What is HDFC Bank Ltd. v. DCIT authority for?

Where an assessee has sufficient interest-free funds, investments yielding exempt income are presumed to be made out of such funds, precluding disallowance of related interest expenditure under section 14A.

How many judgments cite HDFC Bank Ltd. v. DCIT?

408 judgments on BharatTax cite HDFC Bank Ltd. v. DCIT (383 ITR 529), spanning 2016 to 2026.

Which sections of the Income Tax Act does HDFC Bank Ltd. v. DCIT come up under?

It is most often cited in judgments turning on Section 14A, Section 143(3), Section 40(a)(ia), Section 36(1)(iii), Section 8D, Section 10(34).

HDFC Bank Ltd. v. DCIT (383 ITR 529)

Sanjay Digambar Malve, Nashik vs. Assistant Commissioner of Income-Tax, Circle - 1, Nashik

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

ITA 1496/PUN/2017[2013-14]Status: DisposedITAT Pune10 Jan 2020AY 2013-14

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Sanket JoshiFor Respondent: Shri S.P. Walimbe

Section 143(3)Section 14ASection 2(22)Section 2(22)(e)

…h is far more than the investments in shares and mutual funds of Rs.1.37 crores meaning thereby that the availability of interest free funds are more than the investments. We find that Hon’ble Bombay High Court in the case of HDFC Vs. DCIT reported in (2016) 383 ITR 529 (Bom) has held that when interest free funds available with the assessee are in excess of investments and then the investments are presumed to be out of interest free funds. The relevant observations of the Hon’ble Bombay High Court are as under : “15. It is clear that for the first time in the case of HDFC Bank Ltd. (Supra) that this Court too…

M/S Pradeep Trading Company, Kolkata vs. I.T.O., Ward-44(2), Kolkata

In the result, appeal of In the result, appeal of the assessee is allowed for statistical purposes

ITA 875/KOL/2019[2013-14]Status: DisposedITAT Kolkata10 Jan 2020AY 2013-14

Section 234BSection 250

…iance Utilities & Power Ltd. [2009] 313 ITR Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bombay) and in the case of and in the case of HDFC Bank Ltd. v. Deputy Commissioner of Income Bank Ltd. v. Deputy Commissioner of Income-tax - 2(3), Mumbai, [2016] 383 ITR 529 (Bombay) 2(3), Mumbai, [2016] 383 ITR 529 (Bombay). Hence, I set aside to the file of the Assessing Officer with a direction that he may consider all et aside to the file of the Assessing Officer with a direction that he may consider all et aside to the file of the Assessing Officer with a direction that he may consider all the interest free fund…

ACIT, Circle - 5(2), Kolkata vs. M/S. Hindusthan National Glass & Industries Ltd., Kolkata

In the result, appeal of the revenue is dismissed

ITA 184/KOL/2018[2012-13]Status: DisposedITAT Kolkata31 Dec 2019AY 2012-13

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2012-13 Asstt. Commissioner Of Income Tax, Circle-5(2), Kolkata……………......….………....…........Appellant Vs. M/S. Hindusthan National Glass & Industries...........................................……………….....Respondent 2, Red Cross Place Kolkata – 700 001 [Pan : Aaach 7557 G] Appearances By: Shri Akkal Dudhewala, A/R, Appeared On Behalf Of The Assessee. Shri P.K. Srihari, Cit Sr. D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : November 28Th, 2019 Date Of Pronouncing The Order : December 31St, 2019 Order Per J. Sudhakar Reddy, Am :-

Section 14ASection 250Section 80ISection 92B

…the presumption in such cases is that, interest free funds have been invested in non funds have been invested in non-interest bearing investments [*HDFC Bank Ltd. v. HDFC Bank Ltd. v. Deputy Commissioner of Income mmissioner of Income-tax -2(3), Mumbai [2016] 383 ITR 529 (Bombay) 2(3), Mumbai [2016] 383 ITR 529 (Bombay)], [*CIT vs. Rasoi Ltd. (ITA No. 109 of 2016) dt. 15/02/2017 vs. Rasoi Ltd. (ITA No. 109 of 2016) dt. 15/02/2017]. The ld. CIT(A) at page 46 fist para of ]. The ld. CIT(A) at page 46 fist para of his order, held that the proposition of law his order, held that the proposition of law in the above re…

