Godrej & Boyce Manufacturing Company Ltd. v. DCIT

394 ITR 449Supreme Court of India2017#81 most cited

What is Godrej & Boyce Manufacturing Company Ltd. v. DCIT authority for?

Expenditure can only be disallowed under Section 14A if the income is exempt and not part of the total income. The Assessing Officer must first record dissatisfaction with the assessee's accounts or computation before proceeding to make a disallowance under Section 14A or applying Rule 8D.

683

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2016 to 2026.

Also referred to as

Godrej & Boyce Manufacturing Company Ltd. v. DCIT · Section 14A disallowance · exempt income expenditure · dividend income disallowance · Assessing Officer satisfaction · Rule 8D application · condition precedent for disallowance · income not includible in total income · AO recording dissatisfaction · 394 ITR 449

Also reported as

81 Taxmann.com 11181 Taxmann 111

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 250Section 8DSection 142(1)Section 143(2)Section 154
Read the full judgment

Issues it is cited on

section 14a(1)section 14a(2)section 36(1)(viii)dividend distribution taxddtdomestic companyinfrastructure facilitysection 10(34)disallowance under section 14asection 36(1)(vii)put to usedisallowance u/s 14a

Judgments citing Godrej & Boyce Manufacturing Company Ltd. v. DCIT

Tcg Lifesciences Limited., Kolkata vs. ACIT, Circle-11(2), Kolkata

Appeal is allowed for statistical purposes

ITA 1553/KOL/2019[2008-09]Status: DisposedITAT Kolkata27 Aug 2021AY 2008-09

Bench: Shri P.M. Jagtap, V.P (Kz) & Smt. Madhumita Roy, Jm ]

Section 143(3)

…1 I.T.A. No.1553&1554/Kol/2019 Assessment Years: 2008-09 & 2009-10 IN THE INCOME TAX APPELLATE TRIBUNAL, “B” BENCH, KOLKATA [ Before Shri P.M. Jagtap, V.P (KZ) and Smt. Madhumita Roy, JM ] I.T.A. No.1553&1554/Kol/2019 Assessment Years: 2008-09 & 2009-10 TCG Lifesciences Pvt. Ltd. Vs. ACIT, Circle-11(2), Kolkata PAN: AABCC0401D Appellant Respondent Date of Hearing (Virtual) 24/08/2021 Date of Pronouncement 27/08/2021 For the Appellant Shri A. K. Tibrewal, AR For the Respondent Smt. Ranu Biswas, Addl. CIT, DR ORDER Per Smt. Madhumita Roy, JM Both the appeals filed by the assessee are directed against the sepa…

Shardul Securities Ltd, Mumbai vs. Dy CIT Range 3 (3)(1), Mumbai

The appeal stand partly allowed

ITA 354/MUM/2020[2015-16]Status: DisposedITAT Mumbai02 Aug 2021AY 2015-16

Bench: Hon’Ble Shri Amarjit Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील िं./ I.T.A. No.354 & 355/Mum/2020 (धििाारण वर्ा / Assessment Year: 2015-16 & 2016-17) M/S Shardul Securities Ltd. Dcit Range- 3(3)(1) बिाम/ 6Th Floor, R. No. 609 G-12, Tulsiani Chambers Free Press Road 212 Aayakar Bhavan, M. K. Road, Vs. Nariman Point, Mumbai-400 021 Mumbai-400 020. स्थायीलेखा िं./ जीआइआर िं./ Pan/Gir No. Aaacs-7141-R (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Assessee By : Shri Anuj Kisnadwala– Ld. Ar Revenue By : Shri Vijay Kumar Menon– Ld. Dr ुनवाई की तारीख/ : 28/07/2021 Date Of Hearing घोषणा की तारीख / : 02/08/2021 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Only Grievance Of The Assessee In Aforesaid Appeals For Assessment Year (Ay) 2015-16 & 2016-17 Is Disallowance U/S 14A. The Facts Are Pari-Materia The Same In Both The Years & Therefore, The Appeals Were Heard Together & Are Now Being Disposed-Off By Way Of This Common Order For The Sake Of Convenience & Brevity. 2. The Ld Ar Submitted That Ld. Ao Did Not Recorded Objective Satisfaction Before Applying Rule 8D & Therefore, The Disallowance

For Appellant: Shri Anuj Kisnadwala– Ld. ARFor Respondent: Shri Vijay Kumar Menon– Ld. DR
Section 115JSection 14A

…nd Ld.AO straightway proceeded to compute disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 5. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A of the Act read with Rule 8D of the Rules merely prescribe a formula for determination of expenditure incurred in relation to income which does not form part of the total income under the Act in a situation where the Assessing Officer is not satisfied with the claim of the assessee. Whether such…

