine Lines, Mumbai-400020. PAN: AADCV6100E ..... Respondent Appellant by : Vranda U Matkarni, Sr.-DR Respondent by : None Date of hearing : 17/10/2022 Date of pronouncement : 13/01/2023 ORDER PER GAGAN GOYAL, A.M: This appeal by the Revenue is directed against the order of Commissioner of Income Tax (…

State Bank of India, Mumbai vs. DCIT, Mumbai

In the result, the present appeal is partly allowed

ITA 2446/MUM/2021[2015-16]Status: DisposedITAT Mumbai10 Jan 2023AY 2015-16

For Appellant: Shri Ketan Ved & Ms. ShraddhaFor Respondent: Shri Sanyam Suresh Joshi

Section 143(3)Section 14ASection 254

…Therefore, based upon the theory of apportionment of expenditure between taxable and non-taxable income as held ITA. No. 2446//Mum/2021 Assessment Year: 2015-16 by the Hon'ble Supreme Court in the case of CIT Vs. Walfort Share and Stock Brokers P. Ltd [2010] 326 ITR 1 (SC), the expenditure incurred in acquiring such shares which are held as stock-in-trade would have to be apportioned. The Hon'ble Supreme Court discarded the theory of dominant intention adopted by the Hon'ble Punjab & Haryana High Court. However, the Hon'ble Supreme Court held that the decision arrived at by the Hon'ble Punjab & Haryana High Cour…

ACIT, Circle-12(1), New Delhi vs. Icra Limited, New Delhi

ITA 9199/DEL/2019[2016-17]Status: DisposedITAT Delhi10 Jan 2023AY 2016-17

Bench: Sh. Pradip Kumar Kedia & Sh. Anubhav Sharmaacit, Vs. M/S. Icra Limited 1105, 11Th Floor, Circle-12(1), New Delhi Kailash Building 26, Kasturba Gandhi Marg, Connaught Place, New Delhi-110001 Pan : Aaacg7758B Appellant Respondent

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘C’ : NEW DELHI) BEFORE SH. PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ACIT, Vs. M/s. ICRA Limited 1105, 11th Floor, Circle-12(1), New Delhi Kailash Building 26, Kasturba Gandhi Marg, Connaught Place, New Delhi-110001 PAN : AAACG7758B Appellant Respondent Cross Objection no. 42/Del/2022 (in appeal no. 9199/Del/2019) (Assessment Year : 2016-17) M/s. ICRA Limited Vs. ACIT, B-710, Statesman House Circle-12(1), 148, Barakhamba Road New Delhi New Delhi-110001 PAN : AAACI0218B Appellant Respondent Revenue by Smt. Sunita Singh, CI…

ACIT, Kochi vs. Federal Bank Ltd, Aluva

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 35/COCH/2020[2010-11]Status: DisposedITAT Cochin12 Dec 2022AY 2010-11

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

ACIT, Kochi vs. Federal Bank Ltd, Aluva

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 34/COCH/2020[2009-10]Status: DisposedITAT Cochin12 Dec 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

ACIT, Kochi vs. Federal Bank Ltd, Aluva

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 33/COCH/2020[2008-09]Status: DisposedITAT Cochin12 Dec 2022AY 2008-09

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The ACIT, Kochi vs. M/S.Federal Bank Ltd, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 311/COCH/2020[2014-15]Status: DisposedITAT Cochin12 Dec 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The ACIT, Kochi vs. The Federal Bank Ltd, Ernakulam

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 310/COCH/2020[2008-09]Status: DisposedITAT Cochin12 Dec 2022AY 2008-09

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The ACIT, Kochi vs. M/S.Federal Bank Ltd, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 309/COCH/2020[2012-13]Status: DisposedITAT Cochin12 Dec 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 275/COCH/2020[2014-15]Status: DisposedITAT Cochin12 Dec 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 274/COCH/2020[2013-14]Status: DisposedITAT Cochin12 Dec 2022AY 2013-14

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 273/COCH/2020[2012-13]Status: DisposedITAT Cochin12 Dec 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 272/COCH/2020[2011-12]Status: DisposedITAT Cochin12 Dec 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 747/COCH/2019[2010-11]Status: DisposedITAT Cochin12 Dec 2022AY 2010-11

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

In the result, appeals of the Assessee and revenue for AY 2008-09 to 2010-

ITA 746/COCH/2019[2009-10]Status: DisposedITAT Cochin12 Dec 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri Rajesekharan, CA and Shri K.Gopi, CAFor Respondent: Smt. J. M. Jamuna Devi, Sr. DR, Cochin

Section 147Section 14ASection 154

…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…

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

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

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

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

DCIT, C-11(1), New Delhi vs. Hero Motocorp Ltd., New Delhi

ITO 3(3)(2), Mumbai vs. Satya Securities Ltd, Mumbai

DCIT 3(3)(1), Mumbai vs. Satya Securities Ltd, Mumbai

S N Tradelink Private Limited, Surat vs. Pr. Commissioner of Income Tax-1, Surat

The Assisstant Commissioner of Income Tax-15(1)(1), Mumbai vs. Gauri Tandon, Mumbai

Assistant Commissioner of Income Tax 1(3)(2), Mumbai vs. Varsity Education Management Private Limited, Mumbai

State Bank of India, Mumbai vs. DCIT, Mumbai

ACIT, Circle-12(1), New Delhi vs. Icra Limited, New Delhi

ACIT, Kochi vs. Federal Bank Ltd, Aluva

ACIT, Kochi vs. Federal Bank Ltd, Aluva

ACIT, Kochi vs. Federal Bank Ltd, Aluva

The ACIT, Kochi vs. M/S.Federal Bank Ltd, Kochi

The ACIT, Kochi vs. The Federal Bank Ltd, Ernakulam

The ACIT, Kochi vs. M/S.Federal Bank Ltd, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi

The Federal Bank Ltd, Aluva vs. The ACIT, Kochi