Garware Wall Ropes Ltd. v. ACIT

65 SOT 86Income Tax Appellate Tribunal2014#1537 most cited

What is Garware Wall Ropes Ltd. v. ACIT authority for?

Disallowance under Section 14A read with Rule 8D(2)(iii) does not apply to long-term investments, including those in subsidiary/group concerns or strategic investments, and such investments should be excluded from the calculation.

74

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Garware Wall Ropes Ltd v ACIT · Section 14A disallowance · Rule 8D(2)(iii) · long term investments · strategic investments · investments in subsidiary · investments in group concerns · expenditure relating to exempt income · ITAT decision · 65 SOT 86

Sections most often in play

Section 14ASection 244ASection 36(1)(vii)Section 36(1)(viia)Section 40(a)(ia)Section 43BSection 80-IA

Judgments citing Garware Wall Ropes Ltd. v. ACIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…umstances of the case and in law, the Ld CIT(A) has erred in directing the A.O to restrict the disallowance u/s 14A r.w.r 8D(2)(ii) by excluding the long term investments in subsidiary / group relying on the decision of ITAT in the case of Garware Wall Ropes (65 SOT 86), without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted admitted by the Hon'ble High Court. 8. On the facts and circumstances of the case and in law, the Ld CIT(A) has erred in relating loss on account of depreciation of securities of HTM category without appreciating that n…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…umstances of the case and in law, the Ld CIT(A) has erred in directing the A.O to restrict the disallowance u/s 14A r.w.r 8D(2)(ii) by excluding the long term investments in subsidiary / group relying on the decision of ITAT in the case of Garware Wall Ropes (65 SOT 86), without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted admitted by the Hon'ble High Court. 8. On the facts and circumstances of the case and in law, the Ld CIT(A) has erred in relating loss on account of depreciation of securities of HTM category without appreciating that n…

ASST CIT CIR 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

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

ITA 4564/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…he case and in law, the Ld. CIT(A) has erred in directing the AO to restrict the disallowance u/s. 14A r.w.r 8D(2)(iii) by excluding the long term investments in subsidiary/group concerns relying on the decision of ITAT in the case of Garware Wall Ropes Ltd. (65 SOT 86), without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon'ble High Court. 8. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in treating loss on account of depreciation of securities in HTM category/amortization of securities in HT…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

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

ITA 3645/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…he case and in law, the Ld. CIT(A) has erred in directing the AO to restrict the disallowance u/s. 14A r.w.r 8D(2)(iii) by excluding the long term investments in subsidiary/group concerns relying on the decision of ITAT in the case of Garware Wall Ropes Ltd. (65 SOT 86), without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon'ble High Court. 8. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in treating loss on account of depreciation of securities in HTM category/amortization of securities in HT…

DCIT 2(2)(1), MUMBAI vs. GEA PROCESSING ENGINEERING INDIA P.LTD, GUJRAT

In the result appeal of the learned assessing officer for assessment year 2010 – 11 is partly allowed and CO of the assessee allowed for statistical purposes

ITA 1213/MUM/2017[2005-06]Status: DisposedITAT Mumbai24 Feb 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 216/Mum/2017 Arising Out Of Ita No. 1213/Mum/2017 (Assessment Year 2005-06) M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 127/Mum/2017 Arising Out Of Ita No. 6494/Mum/2016 (Assessment Year 2009-10) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. Vs. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740

For Appellant: Mr. Sunil MotiLala, Adv
Section 143

…has erred in directing the Assessing Officer to restrict the disallowance u/s. 14A r.w. Rule 8D(2)(iii) by excluding the long term investments which are in the nature of strategic investments relying on the decision of ITAT in case of Garware Wall Ropes Ltd (65 SOT 86), without appreciation the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon‟ble High Court.” 035. The assessee has raised cross objection for assessment year 2010 – 11 as under CO No. 128/MUM/2017 Arising Out of ITA No. 6495/MUM/2016 (Assessment Year 2010-11) “1. On the facts and ci…