Puja Trades & Investments Pvt Ltd., Mumbai vs. Dy CIT 3 (2)92), Mumbai

ITA 7442/MUM/2019[2013-14]Status: DisposedITAT Mumbai26 Jul 2021AY 2013-14

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () M/S Puja Traders & Investments Deputy Commissioner Of Private Limited, 16Th Floor, Vs. Income Tax -3(2)(2) Atlanta, 209, Jamnalal Bajaj Aayakar Bhavan, M.K. Road, Marg, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 Pan No. Aabcp1659A (Assessee) (Revenue) Assessee By : Shri Sunil Nahata, A.R Revenue By : Ms. Shreekala Pardeshi, D.R Date Of Hearing : 22/07/2021 Date Of Pronouncement : 26/07/2021

For Appellant: Shri Sunil Nahata, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R
Section 143(2)Section 143(3)Section 14A

…herefore, the same could not be sustained and was liable to be vacated. In support of his aforesaid contention the ld. A.R had relied on the judgments of the Hon‟ble Supreme Court in the case of Godrej & Boyce Manufacturing Company Ltd. Vs. DCIT & Anr. (2017) 394 ITR 449 (SC) and Maxopp Investment Ltd. Vs. CIT (2018) 402 ITR 640 (SC). Also, support was drawn by the ld. A.R from a host of judicial pronouncements to which our attention was drawn. Alternatively, it was submitted by the ld. A.R that as the assessee had sufficient own funds and interest free funds amounting to Rs. 10.93 crores, viz. (i). Share capital…

Sainath Trading Company Private Limited, Mumbai vs. ACIT - 8(1)(2), Mumbai

ITA 3795/MUM/2019[2015-16]Status: DisposedITAT Mumbai26 Jul 2021AY 2015-16

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () Sainath Trading Company Pvt. Acit -8(1)(2) Ltd. , 509-510, Navratan Vs. Mumbai Premises Co-Op Soc. Ltd. 69 Pd Mello Road, Carnac Bunder, Mumbai – 400 009

For Appellant: Shri Dr. K. Shivaram, Senior AdvocateFor Respondent: Shri T.S. Khalsa, D.R
Section 143(1)Section 143(2)Section 143(3)Section 14A

…ITA No.3795/Mum/2019 A.Y. 2015-16 1 Sainath Trading Company Pvt. Ltd. Vs. ACIT-8(1)(2) IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI BEFORE SHRI RAJESH KUMAR (ACCOUNTANT MEMBER) AND SHRI RAVISH SOOD (JUDICIAL MEMBER) Sainath Trading Company Pvt. ACIT -8(1)(2) Ltd. , 509-510, Navratan Vs. Mumbai Premises Co-op Soc. Ltd. 69 PD Mello Road, Carnac Bunder, Mumbai – 400 009 PAN No. AABCS9243B (Assessee) (Revenue) Assessee by : Shri Dr. K. Shivaram, Senior Advocate Revenue by : Shri T.S. Khalsa, D.R Date of Hearing : 15/07/2021 Date of pronouncement : 26/07/2021 ORDER PER RAVISH SOOD, J.M: The pr…

Bio Med Pvt. Ltd., Ghaziabad vs. DCIT, Circle- 1, Ghaziabad

In the result, the appeals of the assessee in ITA Nos

ITA 2771/DEL/2018[2012-13]Status: DisposedITAT Delhi26 Jul 2021AY 2012-13

Bench: Shri N.K. Billaiya & Shri K.N. Chary

For Appellant: Shri Akhilesh Kumar, AdvFor Respondent: Shri Jagdish Singh Dahia, Sr. DR
Section 14A

…is no acceptable and that making, continuing, exiting from investment etc. are coordinated management decision and so expenditure is embedded in indirect expenses( from para 36) and so s.14A invoked. Hon'ble court after relying on Godrej & Boyce Mfg. Co. Ltd. 394 ITR 449(SC) held that AO failed to record proper satisfaction. In the case of Taikisha Engineering, hon'ble court has relied on hon'ble Bombay HC decision in above case of Godrej reported in 328 ITR 81 for the proposition that that satisfaction has to be recorded with respect to accounts in terms of ss. (2)/(3) of s. 14A and the provisions does not ipso…

Bio Med Pvt. Ltd., Ghaziabad vs. Addl. CIT, Range- 2, Ghaziabad

In the result, the appeals of the assessee in ITA Nos

ITA 2770/DEL/2018[2011-12]Status: DisposedITAT Delhi26 Jul 2021AY 2011-12

Bench: Shri N.K. Billaiya & Shri K.N. Chary

For Appellant: Shri Akhilesh Kumar, AdvFor Respondent: Shri Jagdish Singh Dahia, Sr. DR
Section 14A

