H T Media Ltd. v. PCIT

399 ITR 576High Court2017#773 most cited

What is H T Media Ltd. v. PCIT authority for?

The Assessing Officer must first record satisfaction that the assessee’s claim regarding expenditure incurred for earning exempt income is incorrect or unreasonable before applying the provisions of Rule 8D to determine such disallowance under Section 14A(2) of the Income Tax Act.

132

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

H T Media Ltd. v. PCIT · 399 ITR 576 · Section 14A · Section 14A(2) · Rule 8D · AO satisfaction recording · exempt income expenditure disallowance · application of Rule 8D

Sections most often in play

Section 143(3)Section 14ASection 1961Section 153ASection 142(2A)Section 147Section 2(22)(e)Section 40(a)(ia)

Issues it is cited on

recognised provident fundsection 40(3)depreciation on non-compete feesection 24(1)section 50brule 8d disallowancesection 41(2)section 43b(f)approved gratuity fundsection 40a(9)section 211short deduction of tds

Judgments citing H T Media Ltd. v. PCIT

DCIT CENTRAL CIRCLE-01, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORPORATION LTD. , KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5793/DEL/2019[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

ACIT, CENTRAL CIRCLE- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORPORATION, KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 2369/DEL/2018[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 1893/DEL/2018[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

ACIT, CC- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5534/DEL/2017[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

ACIT, CC- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5505/DEL/2017[2013-2014]Status: DisposedITAT Delhi23 Dec 2025AY 2013-2014

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

ACIT, CC- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5504/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

ACIT, CENTRAL CIRCLE-1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD, LUCKNOW

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4855/DEL/2017[2010-11]Status: DisposedITAT Delhi23 Dec 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4731/DEL/2017[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4730/DEL/2017[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4729/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4728/DEL/2017[2010-11]Status: DisposedITAT Delhi23 Dec 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA COMMERCIAL CORPN. LTD.,KOLKATA vs. ACIT, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 2795/DEL/2017[2011-12]Status: DisposedITAT Delhi23 Dec 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

DCIT, NEW DELHI vs. M/S. SAHARA INDIA COMMERCIAL CORPORATION LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 2620/DEL/2013[2009-10]Status: DisposedITAT Delhi23 Dec 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SAHARA INDIA,KOLKATA vs. DCIT, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 1977/DEL/2013[2009-10]Status: DisposedITAT Delhi23 Dec 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

SICPA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 22(2), DELHI

In the result, the appeal of the assessee is allowed

ITA 330/DEL/2025[2020-21]Status: DisposedITAT Delhi17 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[ Sicpa India Private Limited, Asst. Cit, 308-312, Mercantile House, Circle -22(2), 15 K.G. Marg, Vs. Delhi. Delhi-110001. Pan-Aadcs6121L (Appellant) (Respondent) Assessee By Shri Akash Singhal, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 17/10/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [Cit(A), In Short] Dated 28.11.2024 In Appeal No. Nfac/2019-20/10183865 Arising Out Of Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.09.2022 For Assessment Year 2020-21. 2. Brief Facts Of The Case Are That Assessee Is A Company Engaged In The Business Of Manufacturing & Distribution Of Security Inks. The Return Of Income For The Year Under Appeal Was E-Filed On 15.02.2021 Declaring Total Income At Rs.6,74,74,000/-. The Case Of The Assessee Was Taken Up For Scrutiny & The Order Was Passed U/S 143(3) On 30.09.2022 Wherein Disallowance Of Rs.23,09,391/- Was Made On Account Of Dividend Distributions Tax & Educational Cess Claimed By The Assessee As Sicpa India Private Limited Vs. Acit Expenses & Further Disallowance U/S 14A Of Rs.25,56,078/- Was Made & The Total Income Of The Assessee Was Assessed At Rs.7,71,05,940/-.

