Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT

242 ITR 450Supreme Court of India2002#637 most cited

What is Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT authority for?

Expenditure incurred by an assessee operating a composite business that generates both taxable and non-taxable income is fully allowable without apportionment. This position led to the subsequent insertion of Section 14A, which disallowed expenditure related to earning exempt income.

154

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2025.

Also referred to as

Maharashtra Sugar Mills Ltd · Rajasthan State Warehousing Corporation · Section 14A · expenditure allowance · composite business · taxable income · non-taxable income · apportionment of expenditure · exempt income · disallowance of expenditure

Sections most often in play

Section 14ASection 143(3)Section 8DSection 36(1)(vii)Section 115JBSection 1961Section 37(1)Section 4

Issues it is cited on

strategic investmentsection 144adisallowance under section 14adisallowance u/s 14asection 14asection 115jrevenue expendituresection 115jbnon-residentsection 37previous yearsection 19

Judgments citing Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT

ASSISSTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. CENTRUM RETAIL SERVICES LIMITED, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 5970/MUM/2025[2017-18]Status: DisposedITAT Mumbai14 Nov 2025AY 2017-18

Bench: BEFORESHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri. Virabhadra Mahajan, (SR.DR.)For Respondent: Shri. Ravikant Pathak, CA
Section 115JSection 143(3)Section 14ASection 250

…ovisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax Vs. Maharashtra Sugar Mills Limited (1971) (82 ITR 452) and Rajasthan State Ware Housing Corporation Vs. Commissioner of Income Tax ((2002) 242 ITR 450) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of Inc…

DCIT, CHENNAI vs. THIRUVALLUVAR TEXTILES PRIVATE LIMITED, NAMAKKAL

In the result, appeals filed by the Revenue are dismissed

ITA 2111/CHNY/2025[2014-15]Status: DisposedITAT Chennai24 Oct 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Saujanya Ranjan, IRSFor Respondent: Mr.Y. Sridhar, FCA
Section 14ASection 36(1)(iii)

…provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited (1971) 82 ITR 452) and Rajasthan State Ware Housing Corporation v. Commissioner of Income Tax ((2002) 242 ITR 450) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall ITA Nos.2110 & 2111/Chny/2025 (AYs 2013-14 & 2014-15) Thiruvalluvar Textiles Pvt.…

DCIT, CHENNAI vs. THIRUVALLUVAR TEXTILES PRIVATE LIMITED, NAMAKKAL

In the result, appeals filed by the Revenue are dismissed

ITA 2110/CHNY/2025[2013-14]Status: DisposedITAT Chennai24 Oct 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Saujanya Ranjan, IRSFor Respondent: Mr.Y. Sridhar, FCA
Section 14ASection 36(1)(iii)

…provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited (1971) 82 ITR 452) and Rajasthan State Ware Housing Corporation v. Commissioner of Income Tax ((2002) 242 ITR 450) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall ITA Nos.2110 & 2111/Chny/2025 (AYs 2013-14 & 2014-15) Thiruvalluvar Textiles Pvt.…

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

ITA 1402/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1402/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (अपीलार्थी/Appellant) V. The Dcit, Ncc-8(1), Ltu-Ii, Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1663/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 The Dcit, Ncc-8, Chennai. (अपीलार्थी/Appellant) V. M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (प्रत्यर्थी/Respondent) Assessee By : Mr.R. Vijayaraghavan, Advocate Department By : Ms.Ann Marry Baby, Cit सुनवाईकीतारीख/Date Of Hearing : 04.06.2025 घोषणाकीतारीख /Date Of Pronouncement : 07.07.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Cross-Appeals Preferred By The Assessee As Well As The Revenue Against The Order Of The Learned Commissioner Of Income Tax

For Appellant: Mr.R. Vijayaraghavan, AdvocateFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

ITA 111/MUM/2016[2011-12]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-12
Section 115Section 14ASection 250

…rovisions of section\n14A were inserted as a response to the judgments of the Supreme Court in\nCommissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82\nITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of\nIncome-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an\nassessee carrying on a composite business giving rise to both taxable as well\nas non-taxable income, was allowable in entirety without apportionment. It\nwas thus that s.14A was inserted providing that no deduction shall be\nallowable in respect of expenditure incurred in relation to the earning of\…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 110/MUM/2016[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

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

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

ITA 5750/MUM/2015[2011-12]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-12
Section 115Section 14ASection 250

…rovisions of section\n14A were inserted as a response to the judgments of the Supreme Court in\nCommissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82\nITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of\nIncome-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an\nassessee carrying on a composite business giving rise to both taxable as well\nas non-taxable income, was allowable in entirety without apportionment. It\nwas thus that s.14A was inserted providing that no deduction shall be\nallowable in respect of expenditure incurred in relation to the earning of\…

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 5749/MUM/2015[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

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

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 4172/MUM/2013[2009-10]Status: DisposedITAT Mumbai01 Jul 2025AY 2009-10