…is no acceptable and that making, continuing, exiting from investment etc. are coordinated management decision and so expenditure is embedded in indirect expenses( from para 36) and so s.14A invoked. Hon'ble court after relying on Godrej & Boyce Mfg. Co. Ltd. 394 ITR 449(SC) held that AO failed to record proper satisfaction. In the case of Taikisha Engineering, hon'ble court has relied on hon'ble Bombay HC decision in above case of Godrej reported in 328 ITR 81 for the proposition that that satisfaction has to be recorded with respect to accounts in terms of ss. (2)/(3) of s. 14A and the provisions does not ipso…

Gebr Pfeiffer India Pvt. Ltd., New Delhi vs. Addl.CIT, Special Range-4, New Delhi

The appeal of the assessee stands allowed

ITA 6902/DEL/2017[2014-15]Status: DisposedITAT Delhi07 Jul 2021AY 2014-15
Section 143(3)Section 14A

…istrative expenses to earn the interest free dividend income, no disallowance can be made u/s 14A read with Rule 8D. Reliance in this regard may be placed on the decision of Hon’ble Supreme Court in case of Godrej & Boyce Manufacturing Company Ltd. vs. DCIT – 394 ITR 449 (SC) and the Hon’ble Supreme Court observed as under: GEBR Pfeiffer (India) Pvt. Ltd. Vs. ACIT “37. We do not see how in the aforesaid fact situation a different view could have been taken for the Assessment Year 2002-2003. Sub-sections (2) and (3) of Section 14A of the Act read with Rule 8D of the Rules merely prescribe a formula for determina…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/214/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…ration and therefore, will strictly be adhered to by the Assessee. In para 3.6 of the assessment order, after discussing Section 14A(1) read with Rule 8D and referring to the decision of the Bombay High Court in Godrej and Boyce Mfg. Co. Ltd v. DCIT [2017] 394 ITR 449 (SC) , the AO simply stated that “in view of the facts and circumstances and legal position on the issue as discussed above, I am satisfied that the Assessee had incurred expenses to manage its investments which may yield exempt income, and Assessee grossly failed to calculate such expenses in a reasonable manner to ascertain to ascertain the…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/215/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…ration and therefore, will strictly be adhered to by the Assessee. In para 3.6 of the assessment order, after discussing Section 14A(1) read with Rule 8D and referring to the decision of the Bombay High Court in Godrej and Boyce Mfg. Co. Ltd v. DCIT [2017] 394 ITR 449 (SC) , the AO simply stated that “in view of the facts and circumstances and legal position on the issue as discussed above, I am satisfied that the Assessee had incurred expenses to manage its investments which may yield exempt income, and Assessee grossly failed to calculate such expenses in a reasonable manner to ascertain to ascertain the…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/213/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…ration and therefore, will strictly be adhered to by the Assessee. In para 3.6 of the assessment order, after discussing Section 14A(1) read with Rule 8D and referring to the decision of the Bombay High Court in Godrej and Boyce Mfg. Co. Ltd v. DCIT [2017] 394 ITR 449 (SC) , the AO simply stated that “in view of the facts and circumstances and legal position on the issue as discussed above, I am satisfied that the Assessee had incurred expenses to manage its investments which may yield exempt income, and Assessee grossly failed to calculate such expenses in a reasonable manner to ascertain to ascertain the…

Assistant Commissioner of Income Tax 2(3)(1), Mumbai vs. Tata Capital Limited, Mumbai

In the result, appeals of the assessee are partly allowed as indicated above and revenue’s appeals are dismissed

ITA 60/MUM/2018[2013-14]Status: DisposedITAT Mumbai18 Jun 2021AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

For Appellant: Shri Niraj ShethFor Respondent: Shri Manjunatha Swamy
Section 143(3)Section 14A

…e made by the assessee is wrong. Ld. Counsel for the assessee further in support to his submissions also placed reliance on the following decisions: - i. Maxopp Investment Ltd. v. CIT [402 ITR 640 (SC)] ii. Godrej and Boyce Manufacturing company Ltd. v. DCIT [394 ITR 449 (SC)] iii. PCIT v. Reliance Capital Asset Management Ltd., [400 ITR 217 (Bom)] iv. H.T. Media Ltd., v. PCIT [399 ITR 576 (Del.)] 8. With regard to the additional ground No.2 of grounds of appeal i.e., in respect of deduction of education cess on income tax and secondary and higher education cess on Income-tax, Learned Counsel for the assessee pl…