DCIT CIR 2(2)(1), MUMBAI vs. GEA PROCESSING ENGINEERING INDIA P.LTD, GUJRAT

In the result appeal of the learned assessing officer for assessment year 2010 – 11 is partly allowed and CO of the assessee allowed for statistical purposes

ITA 6495/MUM/2016[2010-11]Status: DisposedITAT Mumbai24 Feb 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 216/Mum/2017 Arising Out Of Ita No. 1213/Mum/2017 (Assessment Year 2005-06) M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 127/Mum/2017 Arising Out Of Ita No. 6494/Mum/2016 (Assessment Year 2009-10) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. Vs. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740

For Appellant: Mr. Sunil MotiLala, Adv
Section 143

…has erred in directing the Assessing Officer to restrict the disallowance u/s. 14A r.w. Rule 8D(2)(iii) by excluding the long term investments which are in the nature of strategic investments relying on the decision of ITAT in case of Garware Wall Ropes Ltd (65 SOT 86), without appreciation the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon‟ble High Court.” 035. The assessee has raised cross objection for assessment year 2010 – 11 as under CO No. 128/MUM/2017 Arising Out of ITA No. 6495/MUM/2016 (Assessment Year 2010-11) “1. On the facts and ci…

DCIT CIR 2(2)(1), MUMBAI vs. GEA PROCESSING ENGINEERING INDIA P.LTD, GUJRAT

In the result appeal of the learned assessing officer for assessment year 2010 – 11 is partly allowed and CO of the assessee allowed for statistical purposes

ITA 6494/MUM/2016[2009-10]Status: DisposedITAT Mumbai24 Feb 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 216/Mum/2017 Arising Out Of Ita No. 1213/Mum/2017 (Assessment Year 2005-06) M/S. Gea Procees Engineering Acit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad Vs. M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740 (Appellant) (Respondent) Co No. 127/Mum/2017 Arising Out Of Ita No. 6494/Mum/2016 (Assessment Year 2009-10) M/S. Gea Procees Engineering Dcit Cir 2(2)(1) (I) Pvt.Ltd. Vs. R.No. 545, Aayakar Bhavan, Savali Road, P.O. Dumad M.K.Road, Mumbai-400 020 Baroda, Gujarat-391 740

For Appellant: Mr. Sunil MotiLala, Adv
Section 143

…has erred in directing the Assessing Officer to restrict the disallowance u/s. 14A r.w. Rule 8D(2)(iii) by excluding the long term investments which are in the nature of strategic investments relying on the decision of ITAT in case of Garware Wall Ropes Ltd (65 SOT 86), without appreciation the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon‟ble High Court.” 035. The assessee has raised cross objection for assessment year 2010 – 11 as under CO No. 128/MUM/2017 Arising Out of ITA No. 6495/MUM/2016 (Assessment Year 2010-11) “1. On the facts and ci…

M/S KARNATAKA STATE BEVERAGES CORPORATION LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, the appeal of the assessee is dismissed

ITA 973/BANG/2018[2012-13]Status: DisposedITAT Bangalore09 Dec 2021AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year : 2012-13

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Chetan R., Addl. CIT(DR)(ITAT), Bengaluru
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI GEORGE GEORGE K., JUDICIAL MEMBER Assessment year : 2012-13 M/s. Karnataka State Beverages Vs. The Deputy Commissioner Corporation Lt., of Income Tax, 4th Floor, TTMC Building, ‘A’ Block, Circle 4(1)(1), BMTC, Shanthinagar, Bangalore. Bangalore – 560 027. PAN: AACCK 1421A APPELLANT RESPONDENT Appellant by : Shri S.V. Ravishankar, Advocate Respondent by : Shri Chetan R., Addl. CIT(DR)(ITAT), Bengaluru. Date of hearing : 30.11.2021 Date of Pronouncement : 09.12.2021 O R D E R Per Chandra Poojari, A…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

