Isl Consulting Limited, Ahmedabad vs. The DCIT, Circle-2(1)(1) ( Previously DCIT, Cen. Circ. 1(3), Chennai), Ahmedabad
In the result, appeal filed by the assessee is dismissed
ITA 218/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad20 May 2025AY 2012-13
Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)
For Appellant: Shri S N Divatia & Shri Samir VoraFor Respondent: Shri Ravindra, Sr. DR
Section 143(3)Section 14ASection 250
…total income and is exempt from tax. This triggers the applicability of Section 14-A of the Act which is based on the theory of apportionment of expenditure between taxable and non-taxable income as held in Walfort Share and Stock Brokers (P) Ltd. case (2010) 8 SCC 137, (2010) 326 ITR 1. Therefore, to that extent, depending upon the facts of each case, the expenditure incurred in acquiring those shares will have to be apportioned. 49. We note from the facts in State Bank of Patiala case (2017) 391 ITR 218 (P&H) that the AO, while passing the assessment order, had already restricted the disallowance to the amount…