ACIT, Ltu - 2, Kolkata vs. M/S. Uco Bank, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 584/KOL/2018[2010-11]Status: DisposedITAT Kolkata11 Dec 2019AY 2010-11

Bench: Shri P.M. Jagtap, Vice- & Shri A.T. Varkey

Section 143(3)Section 14ASection 201Section 40

…ITA No. 584/KOL/2018 Assessment Year: 2010-2011 M/s. UCO Bank IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘A’ BENCH, KOLKATA Before Shri P.M. Jagtap, Vice-President and Shri A.T. Varkey, Judicial Member I.T.A. No. 584/KOL/2018 Assessment Year: 2010-2011 Assistant Commissioner of Income Tax,....................................Appellant LTU-2, Kolkata, Aayakar Bhawan Poorva, 9 th Floor, Large Tax Payer Unit-2, 110, Shantipally, Kolkata-700107 -Vs.- M/s. UCO Bank,............................................................................Respondent 10, B.T.M. Sarani, Kolkata-700001 [PAN:AAACU3561B] Appearan…

Deputy Commissioner of Income Tax Central Circle-6(2), Mumbai vs. Sameer Nerurkar, Mumbai

In the result, the appeals are dismissed

ITA 4891/MUM/2017[2007-08]Status: DisposedITAT Mumbai31 Oct 2019AY 2007-08

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2007-08 & Assessment Year: 2008-09

For Appellant: Mr. Gaurav Kabra, ARFor Respondent: Ms. Vidisha Kalara, CIT-DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 144Section 153A

…A.Y. 2007-08 & A.Y. 2008-09. As mentioned earlier, ld. CIT(A) has confirmed or deleted the addition/disallowance for the above two assessment years on the basis of incriminating documents found during the course of search. 6. In HDFC Bank Ltd. v. DCIT (2016) 383 ITR 529 (Bom), the Hon’ble Bombay High Court at para 23 has held: “We are conscious of the fact that we are fallible and, therefore, an order passed by us may not meet the approval of all and some may justifiably consider our order to be incorrect. However the same has to be corrected/rectified in a manner known to law and not by disregarding binding de…

Deputy Commissioner of Income Tax Central Circle-6(2), Mumbai vs. Sameer Nerurkar, Mumbai

In the result, the appeals are dismissed

ITA 4883/MUM/2017[2008-09]Status: DisposedITAT Mumbai31 Oct 2019AY 2008-09

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2007-08 & Assessment Year: 2008-09

For Appellant: Mr. Gaurav Kabra, ARFor Respondent: Ms. Vidisha Kalara, CIT-DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 144Section 153A

…A.Y. 2007-08 & A.Y. 2008-09. As mentioned earlier, ld. CIT(A) has confirmed or deleted the addition/disallowance for the above two assessment years on the basis of incriminating documents found during the course of search. 6. In HDFC Bank Ltd. v. DCIT (2016) 383 ITR 529 (Bom), the Hon’ble Bombay High Court at para 23 has held: “We are conscious of the fact that we are fallible and, therefore, an order passed by us may not meet the approval of all and some may justifiably consider our order to be incorrect. However the same has to be corrected/rectified in a manner known to law and not by disregarding binding de…

DCIT, Cir-12(1), Kolkata vs. M/S Bengal Ambuja Housing Development Ltd., Kolkata

In the result, the both appeals of the Revenue are dismissed

ITA 1514/KOL/2015[2010-2011]Status: DisposedITAT Kolkata18 Oct 2019AY 2010-2011

Bench: Shri A. T. Varkey, Jm & Shri A.L.Saini, Am]