Assistant Commissioner of Income Tax 2(3)(1), Mumbai vs. Tata Capital Limited, Mumbai

In the result, appeals of the assessee are partly allowed as indicated above and revenue’s appeals are dismissed

ITA 59/MUM/2018[2012-13]Status: DisposedITAT Mumbai18 Jun 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

For Appellant: Shri Niraj ShethFor Respondent: Shri Manjunatha Swamy
Section 143(3)Section 14A

…e made by the assessee is wrong. Ld. Counsel for the assessee further in support to his submissions also placed reliance on the following decisions: - i. Maxopp Investment Ltd. v. CIT [402 ITR 640 (SC)] ii. Godrej and Boyce Manufacturing company Ltd. v. DCIT [394 ITR 449 (SC)] iii. PCIT v. Reliance Capital Asset Management Ltd., [400 ITR 217 (Bom)] iv. H.T. Media Ltd., v. PCIT [399 ITR 576 (Del.)] 8. With regard to the additional ground No.2 of grounds of appeal i.e., in respect of deduction of education cess on income tax and secondary and higher education cess on Income-tax, Learned Counsel for the assessee pl…

Tata Capital Ltd, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, appeals of the assessee are partly allowed as indicated above and revenue’s appeals are dismissed

ITA 7059/MUM/2017[2013-14]Status: DisposedITAT Mumbai18 Jun 2021AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

For Appellant: Shri Niraj ShethFor Respondent: Shri Manjunatha Swamy
Section 143(3)Section 14A

…e made by the assessee is wrong. Ld. Counsel for the assessee further in support to his submissions also placed reliance on the following decisions: - i. Maxopp Investment Ltd. v. CIT [402 ITR 640 (SC)] ii. Godrej and Boyce Manufacturing company Ltd. v. DCIT [394 ITR 449 (SC)] iii. PCIT v. Reliance Capital Asset Management Ltd., [400 ITR 217 (Bom)] iv. H.T. Media Ltd., v. PCIT [399 ITR 576 (Del.)] 8. With regard to the additional ground No.2 of grounds of appeal i.e., in respect of deduction of education cess on income tax and secondary and higher education cess on Income-tax, Learned Counsel for the assessee pl…

Tata Capital Ltd, Mumbai vs. DCIT 2(3)(1), Mumbai

In the result, appeals of the assessee are partly allowed as indicated above and revenue’s appeals are dismissed

ITA 7058/MUM/2017[2012-13]Status: DisposedITAT Mumbai18 Jun 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

For Appellant: Shri Niraj ShethFor Respondent: Shri Manjunatha Swamy
Section 143(3)Section 14A

…e made by the assessee is wrong. Ld. Counsel for the assessee further in support to his submissions also placed reliance on the following decisions: - i. Maxopp Investment Ltd. v. CIT [402 ITR 640 (SC)] ii. Godrej and Boyce Manufacturing company Ltd. v. DCIT [394 ITR 449 (SC)] iii. PCIT v. Reliance Capital Asset Management Ltd., [400 ITR 217 (Bom)] iv. H.T. Media Ltd., v. PCIT [399 ITR 576 (Del.)] 8. With regard to the additional ground No.2 of grounds of appeal i.e., in respect of deduction of education cess on income tax and secondary and higher education cess on Income-tax, Learned Counsel for the assessee pl…

DCIT, New Delhi vs. M/S. Paramount Communication Pvt. Ltd., New Delhi

In the result, ITA No.767/Del/2014 is partly allowed,

ITA 2288/DEL/2017[2010-11]Status: DisposedITAT Delhi15 Jun 2021AY 2010-11

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2009-10]

Section 43A

…ction that having regard to the accounts of an assessee, suo-moto disallowance u/s 14A was not correct. In the present case, satisfaction was not recorded. Therefore, no disallowance was called for. Reliance is placed on Godrej & Boyce Mfg. v. Dy. CIT (2017) 394 ITR 449 (SC). He submitted that though there is no estoppel against the statue and it can be argued that no disallowance u/s 14A was called for, however, the assessee to avoid litigation had agreed to disallowance of Rs.27,99,459/-. Therefore, to this extent the assessee has no grievance. He submitted that out of investment of Rs.27,39,71,001/- investme…

Paramount Communications Ltd., New Delhi vs. DCIT, New Delhi

In the result, ITA No.767/Del/2014 is partly allowed,

ITA 1378/DEL/2017[2010-11]Status: DisposedITAT Delhi15 Jun 2021AY 2010-11

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2009-10]

