Godrej & Boyce Mfg. Co. Ltd. v. DCIT

328 ITR 81High Court2010#37 most cited

What is Godrej & Boyce Mfg. Co. Ltd. v. DCIT authority for?

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

1,164

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

Godrej & Boyce Mfg. Co. Ltd. · Section 14A disallowance · Rule 8D applicability · Rule 8D AY 2008-09 · reasonable disallowance · disallowance exceeding exempt income · exempt income expenses · Bombay High Court · 328 ITR 81 · disallowance of interest expenditure · book profits Section 115JB

Also reported as

234 DTR 1

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 271(1)(c)Section 234BSection 37(1)Section 132Section 143(2)

Issues it is cited on

section 14a(1)section 14a(2)dividend distribution taxdisallowance of interest expendituresection 36(1)(vii)disallowance under section 14abook profitsdisallowance u/s 14asection 14asection 115jsection 115jbtransfer pricing adjustment

Judgments citing Godrej & Boyce Mfg. Co. Ltd. v. DCIT

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2480/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR
Section 14ASection 40

…1 wherein it has been held that by the Apex Court that there must be a proximate relationship of expenditure with exempt income, for the purposes of making disallowance of same under section 14A of the Act. In the case of Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 328 ITR 81, the Bombay High Court, while deciding the issue of disallowance under section 14A of the Act, following the aforesaid Supreme Court decision in Walfort Shares & Stock Brokers (supra), observed that disallowance under section 14A can be effected only when a proximate cause for disallowance is established, stating the relationship of the expenditur…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2479/DEL/2011[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR
Section 14ASection 40

…1 wherein it has been held that by the Apex Court that there must be a proximate relationship of expenditure with exempt income, for the purposes of making disallowance of same under section 14A of the Act. In the case of Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 328 ITR 81, the Bombay High Court, while deciding the issue of disallowance under section 14A of the Act, following the aforesaid Supreme Court decision in Walfort Shares & Stock Brokers (supra), observed that disallowance under section 14A can be effected only when a proximate cause for disallowance is established, stating the relationship of the expenditur…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2478/DEL/2011[2005-06]Status: DisposedITAT Delhi15 Apr 2026AY 2005-06

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR
Section 14ASection 40

…1 wherein it has been held that by the Apex Court that there must be a proximate relationship of expenditure with exempt income, for the purposes of making disallowance of same under section 14A of the Act. In the case of Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 328 ITR 81, the Bombay High Court, while deciding the issue of disallowance under section 14A of the Act, following the aforesaid Supreme Court decision in Walfort Shares & Stock Brokers (supra), observed that disallowance under section 14A can be effected only when a proximate cause for disallowance is established, stating the relationship of the expenditur…

CHNHB HEALTH INSURANCE CO. LTD.,,KOLKATA vs. ACIT, CIRCLE 6(1), , KOLKATA

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

ITA 511/KOL/2025[2017-18]Status: DisposedITAT Kolkata08 Apr 2026AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 14ASection 250

…not forming part of the total income, the disallowable expenditure shall be computed in accordance with sub-Rule (2). The constitutional validity of both sub section 2 and 3 as well as Rule 8D has been upheld by the court in Godrej & Boyce Mfg Co. Ltd v DCIT 328 ITR 81 where it was held that Disallowance under section 14A has to be made in accordance with the principle laid down by the Hon'ble Bombay High Court in the present case. The Mumbai Tribunal in Daga Capital Management Pvt. Ltd. 26 SOT 603 held that all disallowances u/s 14A ought to be strictly computed as per Rule 8D. 4.1.3 It is seen from the assessm…

DENTSU AEGIS NETWORK INDIA PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(1), MUMBAI

ITA 6124/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ketan Ved &For Respondent: Shri Annavaran Kosuri
Section 115JSection 143(3)Section 14ASection 234Section 234BSection 234CSection 270A

…tained in Rule 8D of the IT Rules. In our view, the aforesaid approach adopted by the Assessing Officer cannot be countenanced being contrary to judgment of the Hon’ble Bombay High Court in the Godrej & Boyce Mfg. Co. Ltd. v. Deputy Commission of Income Tax : 328 ITR 81. The Hon’ble Bombay High Court had, while rejecting the challenge to the validity of Section 14A of the Act, held as under: "57. Now in dealing with the challenge it is necessary to advert to the position that Sub-section (2) of Section 14A prescribes a uniform method for determining the amount of expenditure incurred in 8 Assessment Year 2020-202…