ITA 3644/MUM/2016[2008-09]Status: DisposedITAT Mumbai03 Feb 2020AY 2008-09

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

For Appellant: Shri P.J. Pardiwalla &For Respondent: Shri Anadi Varma, CIT-DR&
Section 143(3)Section 147

…ct the disallowance under section 14A rw.r. 8D(2)(iii) by the excluding the long term investment in subsidiary/ group concerns relying on the decision of ITAT in the case of Garware Wall 44 | P a g e State Bank of India ITA Nos.3644&4563/Mum/2016 Ropes Ltd. (65 SOT 86), without appreciating the fact that the decision of ITAT has not been accepted by the department and appeal has been admitted by the Hon’ble High Court.” Since both the grounds of Assessee and Department are dealing with the same issue of disallowance under section 14A of the Act relating to the disallowance of expenses relatable to exempt income…

THE INDIAN HOTELS COMPANY LTD,MUMBAI vs. DCIT (OSDZ0 CIR 2(2), MUMBAI

In the result the appeal of the assessee is partly allowed

ITA 9087/MUM/2010[2006-07]Status: DisposedITAT Mumbai06 Sept 2019AY 2006-07

Bench: Shri G.S. Pannu & Shri Pawan Singhthe Indian Hotels Company Ltd, Vs Dy.Cit (Osd), Circle 2(2), Mandlik House, Mandlik Road, Mumbai Colaba, Mumbai-400 001 Pan : Aaact3957G Appellant Respondednt Appellant By Shri Kanchun Kaushal & Aliasgar Rampurawala Ar’S Respondent By Shri Anand Mohan Cit-Dr Date Of Hearing 17-06-2019 Date Of Pronouncement 06-09-2019

Section 143(3)Section 253Section 254(1)

…wance made in the year 1998-99 to assessment year 2002-03 holding that the assessee is claimed is found to be correct and in order. The assessee has pointed out that as per the decision of coordinate bench in case of Garware Walls Limited versus Add. CIT 2014 65 SOT 86 (Mumbai tribunal) and other benches of the tribunal strategic investments made by the assessee as required to be excluded from the value of investment. As per the decision of Delhi bench of the tribunal only those investments are to be considered for computing the average value of investments, which yield exempt income during the year. In Godrej an…

DCIT, CIR 2(2)(2), MUMBAI vs. M.PALLONJI & CO. PVT. LTD., MUMBAI

In the result, both, the appeal of assessee as well as Revenue are partly allowed

ITA 4969/MUM/2015[2011-12]Status: DisposedITAT Mumbai09 Oct 2018AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

For Appellant: Shri Jehangir Mistri, ARFor Respondent: Shri Padma Ram, DR
Section 10(34)Section 143(3)Section 14A

…he case and in law, the Ld. CIT(A) was justified in restricting the disallowance u/s. 14A r.w. Rule 8D(2)(iii) after excluding the long term investments in subsidiary / group concerns relying on the decision of the ITAT in the case of Garware Wall Ropes Ltd. (65 SOT 86) without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon'ble High Court." 3. Briefly stated facts are that the assessee has earned the dividend income of ₹ 1,46,98,558/- and claimed the same as exempt under section 10(34) of the Act. The assessee itself disallowed…

M. PALLONJI & CO. P. LTD,MUMBAI vs. ASST CIT RG 2(2)(2), MUMBAI

In the result, both, the appeal of assessee as well as Revenue are partly allowed

ITA 4925/MUM/2015[2011-12]Status: DisposedITAT Mumbai09 Oct 2018AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

For Appellant: Shri Jehangir Mistri, ARFor Respondent: Shri Padma Ram, DR
Section 10(34)Section 143(3)Section 14A