Section 80ISection 80i

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH: KOLKATA [Before Shri A. T. Varkey, JM & Shri A.L.Saini, AM] I.TA No. 1514/Kol/2015 Assessment Year: 2010-11 And I.TA No. 1515/Kol/2015 Assessment Year: 2011-12 DCIT, Cir-12(1), Kolkata Vs. M/s. Bengal Ambuja Housing Development Ltd. PAN: AABCB0977F Appellant Respondent Date of Hearing 01.08.2019 Date of Pronouncement 18. 10 .2019 For the Appellant Dr. (Shri ) P.K. Srihari, CIT, ld.DR For the Respondent Shri D.S.Damle, FCA & Shri Akkal Dudhwewala, FCA, ld.ARs ORDER PER SHRI A.T. VARKEY, JM These appeals are preferred by the Revenue against the separate o…

Deputy Commissioner of Income-Tax, Pune vs. M/S. Advik Hi-Tech Pvt. Ltd., Pune

In the result, the appeal of Revenue is dismissed

ITA 1197/PUN/2017[2012-13]Status: DisposedITAT Pune16 Oct 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri Sharad ShahFor Respondent: Ms. Nandita Kanchan

Section 14Section 143(3)Section 14ASection 41(1)Section 80I

…in appeal before us. 11. Before us, Ld. D.R. supported the order of AO. Ld.A.R. on the other hand reiterated the submissions made before AO and Ld.CIT(A). He also relied on the decision of Hon’ble Bombay High Court in the case of HDFC Vs. DCIT reported in 383 ITR 529. He thus supported the order of Ld.CIT(A). 12. We have heard the rival submissions and perused the material on record. The issue in the present ground is with respect to disallowance u/s 14A of the Act. AO was of the view that disallowance u/s 14A of the Act has to be worked out even on the investments shown under stock-in-trade. We find that H…

DCIT 10(2)(2), Mumbai vs. M. Suresh Exports P.Ltd, Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 5266/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 Sept 2019AY 2012-13

Bench: Shri Shamim Yahya (Am) & Shri Ravish Sood (Jm)

Section 14A

…ular year. If that is so then the case of the Appellant 2 M/s. M. Suresh Exports P. Ltd. company is a squarely covered by the ratio of jurisdictional high course i e. Bombay High Court In case of HDFC Bank Limited- (2014) 366 ITR 555 (Bom), HDFC Bank (2016) 383 ITR 529 (Bom) and Reliance Utility Power Ltd (2009) 313 ITR 340. The hon’ble Bombay High Court has laid down the proposition that when own Interest free fund is excess than the investment made by the appellant company then no disallowance u/s. 14A of the Act can be restored. In view of submission of the appellant company and ratio laid down by Hon'ble Bo…

Everest Kanto Cylinder Ltd, Mumbai vs. Asst CIT (Ltu) 2, Mumbai

In the result, the appeal filed by the assessee is hereby partly allowed

ITA 740/MUM/2016[2011-12]Status: DisposedITAT Mumbai06 Sept 2019AY 2011-12

Bench: Shri G.S.Pannu, Vp & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.740/Mum/2016 (निर्धारण वर्ा / Assessment Year: 2011-12) M/S. Everest Kanto Cylinder बिधम/ Asst. Commissioner Of Ltd. Income Tax (Ltu)-2 Vs. 29Th Centre No.1, 204, Raheja Centre, Free Press Journal Marg, World Trade Centre, Nariman Point, Cuffe Parade, Mumbai - 400021 Mumbai - 400005 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaace0836F (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Shekhar Gupta Revenue By: Mrs. Malathi Shridharan सुनवाई की तारीख / Date Of Hearing: 05.09.2019 घोषणा की तारीख /Date Of Pronouncement: 06.09.2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Assessment Order Passed U/S.144C(5) Of The Income Tax Act, 1961 ( In Short “The Act”) In Pursuance Of The Directions Of Dispute Resolution Panel – I, Mumbai [Hereinafter Referred To As The “Drp”] Dated 03.12.2015 Relevant To The A.Y. 2011-12. 2. The Assessee Has Raised The Following Grounds: - A.Y.2011-12

For Appellant: Shri Shekhar GuptaFor Respondent: Mrs. Malathi Shridharan

Section 10(33)Section 115JSection 143(3)Section 144C(1)Section 144C(5)Section 14ASection 52C