BAJAJ CONSULTANTS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), MUMBAI

In the result the appeal of the assessee is dismissed

ITA 2676/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Ms. Srushti ChawdaFor Respondent: 17/12/2025
Section 14A

…on the following judgments: reliance is placed on the following judgments:- 4.5.1 The Hon'ble Bombay High Court in the case of Godrej & Boyce applied to Godrej & Boyce applied to 4.5.1 The Hon'ble Bombay High Court in the case of work Manufacturing Co. Ltd. [328 ITR 81] work Manufacturing Co. Ltd. [328 ITR 81] has held that Rule has held that Rule 8D has to out the disallowance u/s 14A with effect from 2008 disallowance u/s 14A with effect from 2008-09 onwards where the assessing 09 onwards where the assessing officer is not satisfied with the correctness of the claim of the assessee. In the officer is not satis…

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

ITA 2552/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

…tention of making investment from own funds before the Learned CIT(A). 10.7. We have considered the rival submission and have perused the material on record. 10.8. We note that in the case of Godrej & Boyce Mfg. Co. Ltd. v. Deputy Commission of Income Tax : 328 ITR 81, the Hon’ble Bombay High Court had, while rejecting the challenge to the validity of Section 14A of the Act, held as under: Assessment Year 2016-2017 "57. Now in dealing with the challenge it is necessary to advert to the position that Sub-section (2) of Section 14A prescribes a uniform method for determining the amount of expenditure incurred in…

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

ITA 2093/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

…tention of making investment from own funds before the Learned CIT(A). 10.7. We have considered the rival submission and have perused the material on record. 10.8. We note that in the case of Godrej & Boyce Mfg. Co. Ltd. v. Deputy Commission of Income Tax : 328 ITR 81, the Hon’ble Bombay High Court had, while rejecting the challenge to the validity of Section 14A of the Act, held as under: Assessment Year 2016-2017 "57. Now in dealing with the challenge it is necessary to advert to the position that Sub-section (2) of Section 14A prescribes a uniform method for determining the amount of expenditure incurred in…

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…of appeal are distinguishable on facts and law and does not help the cause of assessee. The assessee relied upon the decision of various courts of law listed as under: (i) Maxopp Investments Ltd. Vs CIT347ITR 272 (Del) (ii) Godrej & Boyce Mfg.Co.Ltd. vs DCIT 328 ITR 81 (Bom) (iii) Relaxo Footwears Ltd. Vs Addl.CIT (2012) 50 SOT 102 (iv) REI Agro Ltd. Kolkata vs D CIT ITA No.1331/Kol/2011 (v) DCIT vs Ashish Jhunjhunwala In all of the aforesaid judgements, the ratio was that the AO failed to record any satisfaction u/s 14A read with rule 8D whereas in the present case proper satisfaction was recorded by the AO u/s…

M/S COAL INDIA LTD.,KOLKATA vs. DCIT, CIR-5(1), , KOLKATA

ITA 1407/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 1Section 115JSection 250

…of appeal are distinguishable on facts and law and does not help the cause of assessee. The assessee relied upon the decision of various courts of law listed as under: (i) Maxopp Investments Ltd. Vs CIT347ITR 272 (Del) (ii) Godrej & Boyce Mfg.Co.Ltd. vs DCIT 328 ITR 81 (Bom) (iii) Relaxo Footwears Ltd. Vs Addl.CIT (2012) 50 SOT 102 (iv) REI Agro Ltd. Kolkata vs D CIT ITA No.1331/Kol/2011 (v) DCIT vs Ashish Jhunjhunwala In all of the aforesaid judgements, the ratio was that the AO failed to record any satisfaction u/s 14A read with rule 8D whereas in the present case proper satisfaction was recorded by the AO u/s…