…he case and in law, the Ld. CIT(A) was justified in restricting the disallowance u/s. 14A r.w. Rule 8D(2)(iii) after excluding the long term investments in subsidiary / group concerns relying on the decision of the ITAT in the case of Garware Wall Ropes Ltd. (65 SOT 86) without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeal has been admitted by the Hon'ble High Court." 3. Briefly stated facts are that the assessee has earned the dividend income of ₹ 1,46,98,558/- and claimed the same as exempt under section 10(34) of the Act. The assessee itself disallowed…

ITO - 9(3)(3), MUMBAI vs. FUTURE IDEA COMPANY LTD., MUMBAI

In the result, appeal filed by the revenue is dismissed

ITA 5227/MUM/2017[2013-14]Status: DisposedITAT Mumbai08 Jun 2018AY 2013-14

Bench: Shri R.C.Sharma, Am & Shri Ram Lal Negi, Jm Ito – 9(3)(3) Vs. M/S. Future Idea Company Ltd., Room No.471, 4Th Floor Knowledge House Aayakar Bhavan Off. Jogeshwari Vikhroli M.K.Road, Mumbai Link Road Maharashtra – 400020 Shyam Nagar Jogeshwari (E) Mumbai – 400 060 Pan/Gir No. Aaacf9519L Appellant) .. Respondent)

Section 143(3)Section 14A

…e case of Cheminvest Ltd vs CIT (supra) observed that where assessee had not shown any income under the head exempt income’, disallowance u/s 14A was not justified. The co-ordinate bench of ITAT, Mumbai Bench in the case of Garware Walfropes Ltd vs C1T (2014) 65 SOT 86 (Mum) observed that where assessee made certain investments with an object of acquiring controlling stake in a group concern and not for earning any income out of investment, the AO was not justified in invoking provisions of section 14A r.w.r. 8D in order to disallow a part of incidental dividend income earned on said investment. In yet another ca…

DCIT 1(1)(1), MUMBAI vs. AEGIS LOGISTICS P.LTD, MUMBAI

In the result, the appeal filed by the revenue is hereby ordered to be dismissed

ITA 1945/MUM/2016[2011-12]Status: DisposedITAT Mumbai23 May 2018AY 2011-12

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.1945/Mum/2016 (निर्धारण वर्ा / Assessment Year: 2011-12) Dcit-1(1)(1) बिधम/ M/S. Aegis Logistics Ltd. 579, Aayakar Bhawan, M.K. 40, Peninsula Chambers, Vs. Peninsula Corporate Park, Road, Mumbai-400020 G.K. Marg, Lower Parel, Mumbai-400013 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaca3302N (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri Ram Tiwari (Sr. Ar) Assessee By: Shri Ketan Ved सुनवाई की तारीख / Date Of Hearing: 18.05.2018 घोषणा की तारीख /Date Of Pronouncement: 23.05.2018 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue Has Filed The Present Appeal Against The Order Dated 22.12.2015 Passed By The Commissioner Of Income Tax (Appeals)-2, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The Ay. 2011-12. 2. The Revenue Has Raised The Following Grounds: - “1.Whether On Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Correct In Stating That The Interest Portion Of Rs.6,32,96,027/- Be Not Considered In Computing Disallowance U/S 14A R.W. Rule 8D2(Ii).

For Appellant: Shri Ketan VedFor Respondent: Shri Ram Tiwari (Sr. AR)
Section 10Section 143(1)Section 143(2)Section 14A

…ion is placed on the following decision: a. Decision of the Delhi high Court in the case of CIT v. Oriental Securities Engineers (P) Ltd 35 taxmann com 210) (Refer pages 338 to 339) b. Decision of the Mumbai ITAT in the case of Garware Wail Ropes Ltd v. ACIT (65 SOT 86) (Refer pages 340 to 344) c. Decision of the Mumbai ITAT in the case of JM Financial Ltd v ACIT ITA No 4521 /Mum/20 1 2) (Refer pages 345 to d Decision of the Delhi ITAT in the case of Interglobe Enterprises Ltd v DCIT (ITA No. 1 362 &1032/Del/2012 (Refer page 150 to 361) e Decision of the Chennai ITAT in the case of EIH Associated Hotels Ltd. v. D…