….16,37,570/- and also disallowed the same u/s.115JB of the Act. The learned representative of the assessee has argued that the assessee was having his own fund more than the investment, therefore, in view of the law settled in HDFC Bank Ltd. Vs. DCIT (Bombay) 383 ITR 529, the investment was liable to be treated from its own funds and no expenditure of any kind was liable to be assessed to earn the said income in accordance with law. However, on the other hand the learned representative of the department has strongly relied upon the order passed by the Assessing Officer under challenge. By giving the careful thoug…

Idbi Bank Ltd., Mumbai vs. ACIT (Ltu)-2, Mumbai

In the result this ground of appeal is

ITA 3423/MUM/2018[2008-09]Status: DisposedITAT Mumbai03 Sept 2019AY 2008-09

Bench: Shri R.C. Sharma & Shri Pawan Singh

Section 115JSection 143(3)Section 147Section 148Section 254(1)

…essee’s cases as the interest free funds of ₹14567.58 Crore are far exceed the securities from which tax free income was earned of ₹ 1598.60 Crore. In support of his submission the learned AR relied upon the decision of Bombay High Court in case of HDFC Bank (383 ITR 529) and Gujarat High Court in Syntax Industries Ltd (82 taxmann.com 171). It was submitted that the SLP filed against the order of Gujarat High Court has been dismissed by Hon’ble Supreme Court. 13. On the other head the learned DR for the revenue after going through digital furnished in the chart and decision relied by learned AR of the assessee, s…

Assistant Commissioner of Income Tax 2(3)(2), Mumbai vs. Kotak Mahindra Bank Limited, Mumbai

In the result, both the appeals filed by the revenue are dismissed

ITA 781/MUM/2018[2013-14]Status: DisposedITAT Mumbai27 Aug 2019AY 2013-14

Bench: Shri Shamim Yahya & Shri Pawan Singh

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

…nds, no disallowance u/s 14A is warranted. He also submitted that when the investments are made in view of having strategic interest, no disallowance could be made. The following are the decisions, the Ld.Counsel relied upon:- 1. HDFC Bank Ltd vs DCIT (2016) 383 ITR 529 (Bom) 2. CIT vs HDFC Bank Ltd (2016) 383 ITR 529 (Bom) 3. CIT vs Reliance Utilities & Power Ltd (2009) 313 ITR 340 (Bom) 4. CIT vs Bombay Oil Industries Ltd 23014) 42 Taxmann.com 440 (Bom) 5. CIT vs Reliance Industries Ltd CA No. 10 of 2010 (SLP(c) no.37/2010 6. PCIT vs Sintex Industries Ltd (2018) 255 Taxman 171 (SC) 7. PCIT vs Sintex Industrie…

Asst CIT 5(3)(2), Mumbai vs. Spaco Technologies (I) P.Ltd, Mumbai

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

ITA 4034/MUM/2018[2014-15]Status: DisposedITAT Mumbai20 Aug 2019AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon’Blem/S. Spaco Technologies (I) Private Ltd., V. Acit – 5(3)(2) 901, Prasad Chambers, Opera House Aayakar Bhavan Mumbai 400 004 M.K. Road Mumbai-400 020 Pan: Aabcs5307E (Appellant) (Respondent) Dcit– 5(3)(2) V. M/S. Spaco Technologies (I) Private Ltd., Room No. 573, 5Th Floor 901, Prasad Chambers, Opera House Aayakar Bhavan Mumbai 400 004 M.K. Road Mumbai-400 020 Pan: Aabcs5307E (Appellant) (Respondent) Assessee By : Milin Dattani Department By : Shri Chaudhary Arunkumar Singh

For Appellant: Milin DattaniFor Respondent: Shri Chaudhary Arunkumar Singh

Section 10(35)Section 14A

…echnologies (I) Private Ltd., identical issue came up before the Tribunal for the A.Y. 2011-12 and the Tribunal following the decision of the Hon'ble Bombay High Court in the case of CIT v. Reliance Utilities and Power Ltd. [313 ITR 340] and HDFC Ltd v. DCIT [383 ITR 529] deleted the interest expenses as the assessee had sufficient reserves and surplus more than the investments made. Ld. Counsel for the assessee referring to Page No. 6 of the Paper Book which is the balance sheet of the assessee company as on 31.03.2013 submits that for the current Assessment Year the assessee is having reserves and surplus to th…

