Ltd. v. DCIT

76 Taxmann.com 268High Court2016#1100 most cited

What is Ltd. v. DCIT authority for?

Where the Assessing Officer performs an elaborate analysis to determine disallowance under Section 14A, the mere absence of a specific record of dissatisfaction with the assessee's calculation does not nullify the disallowance, provided the statutory steps are followed.

101

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

India Bulls Financial Services Ltd v DCIT · Section 14A · Rule 8D · disallowance for exempt income · AO's satisfaction · recording dissatisfaction · elaborate analysis · procedural validity of disallowance

Issues it is cited on

Judgments citing Ltd. v. DCIT

TECH MAHINDRA BUSINESS SERVICES LTD.,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-13(3)(2), MUMBAI

In the result, appeal by the assessee is partly allowed

ITA 1256/MUM/2022[2017-18]Status: DisposedITAT Mumbai24 Jul 2023AY 2017-18

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.1256/मुं/ 2022 (िन.व.2017-18) Tech Mahindra Business Services Limited. Ground Floor, Spectrum Towers, Mindspace, Chincholi Bunder Link Road, Malad West, Mumbai – 400 064. Pan: Aabch-8136-L ...... अपीलाथ" /Appellant बनाम Vs. The Assistant Commissioner Of Income Tax, Circle – 13(3)(2), Room No.229, 2Nd Floor, Aaykar Bhavan, Mk Road, Mumbai – 400 020. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D,Mistri, Sr. Advocate With Shri Harsh Kapadia, Advocate "ितवादी "ारा/Respondent By : Ms. Richa Gulati, Sr.Ar सुनवाई क" ितिथ/ Date Of Hearing : 28/04/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 24/07/2023 आदेश आदेश/ Order आदेश आदेश Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 30/03/2022, For The Assessment Year 2017-18. 2. The Assessee In Appeal Has Raised Solitary Ground Assailing Disallowance Made U/S. 14A Of Income Tax Act, 1961 (In Short ‘The Act’) R.W. Rule 8D Of The Income Tax Rules, 1962 (In Short ‘The Rules’) Amounting To Rs.80,08,567/-. The Assessee Vide Application Dated 13/09/2022 Has Raised An Additional Ground

For Appellant: Shri J.D,Mistri, Sr. Advocate with Shri Harsh Kapadia, AdvocateFor Respondent: Ms. Richa Gulati, Sr.AR
Section 14A

…आयकर अपीलीय अिधकरण मुंबई पीठ “ई ”, मुंबई पीठ "ी िवकास अव"थी, "याियक सद"य एवं "ी गगन गोयल, लेखाकार सद"य के सम" IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER & SHRI GAGAN GOYAL, ACCOUNTANT MEMBER आअसं.1256/मुं/ 2022 (िन.व.2017-18) Tech Mahindra Business Services Limited. Ground Floor, Spectrum Towers, Mindspace, Chincholi Bunder Link Road, Malad West, Mumbai – 400 064. PAN: AABCH-8136-L ...... अपीलाथ" /Appellant बनाम Vs. The Assistant Commissioner of Income Tax, Circle – 13(3)(2), Room No.229, 2nd Floor, Aaykar Bhavan, MK Road, Mumbai – 400 020. ..... "ि…

SHARE MICROFIN LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYERABAD

In the result, appeal filed by the assessee is dismissed

ITA 430/HYD/2020[2016-17]Status: DisposedITAT Hyderabad12 Jun 2023AY 2016-17

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2016-17 Share Microfin Ltd Vs. Dy. C. I. T. Hyderabad Circle 3(1) Pan:Aaecs9243C Hyderabad (Appellant) (Respondent) Assessee By: Shri A.G. Sitaraman, Ca Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 17/04/2023 Date Of Pronouncement: 12/06/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23003.2020 Of The Learned Cit (A)-3, Hyderabad Relating To A.Y.2016-17. 2. There Is A Delay Of 5 Days In Filing Of This Appeal By The Assessee For Which The Assessee Has Filed A Condonation Application Along With An Affidavit Explaining The Reasons For Such Delay. The Reasons Given Therein Is Due To The Prevailing Covid 2019 Pandemic. After Considering The Contents Of The Condonation Application Explaining The Reasons Filed Along With The Affidavit, The Delay In Filing Of The Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Adjudication.

For Appellant: Shri A.G. Sitaraman, CAFor Respondent: Shri Jeevan Lal Lavidiya, DR
Section 143(2)Section 28Section 41(1)

…ITA 430 of 2020 Share Microfin Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri K. Narasimha Chary, Judicial Member Assessment Year: 2016-17 Share Microfin Ltd Vs. Dy. C. I. T. Hyderabad Circle 3(1) PAN:AAECS9243C Hyderabad (Appellant) (Respondent) Assessee by: Shri A.G. Sitaraman, CA Revenue by: Shri Jeevan Lal Lavidiya, DR Date of hearing: 17/04/2023 Date of pronouncement: 12/06/2023 ORDER Per R.K. Panda, A.M This appeal filed by the assessee is directed against the order dated 23003.2020 of the lear…

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