Section 43A

…ction that having regard to the accounts of an assessee, suo-moto disallowance u/s 14A was not correct. In the present case, satisfaction was not recorded. Therefore, no disallowance was called for. Reliance is placed on Godrej & Boyce Mfg. v. Dy. CIT (2017) 394 ITR 449 (SC). He submitted that though there is no estoppel against the statue and it can be argued that no disallowance u/s 14A was called for, however, the assessee to avoid litigation had agreed to disallowance of Rs.27,99,459/-. Therefore, to this extent the assessee has no grievance. He submitted that out of investment of Rs.27,39,71,001/- investme…

M/S. Paramount Communictions Ltd., New Delhi vs. DCIT, New Delhi

In the result, ITA No.767/Del/2014 is partly allowed,

ITA 767/DEL/2014[2009-10]Status: DisposedITAT Delhi15 Jun 2021AY 2009-10

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2009-10]

Section 43A

…ction that having regard to the accounts of an assessee, suo-moto disallowance u/s 14A was not correct. In the present case, satisfaction was not recorded. Therefore, no disallowance was called for. Reliance is placed on Godrej & Boyce Mfg. v. Dy. CIT (2017) 394 ITR 449 (SC). He submitted that though there is no estoppel against the statue and it can be argued that no disallowance u/s 14A was called for, however, the assessee to avoid litigation had agreed to disallowance of Rs.27,99,459/-. Therefore, to this extent the assessee has no grievance. He submitted that out of investment of Rs.27,39,71,001/- investme…

M/S Soma Block Prints (P) Ltd., Jaipur vs. Income Tax Officer, Ward-3-1, Jaipur

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

ITA 528/JPR/2019[2013-14]Status: DisposedITAT Jaipur15 Jun 2021AY 2013-14
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a
Section 142ASection 142A(2)Section 14ASection 155

…s directly credited to the bank account of the assessee. Hence, the disallowance of Rs.13,775/- confirmed by Ld. CIT(A) is unjustified. In support, reliance was placed on the following cases:- • Godrej & Boyce Manufacturing Company Ltd. Vs. DCIT &Anr. (2017) 394 ITR 449 (SC) • Vijay Solvex Ltd. Vs. ACIT (DBITA No.325/2017 & 326/2017 order dt.09.01.2018) (Raj.) (HC)- • CIT Vs. Taikisha Engineering India Ltd. (2015) 370 ITR 338 (Del.) (HC) In view of above, disallowance of Rs.13,775/- confirmed by Ld. CIT(A) be directed to be deleted. 20. Per contra, the ld. DR has relied on the findings of the lower authorities…

Daawat Foods Ltd., New Delhi vs. ACIT, New Delhi

Appeal are dismissed

ITA 4159/DEL/2013[2009-10]Status: DisposedITAT Delhi07 Jun 2021AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing)

Section 132Section 142Section 143(3)Section 14ASection 40Section 40A(3)Section 69Section 80I

…borrowed funds and therefore, there was no warrant to make any disallowance out of interest expenditure. Thus, the Assessing Officer erroneously applied Rule 8D. The Ld. AR relied upon the following decisions: a) Godrej & Boyce Manufacturing Co. Ltd. vs. DCIT 394 ITR 449 (SC) b) Maxopp Investment Ltd. vs. CIT 91 taxmann.com 154 (SC) c) L T Foods (ITA No. 4164/Del/2013 order dated 30.09.2020 which is a group concern of the assessee) The Ld. AR further submitted that under Rule 8D (2)(iii), what is disallowable is an amount equal to ½ percentage of the average value of investment, the income from which does not or…

DCIT, New Delhi vs. M/S Daawat Foods Ltd., New Delhi

Appeal are dismissed

ITA 4042/DEL/2013[2009-10]Status: DisposedITAT Delhi07 Jun 2021AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing)

Section 132Section 142Section 143(3)Section 14ASection 40Section 40A(3)Section 69Section 80I

…borrowed funds and therefore, there was no warrant to make any disallowance out of interest expenditure. Thus, the Assessing Officer erroneously applied Rule 8D. The Ld. AR relied upon the following decisions: a) Godrej & Boyce Manufacturing Co. Ltd. vs. DCIT 394 ITR 449 (SC) b) Maxopp Investment Ltd. vs. CIT 91 taxmann.com 154 (SC) c) L T Foods (ITA No. 4164/Del/2013 order dated 30.09.2020 which is a group concern of the assessee) The Ld. AR further submitted that under Rule 8D (2)(iii), what is disallowable is an amount equal to ½ percentage of the average value of investment, the income from which does not or…