Spaco Technologies (I) P.Ltd, Mumbai vs. Asst CIT 5(3)(2), Mumbai

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

ITA 1811/MUM/2018[2013-14]Status: DisposedITAT Mumbai20 Aug 2019AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon’Blem/S. Spaco Technologies (I) Private Ltd., V. Acit – 5(3)(2) 901, Prasad Chambers, Opera House Aayakar Bhavan Mumbai 400 004 M.K. Road Mumbai-400 020 Pan: Aabcs5307E (Appellant) (Respondent) Dcit– 5(3)(2) V. M/S. Spaco Technologies (I) Private Ltd., Room No. 573, 5Th Floor 901, Prasad Chambers, Opera House Aayakar Bhavan Mumbai 400 004 M.K. Road Mumbai-400 020 Pan: Aabcs5307E (Appellant) (Respondent) Assessee By : Milin Dattani Department By : Shri Chaudhary Arunkumar Singh

For Appellant: Milin DattaniFor Respondent: Shri Chaudhary Arunkumar Singh

Section 10(35)Section 14A

…echnologies (I) Private Ltd., identical issue came up before the Tribunal for the A.Y. 2011-12 and the Tribunal following the decision of the Hon'ble Bombay High Court in the case of CIT v. Reliance Utilities and Power Ltd. [313 ITR 340] and HDFC Ltd v. DCIT [383 ITR 529] deleted the interest expenses as the assessee had sufficient reserves and surplus more than the investments made. Ld. Counsel for the assessee referring to Page No. 6 of the Paper Book which is the balance sheet of the assessee company as on 31.03.2013 submits that for the current Assessment Year the assessee is having reserves and surplus to th…

DCIT CC 6(3), Mumbai vs. Horizon Infrastructure Ltd, Mumbai

In the result, appeal filed by the assessee ITA No

ITA 844/MUM/2018[2013-14]Status: DisposedITAT Mumbai09 Aug 2019AY 2013-14

Bench: Shri G. Manjunatha & Shri Ravish Soodita No.2471/Mum/2018 (Assessment Year: 2013-14) (Assessment Year: 2014-15) Horizon Infrastructure Ltd. Vs. Dcit,Cc-6(3) (Now Known As Skil Air India Building Infrastructure Ltd.) Nariman Point Mumbai-400 021 Skil House, 209 Bank Street Cross Lane, Fort Mumbai-400 023

Section 14ASection 32

…T(A), in respect of investments in group companies, for controlling interest and also for strategic purpose, investments in shares and securities out of own funds in light of decision of Hon’ble Bombay High Court in the case of HDFC bank Ltd. Vs DCIT (2016) 383 ITR 529 and CIT vs. Reliance Utilities and Power Limited (2009) 313 ITR 340 that no disallowance could be made, in respect of interest expenditure, where own funds in form of share capital and reserves is in excess of investment in shares. The assesee had also taken one more argument, in respect of disallowances of expenditure under Rule 8D(2)(iii)…

Horizon Infrastructure Ltd(Now Known As Skil Infrastructure Limited), Mumbai vs. DCIT CC 6(3), Mumbai

In the result, appeal filed by the assessee ITA No

ITA 2470/MUM/2018[2013-14]Status: DisposedITAT Mumbai09 Aug 2019AY 2013-14

Bench: Shri G. Manjunatha & Shri Ravish Soodita No.2471/Mum/2018 (Assessment Year: 2013-14) (Assessment Year: 2014-15) Horizon Infrastructure Ltd. Vs. Dcit,Cc-6(3) (Now Known As Skil Air India Building Infrastructure Ltd.) Nariman Point Mumbai-400 021 Skil House, 209 Bank Street Cross Lane, Fort Mumbai-400 023