Section 143(3)Section 14ASection 234CSection 270A

…also argued by the Id. AR for the assessee that no proper satisfaction has been recorded by the AO before invoking the provisions contained under Rule 8D and relied upon the decisions of Eicher Motors Ltd. vs. CIT 398 ITR 51 (Del.) and HT Media Ltd. vs. PCIT 399 ITR 576 (Del.). However, on the other hand, Id. DR for the Revenue relied upon the orders passed by the AO as well as ld. CIT (A). 22. First of all, when we examine the satisfaction recorded by the AO for all the three assessment years i.e. 2009-10, 2010-11 & 2011-12 in order to invoke the provisions contained under Rule 8D, no satisfaction has been reco…

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…sessee had surplus funds and there was no finding by the assessing officer of any direct nexus of borrowed funds with investments:  CIT v. Reliance Industries Ltd.: 410 ITR 466 (SC)  Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 394 ITR 449 (SC)  HT Media v. PCIT: 399 ITR 576 (Del.)  CIT vs. Taikisha Engineering India Ltd: 370 ITR 338 (Del) 9. He submitted that no disallowance out of administrative expenditure can be made and relied on the following decisions :-  SIL Investment Ltd. v. ACIT: 148 TTJ 213 (Del. Trib.)  DCIT v. Jammu and Kashmir Bank Ltd: 152 TTJ 522 (Asr. Trib.) 10. With regard to investments not r…

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…sessee had surplus funds and there was no finding by the assessing officer of any direct nexus of borrowed funds with investments:  CIT v. Reliance Industries Ltd.: 410 ITR 466 (SC)  Godrej & Boyce Mfg. Co. Ltd. v. DCIT: 394 ITR 449 (SC)  HT Media v. PCIT: 399 ITR 576 (Del.)  CIT vs. Taikisha Engineering India Ltd: 370 ITR 338 (Del) 9. He submitted that no disallowance out of administrative expenditure can be made and relied on the following decisions :-  SIL Investment Ltd. v. ACIT: 148 TTJ 213 (Del. Trib.)  DCIT v. Jammu and Kashmir Bank Ltd: 152 TTJ 522 (Asr. Trib.) 10. With regard to investments not r…

ADDI. CIT SPL. RANGE-9, NEW DELHI vs. THE HINDUSTAN TIMES LTD., NEW DELHI

In the result, appeal of Revenue in ITA No

ITA 7597/DEL/2019[2015-16]Status: DisposedITAT Delhi08 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri V.K. Dubey, Sr. DR
Section 14Section 14ASection 14A(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 7597/DEL/2019 [A.Y 2015-16] The Addl. C.I.T Vs. The Hindustan Times Ltd Special Range - 9 9th Floor, Hindustan Times House New Delhi 18-20, Kasturba Gandhi Marg New Delhi PAN: AAACT 4962 F (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Adv Shri Shourya Jain, CA Shri Deepesh Jain, Adv Department By : Shri V.K. Dubey, Sr. DR Date of Hearing : 07.05.2025 Date of Pronouncement : 07.05.2025 ORDER PER NAVEEN CHANDRA, AM :- This ap…

COBOL TECHNOLOGIES P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5505/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Apr 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…t of expenditure in relation to exempt income in accordance with Rule 8D. In the present case, the AO has failed to record satisfaction as mandated u/s.14A(2) of the Act. The Hon’ble Jurisdictional High Court in the case of HT Media Ltd. vs. PCIT, reported as 399 ITR 576 (Del.) has held that unless the AO records satisfaction as per section 14A(2) of the Act, the provisions of Rule 8D cannot be applied. Thus, in light of the above facts we find merit in ground no. 1 of assessee’s appeal, hence, the same is allowed. The corresponding ground raised by the Revenue in its appeal i.e. ground no. 16 is consequently dis…

G R N CONSTRUCTIONS PRIVATE LIMITED,NELLORE vs. DCIT., CIRCLE-1, NELLORE

ITA 1296/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad23 Apr 2025AY 2018-2019

Bench: Us:

For Appellant: Shri Pawan KumarFor Respondent: Dr.Sachin Kumar, Sr.DR
Section 143(2)Section 143(3)Section 14ASection 234C

…of the assessee that the other expenditure which 10 were being claimed qua the non-exempt income were in fact related to its exempt income. Also, a similar view had been taken by the Hon'ble High Court of Delhi in the case of H.T Media Ltd. Vs. Pr. CIT (2017) 399 ITR 576 (Delhi). 10. Now, in the case before us, we find that the A.O had failed to give any reason as to why the claim of the assessee company that no part of the expenditure could be attributed towards earning of exempt income was not to be accepted. Although, the CIT(Appeals) in his order had stated to undo the aforesaid lapse of the A.O, but a perus…

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