ACIT, CIRCLE-12(2), KOLKATA, KOLKATA vs. M/S SELVEL ADVERTISING PRIVATE LIMITED, KOLKATA

In the result, appeals filed by Revenue in ITA No

ITA 2197/KOL/2016[2013-14]Status: DisposedITAT Kolkata04 May 2018AY 2013-14

Bench: Shri Aby T. Varkey & Dr.A.L. Saini

Section 143(3)Section 14ASection 153Section 2(24)(x)Section 36(1)(va)

…आयकर अपील"य अधीकरण, "यायपीठ – “D” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “D” KOLKATA Before Shri Aby T. Varkey, Judicial Member and Dr.A.L. Saini, Accountant Member ITA No.2196-2197/Kol/2016 Assessment Years :2012-13 & 2013-14 ACIT, Circle-12(2), V/s. M/s Selvel Advertising Aayakar Bhawan, P-7, Pvt. Ltd., 6th Floor, Chowringhee 10/1G,DiamondHarbour Square, Kolkata-69 Road, Kolkta-700 027 [PAN No.AAECS 8398 C] अपीलाथ" /Appellant ""यथ"/Respondent .. C.O.No.97/Kol/2016 (a/o ITA No.2197/Kol/2016) Assessment Year: 2013-14 M/s Selvel Advertising V/s. ACIT, Circle-12(2), Pvt. Ltd., Aayakar Bhawa…

ACIT,CIR-12(2),KOLKATA, KOLKATA vs. M/S SELVEL ADVERTISING PRIVATE LIMITED, KOLKATA

In the result, appeals filed by Revenue in ITA No

ITA 2196/KOL/2016[2012-13]Status: DisposedITAT Kolkata04 May 2018AY 2012-13

Bench: Shri Aby T. Varkey & Dr.A.L. Saini

Section 143(3)Section 14ASection 153Section 2(24)(x)Section 36(1)(va)

…आयकर अपील"य अधीकरण, "यायपीठ – “D” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “D” KOLKATA Before Shri Aby T. Varkey, Judicial Member and Dr.A.L. Saini, Accountant Member ITA No.2196-2197/Kol/2016 Assessment Years :2012-13 & 2013-14 ACIT, Circle-12(2), V/s. M/s Selvel Advertising Aayakar Bhawan, P-7, Pvt. Ltd., 6th Floor, Chowringhee 10/1G,DiamondHarbour Square, Kolkata-69 Road, Kolkta-700 027 [PAN No.AAECS 8398 C] अपीलाथ" /Appellant ""यथ"/Respondent .. C.O.No.97/Kol/2016 (a/o ITA No.2197/Kol/2016) Assessment Year: 2013-14 M/s Selvel Advertising V/s. ACIT, Circle-12(2), Pvt. Ltd., Aayakar Bhawa…

ZEE MEDIA CORPORATION LIMITED,MUMBAI vs. ADDLL.CIT -RG.7(3), MUMBAI

In the result, both the appeals are partly allowed as indicated above

ITA 2695/MUM/2016[2011-12]Status: DisposedITAT Mumbai16 Apr 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Ramit Kochar, Hon'Ble

For Appellant: Shri Jay BhansaliFor Respondent: Shri Ram Tiwari
Section 133(6)Section 154

…d. (supra), 11 ITA.NO.2166 & 2695/MUM/2016 (A.Y.2011-12) M/s. Zee Media Corporation Ltd. however we find that the Coordinate Bench deleted the disallowance u/s. 14A based on the decision of the Coordinate Bench in the case of Garware Wall Ropes Ltd. v. ACIT [65 SOT 86] wherein it has been held that the investments made in subsidiaries is not for the purpose of earning dividend income but was only to hold controlling stakes and it was strategic investments. As far as the proposition that there should not be any disallowance u/s. 14A when the investment was made in subsidiaries as a strategic investment is no more…