Section 14ASection 32

…T(A), in respect of investments in group companies, for controlling interest and also for strategic purpose, investments in shares and securities out of own funds in light of decision of Hon’ble Bombay High Court in the case of HDFC bank Ltd. Vs DCIT (2016) 383 ITR 529 and CIT vs. Reliance Utilities and Power Limited (2009) 313 ITR 340 that no disallowance could be made, in respect of interest expenditure, where own funds in form of share capital and reserves is in excess of investment in shares. The assesee had also taken one more argument, in respect of disallowances of expenditure under Rule 8D(2)(iii)…

Horizon Country Wide Logistics Ltd(Now Succeeded on Amalgamation by Skil Infrastructure Limited ), Mumbai vs. DCIT 1(2)(Presently ACIT--6(3)), Mumbai

In the result, appeal filed by the assessee ITA No

ITA 5817/MUM/2017[2010-11]Status: DisposedITAT Mumbai09 Aug 2019AY 2010-11

Bench: Shri G. Manjunatha & Shri Ravish Soodita No.2471/Mum/2018 (Assessment Year: 2013-14) (Assessment Year: 2014-15) Horizon Infrastructure Ltd. Vs. Dcit,Cc-6(3) (Now Known As Skil Air India Building Infrastructure Ltd.) Nariman Point Mumbai-400 021 Skil House, 209 Bank Street Cross Lane, Fort Mumbai-400 023

Section 14ASection 32

…T(A), in respect of investments in group companies, for controlling interest and also for strategic purpose, investments in shares and securities out of own funds in light of decision of Hon’ble Bombay High Court in the case of HDFC bank Ltd. Vs DCIT (2016) 383 ITR 529 and CIT vs. Reliance Utilities and Power Limited (2009) 313 ITR 340 that no disallowance could be made, in respect of interest expenditure, where own funds in form of share capital and reserves is in excess of investment in shares. The assesee had also taken one more argument, in respect of disallowances of expenditure under Rule 8D(2)(iii)…

DCIT CC 6(3), Mumbai vs. Horizon Infrastructure Ltd, Mumbai

In the result, appeal filed by the assessee ITA No

ITA 5779/MUM/2017[2012-13]Status: DisposedITAT Mumbai09 Aug 2019AY 2012-13

Bench: Shri G. Manjunatha & Shri Ravish Soodita No.2471/Mum/2018 (Assessment Year: 2013-14) (Assessment Year: 2014-15) Horizon Infrastructure Ltd. Vs. Dcit,Cc-6(3) (Now Known As Skil Air India Building Infrastructure Ltd.) Nariman Point Mumbai-400 021 Skil House, 209 Bank Street Cross Lane, Fort Mumbai-400 023

Section 14ASection 32

…T(A), in respect of investments in group companies, for controlling interest and also for strategic purpose, investments in shares and securities out of own funds in light of decision of Hon’ble Bombay High Court in the case of HDFC bank Ltd. Vs DCIT (2016) 383 ITR 529 and CIT vs. Reliance Utilities and Power Limited (2009) 313 ITR 340 that no disallowance could be made, in respect of interest expenditure, where own funds in form of share capital and reserves is in excess of investment in shares. The assesee had also taken one more argument, in respect of disallowances of expenditure under Rule 8D(2)(iii)…

Bharat Petroleum Corporation Ltd, Mumbai vs. ACIT 2(1)(1), Mumbai

In the result, the appeals of the assessee are partly allowed and that of the Revenue in AY 2011-12 is dismissed

ITA 2685/MUM/2018[2011-12]Status: DisposedITAT Mumbai07 Aug 2019AY 2011-12

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

For Appellant: Shri Jehangir D.J. Mistri, Sr. AdvocateFor Respondent: Shri N.S. Jang Pangi, CIT DR