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

ITA 623/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115JSection 250

…of appeal are distinguishable on facts and law and does not help the cause of assessee. The assessee relied upon the decision of various courts of law listed as under: (i) Maxopp Investments Ltd. Vs CIT347ITR 272 (Del) (ii) Godrej & Boyce Mfg.Co.Ltd. vs DCIT 328 ITR 81 (Bom) (iii) Relaxo Footwears Ltd. Vs Addl.CIT (2012) 50 SOT 102 (iv) REI Agro Ltd. Kolkata vs D CIT ITA No.1331/Kol/2011 (v) DCIT vs Ashish Jhunjhunwala In all of the aforesaid judgements, the ratio was that the AO failed to record any satisfaction u/s 14A read with rule 8D whereas in the present case proper satisfaction was recorded by the AO u/s…

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…of appeal are distinguishable on facts and law and does not help the cause of assessee. The assessee relied upon the decision of various courts of law listed as under: (i) Maxopp Investments Ltd. Vs CIT347ITR 272 (Del) (ii) Godrej & Boyce Mfg.Co.Ltd. vs DCIT 328 ITR 81 (Bom) (iii) Relaxo Footwears Ltd. Vs Addl.CIT (2012) 50 SOT 102 (iv) REI Agro Ltd. Kolkata vs D CIT ITA No.1331/Kol/2011 (v) DCIT vs Ashish Jhunjhunwala In all of the aforesaid judgements, the ratio was that the AO failed to record any satisfaction u/s 14A read with rule 8D whereas in the present case proper satisfaction was recorded by the AO u/s…

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…of appeal are distinguishable on facts and law and does not help the cause of assessee. The assessee relied upon the decision of various courts of law listed as under: (i) Maxopp Investments Ltd. Vs CIT347ITR 272 (Del) (ii) Godrej & Boyce Mfg.Co.Ltd. vs DCIT 328 ITR 81 (Bom) (iii) Relaxo Footwears Ltd. Vs Addl.CIT (2012) 50 SOT 102 (iv) REI Agro Ltd. Kolkata vs D CIT ITA No.1331/Kol/2011 (v) DCIT vs Ashish Jhunjhunwala In all of the aforesaid judgements, the ratio was that the AO failed to record any satisfaction u/s 14A read with rule 8D whereas in the present case proper satisfaction was recorded by the AO u/s…

DCIT 2(3)(1), MUMBAI vs. TATA INDUSTRIES LTD, MUMBAI

Accordingly, Ground No 2(a) & (b) of the revenue in ITA No. 4109/Mum/2012, therefore stands dismissed

ITA 5690/MUM/2015[2006-07]Status: DisposedITAT Mumbai19 Nov 2025AY 2006-07

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI ARUN KHODPIA (Accountant Member)

Section 115JSection 143(3)Section 14ASection 271(1)(c)Section 37Section 40

…-. The AO has discussed the issue of disallowance u/s. 14A from Para 3.1 to Para 3.22 Page 2 to 18 of the assessment order and has mad disallowance as per Rule 8D. The appellant submitted that the Bombay High Court in case of M/s. Godrej Boyce Ltd. v/s. DCIT (328 ITR 81) has held that Rule 8D is applicable for A.Y. 2008-09 onwards. The appellant submitted that it has itself made disallowance of Rs.29.92 Crores. 1.1 I have gone through the order of the AO and submission of the appellant. 1.1.1 The Bombay High Court in case of M/s. Godrej & Boyce Ltd. v/s. DCIT (328 ITR 81) has held that Rule 8D is applicable for A…

ADDL CIT 2(3), MUMBAI vs. TATA INDUSTRIES LTD, MUMBAI

Accordingly,\nGround No 2(a) & (b) of the revenue in ITA No. 4109/Mum/2012, therefore\nstands dismissed

ITA 4109/MUM/2012[2006-07]Status: DisposedITAT Mumbai19 Nov 2025AY 2006-07
Section 115JSection 143(3)Section 14ASection 40

…The AO has discussed the\nissue of disallowance u/s.14A from Para 3.1 to Para 3.22 Page 2 to 18 of the assessment order\nand has mad disallowance as per Rule 8D. The appellant submitted that the Bombay High Court\nin case of M/s. Godrej Boyce Ltd. v/s. DCIT (328 ITR 81) has held that Rule 8D is applicable for\nA.Y. 2008-09 onwards. The appellant submitted that it has itself made disallowance of Rs.29.92\nCrores.\n\n1.1 I have gone through the order of the AO and submission of the appellant.\n\n1.1.1 The Bombay High Court in case of M/s. Godrej & Boyce Ltd. v/s. DCIT (328 ITR 81) has held\nthat Rule 8D is applica…