ACIT 8(3)(2), MUMBAI vs. ZEE MEDIA CORPORATION LTD. (FORMERLY KNOWN AS ZEE NEWS LTD.), MUMBAI

In the result, both the appeals are partly allowed as indicated above

ITA 2166/MUM/2016[2011-12]Status: DisposedITAT Mumbai16 Apr 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Ramit Kochar, Hon'Ble

For Appellant: Shri Jay BhansaliFor Respondent: Shri Ram Tiwari
Section 133(6)Section 154

…d. (supra), 11 ITA.NO.2166 & 2695/MUM/2016 (A.Y.2011-12) M/s. Zee Media Corporation Ltd. however we find that the Coordinate Bench deleted the disallowance u/s. 14A based on the decision of the Coordinate Bench in the case of Garware Wall Ropes Ltd. v. ACIT [65 SOT 86] wherein it has been held that the investments made in subsidiaries is not for the purpose of earning dividend income but was only to hold controlling stakes and it was strategic investments. As far as the proposition that there should not be any disallowance u/s. 14A when the investment was made in subsidiaries as a strategic investment is no more…

DCIT 3(1), MUMBAI vs. EDELWEISS CAPITAL LTD, MUMBAI

In the result appeals of Revenue are dismissed

ITA 7797/MUM/2011[2007-08]Status: DisposedITAT Mumbai14 Mar 2018AY 2007-08

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm

Section 143(3)Section 14ASection 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL “E”, BENCH MUMBAI BEFORE SHRI R.C.SHARMA, AM & SHRI SANDEEP GOSAIN, JM ITA No.7654/Mum/2011 (Assessment Year :2007-08 & 2008-09) DCIT CIR 3(1) Vs. M/s. Edelweiss Capital Ltd., 4th R.No.607, Aayakar Bhavan Edelweiss House, Floor, Mumbai – 400 020 Off. CST Road, Kalina, Mumbai – 400 098 PAN/GIR No. AAACE1461E Appellant) .. Respondent) DCIT CIR 3(1) Vs. M/s. Edelweiss Capital Ltd., 14th R.No.607, Aayakar Bhavan Floor, Express Towers, Mumbai – 400 020 Nariman Point, Mumbai – 400 021 PAN/GIR No. AAACE1461E Appellant) .. Respondent) M/s. Edelweiss Capital Ltd., Vs. Addl CIT RG 3(1…

M/S. SIMPSON & CO. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 171/CHNY/2018[2013-14]Status: DisposedITAT Chennai28 Feb 2018AY 2013-14

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Raoआयकर अपील सं./Ita Nos.170 & 171/Chny/2018 "नधा"रण वष" /Assessment Years: 2013-14 & 2014-15

For Appellant: Shri ARV Sreenivasan, JCITFor Respondent: 19.02.2019
Section 14A

…cy there is no reason to believe that the assessee would have incurred any administrative expenses in holding these investments; EIH vs. DCIT (ITAT Chennai) (2009) 126 TTJ 0246 Interglobe Enterprises Ltd 2014-TIOL-729-ITAT-DEL/ Garware WaLl Ropes Ltd vs. ACIT 65 SOT 86 Mum. J.M.Financial Ltd v ACIT 2014-TIOL-202-ITAT-MUM ITA Nos.170 & 171/Chny/2018 (AYs: 2013-14 & 2014-15) :- 3 -: 2.6 The Commissioner of Income tax (Appeals) ought to have appreciated that the Investments in Mutual Funds are handled by the outsourced intermediary who doesn’t charge any fees, as they earn commission from the concerned mutual funds…

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