Section 143(3)Section 14A

…judgment of the Hon’ble High Court of Bombay in the case of Reliance Utility and Power Ltd. (Supra), which thereafter had been followed by the Hon’ble High Court in the case of CIT Vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) and HDFC Bank Ltd. Vs. DCIT (2016) 383 ITR 529 (Bom). We thus are of the considered view that the facts of the present case are squarely covered by the aforesaid judgments of the Hon’ble Jurisdictional High Court, as well as the order passed by the Tribunal in the assessee‟s own case for the immediately preceding years, viz. A.Ys. 2002-03 and 2003-04. 9. Alternatively, we find that the A.O af…

Bharat Petroleum Corporation Ltd, Mumbai vs. DCIT (DCIT) RG 2(1), Mumbai

In the result, the appeals of the assessee are partly allowed and that of the Revenue in AY 2011-12 is dismissed

ITA 7606/MUM/2014[2010-11]Status: DisposedITAT Mumbai07 Aug 2019AY 2010-11

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

For Appellant: Shri Jehangir D.J. Mistri, Sr. AdvocateFor Respondent: Shri N.S. Jang Pangi, CIT DR

Section 143(3)Section 14A

…judgment of the Hon’ble High Court of Bombay in the case of Reliance Utility and Power Ltd. (Supra), which thereafter had been followed by the Hon’ble High Court in the case of CIT Vs. HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) and HDFC Bank Ltd. Vs. DCIT (2016) 383 ITR 529 (Bom). We thus are of the considered view that the facts of the present case are squarely covered by the aforesaid judgments of the Hon’ble Jurisdictional High Court, as well as the order passed by the Tribunal in the assessee‟s own case for the immediately preceding years, viz. A.Ys. 2002-03 and 2003-04. 9. Alternatively, we find that the A.O af…

HDFC Bank Ltd. v. DCIT

What is HDFC Bank Ltd. v. DCIT authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing HDFC Bank Ltd. v. DCIT

Sanjay Digambar Malve, Nashik vs. Assistant Commissioner of Income-Tax, Circle - 1, Nashik

M/S Pradeep Trading Company, Kolkata vs. I.T.O., Ward-44(2), Kolkata

ACIT, Circle - 5(2), Kolkata vs. M/S. Hindusthan National Glass & Industries Ltd., Kolkata

ACIT, Ltu - 2, Kolkata vs. M/S. Uco Bank, Kolkata

Deputy Commissioner of Income Tax Central Circle-6(2), Mumbai vs. Sameer Nerurkar, Mumbai

Deputy Commissioner of Income Tax Central Circle-6(2), Mumbai vs. Sameer Nerurkar, Mumbai

DCIT, Cir-12(1), Kolkata vs. M/S Bengal Ambuja Housing Development Ltd., Kolkata

Deputy Commissioner of Income-Tax, Pune vs. M/S. Advik Hi-Tech Pvt. Ltd., Pune

DCIT 10(2)(2), Mumbai vs. M. Suresh Exports P.Ltd, Mumbai

Everest Kanto Cylinder Ltd, Mumbai vs. Asst CIT (Ltu) 2, Mumbai

Idbi Bank Ltd., Mumbai vs. ACIT (Ltu)-2, Mumbai

Assistant Commissioner of Income Tax 2(3)(2), Mumbai vs. Kotak Mahindra Bank Limited, Mumbai

Asst CIT 5(3)(2), Mumbai vs. Spaco Technologies (I) P.Ltd, Mumbai

Spaco Technologies (I) P.Ltd, Mumbai vs. Asst CIT 5(3)(2), Mumbai

DCIT CC 6(3), Mumbai vs. Horizon Infrastructure Ltd, Mumbai

Horizon Infrastructure Ltd(Now Known As Skil Infrastructure Limited), Mumbai vs. DCIT CC 6(3), Mumbai

Horizon Country Wide Logistics Ltd(Now Succeeded on Amalgamation by Skil Infrastructure Limited ), Mumbai vs. DCIT 1(2)(Presently ACIT--6(3)), Mumbai

DCIT CC 6(3), Mumbai vs. Horizon Infrastructure Ltd, Mumbai

Bharat Petroleum Corporation Ltd, Mumbai vs. ACIT 2(1)(1), Mumbai

Bharat Petroleum Corporation Ltd, Mumbai vs. DCIT (DCIT) RG 2(1), Mumbai