INDRAPRASTHA GAS LIMITED,DELHI vs. JCIT OSD RANGE-10, DELHI

In the result, the appeal of the assessee is allowed as above

ITA 2422/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 14ASection 32(1)(iia)

…edit Bank Ltd.; [2013] 40 taxman.com 532, (iv) Wella India Hair Cosmetics Pvt Ltd.; [2014] 51 taxman.com 203, (v) Hero Cycle; 323 ITR 518, (vi) Inductis India Pvt. Ltd. 157 taxmann.com 87, (vii) Eichear; 101 TTJ (Del.) 369, (vii) Godrej & Boyce Mfg. Co. Ltd.; 328 ITR 81 (Mum), (ix) Taikisha; 370 ITR 338 (Del.), (x) Priya Exhibitors (P) Ltd.; [2012] 54 SOT 356, (xi) Pukhraj Chunnilal Bafna; [2014] 47 taxman.com 288 and (xii) Magarpatta Township Development and Construction Company Ltd. [2014]. Besides these case laws, the Ld. AR also placed reliance on the decision of the coordinate bench in the cases of Punjab Na…

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

ITA 3173/MUM/2023[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19
Section 115JSection 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)

…\n(Delhi) and also the judgment of the Hon'ble Supreme Court in the case of\nGodrej & Boyce Mfg. Co. Ltd., [2017] 81 taxmann.com 111 (SC), which has\napproved the judgment of the Hon'ble Bombay High Court reported in the\ncase of Godrej & Boyce Mfg. Co. Ltd., 328 ITR 81 (Bom) on the aspect of\nrecording of satisfaction contemplated in Sec. 14A(2) of the Act. The\nAssessing Officer ought to have recorded his satisfaction in an objective\nmanner as to why the expenditure determined by the assessee as being\nincurred in relation to the exempt income is incorrect, having regard to the\naccounts of the assessee. In th…

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI , MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

ITA 3160/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…272 (Delhi) and also the judgment of the Hon'ble Supreme Court in the case of Godrej & Boyce Mfg. Co. Ltd., [2017] 81 taxmann.com 111 (SC), which has approved the judgment of the Hon'ble Bombay High Court reported in the case of Godrej & Boyce Mfg. Co. Ltd., 328 ITR 81 (Bom) on the aspect of recording of satisfaction contemplated in Sec. 14A(2) of the Act. The Assessing Officer ought to have recorded his satisfaction in an objective manner as to why the expenditure determined by the assessee as being incurred in relation to the exempt income is incorrect, having regard to the accounts of the assessee. In the abs…

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

ITA 2971/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18
Section 115JSection 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…\n(Delhi) and also the judgment of the Hon'ble Supreme Court in the case of\nGodrej & Boyce Mfg. Co. Ltd., [2017] 81 taxmann.com 111 (SC), which has\napproved the judgment of the Hon'ble Bombay High Court reported in the\ncase of Godrej & Boyce Mfg. Co. Ltd., 328 ITR 81 (Bom) on the aspect of\nrecording of satisfaction contemplated in Sec. 14A(2) of the Act. The\nAssessing Officer ought to have recorded his satisfaction in an objective\nmanner as to why the expenditure determined by the assessee as being\nincurred in relation to the exempt income is incorrect, having regard to the\naccounts of the assessee. In th…

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

ITA 2970/MUM/2023[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…272 (Delhi) and also the judgment of the Hon'ble Supreme Court in the case of Godrej & Boyce Mfg. Co. Ltd., [2017] 81 taxmann.com 111 (SC), which has approved the judgment of the Hon'ble Bombay High Court reported in the case of Godrej & Boyce Mfg. Co. Ltd., 328 ITR 81 (Bom) on the aspect of recording of satisfaction contemplated in Sec. 14A(2) of the Act. The Assessing Officer ought to have recorded his satisfaction in an objective manner as to why the expenditure determined by the assessee as being incurred in relation to the exempt income is incorrect, having regard to the accounts of the assessee. In the abs…

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