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

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

ITA 1262/CHNY/2024[2010-11]Status: DisposedITAT Chennai16 May 2025AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Cognizant Technology Solutions Vs The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai - 600 096. (प्रत्यर्थी/Respondent) Pan: Aaacd 3312M (अपीलार्थी/Appellant) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) The Asst. Commissioner Of Vs Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai - 600 096. Pan: Aaacd 3312M (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निधारिती की ओर से/Assessee By राजस्व की ओर से /Revenue By : Shri N.V. Balaji, Advocate : Shri R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 11.03.2025 घोषणा की तारीख/Date Of Pronouncement : 16.05.2025 - 2 -

For Respondent: Shri N.V. Balaji, Advocate
Section 10ASection 14ASection 40Section 9(1)

…. The provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income-tax v. Maharashtra Sugar Mills Ltd. [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2000] 242 ITR 450/109 taxmann.com 145 (SC) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relati…

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

ITA 1207/CHNY/2024[2014-15]Status: DisposedITAT Chennai16 May 2025AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 14ASection 40Section 9(1)

…. The provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income-tax v. Maharashtra Sugar Mills Ltd. [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2000] 242 ITR 450/109 taxmann.com 145 (SC) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relati…

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

ITA 1193/CHNY/2024[2010-11]Status: DisposedITAT Chennai16 May 2025AY 2010-11

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 10ASection 14ASection 40Section 9(1)

…. The provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income-tax v. Maharashtra Sugar Mills Ltd. [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2000] 242 ITR 450/109 taxmann.com 145 (SC) in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relati…

M/S PANCHSHEEL TEXTILE MANFAC. & TRAD. vs. C I T AND ANR.

ITA/109/2007HC Punjab & Haryana13 May 2025

Bench: MRS. JUSTICE LISA GILL,MRS. JUSTICE SUDEEPTI SHARMA

…the said finding we proceed to c s entitled to deduction on ac rrowed for the acquisition of su ares by the assessee of M/S Va urse of business of trading in sh borrowed money for the purcha penditure incurred for the pu preme Court in the case of Raja CIT, 242 ITR 450(SC) laid dow rriers on different ventures, the allowed as a deduction against e business of different venture is dships laid down the following p if the income of an assessee come, he is entitled to claim pective head whether or not co taxable income; if the income of an assessee come but from different items, an one is taxable whereas inco…

ACIT, CHENNAI vs. V A TECH WABAG LIMITED, CHENNAI

In the result, the appeal of Revenue vide ITA No

ITA 147/CHNY/2018[2009-10]Status: DisposedITAT Chennai19 Feb 2025AY 2009-10

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.147/Chny/2018, Assessment Years: 2009-10 आयकर अपील सं./Ita No.1182/Chny/2018, Assessment Years: 2012-13

For Appellant: Mrs.Pushya Sitaraman, Sr.Advocate for Mr.T.Ramesh Kutty & B.SivaramanFor Respondent: Shri A.Sasikumar, CIT
Section 143(3)Section 92C

…2011-12 vide ITA Nos.953 / Chny / 2015 and 807/Chny/2016 on this issue a corporate guaranty, pronouncing as under: “…8. Before us, the Ld. CIT-DR relied on the decision of Hon'ble High Court of Madras in the case of Redington (India) Ltd. vs. Addl. CIT [2022] 242 ITR 450 (Mad.). 9. On the other hand, the Ld. counsel for the assessee only requested that in view of the decision of Hon'ble Bombay High Court in the case of Everest Kanto Cylinder Ltd. 52 taxmann.com 395 (Bom.), wherein it is held that the corporate guarantee upward adjustment in ALP can be done by taking 0.5%, but it is held to be international transa…

ACIT CENTRAL CIRCLE 3(2), CHENNAI vs. VA TECH WABAG PVT. LTD., CHENNAI

In the result, the appeal of Revenue vide ITA No

ITA 1182/CHNY/2018[2012-13]Status: DisposedITAT Chennai19 Feb 2025AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.147/Chny/2018, Assessment Years: 2009-10 आयकर अपील सं./Ita No.1182/Chny/2018, Assessment Years: 2012-13

For Appellant: Mrs.Pushya Sitaraman, Sr.Advocate for Mr.T.Ramesh Kutty & B.SivaramanFor Respondent: Shri A.Sasikumar, CIT
Section 143(3)Section 92C

…2011-12 vide ITA Nos.953 / Chny / 2015 and 807/Chny/2016 on this issue a corporate guaranty, pronouncing as under: “…8. Before us, the Ld. CIT-DR relied on the decision of Hon'ble High Court of Madras in the case of Redington (India) Ltd. vs. Addl. CIT [2022] 242 ITR 450 (Mad.). 9. On the other hand, the Ld. counsel for the assessee only requested that in view of the decision of Hon'ble Bombay High Court in the case of Everest Kanto Cylinder Ltd. 52 taxmann.com 395 (Bom.), wherein it is held that the corporate guarantee upward adjustment in ALP can be done by taking 0.5%, but it is held to be international transa…

M/S. UNITED PHOSPHORS LTD.,MUMBAI vs. DCIT CEN. CIR. - 38, MUMBAI

ITA 2990/MUM/2005[2001-2002]Status: DisposedITAT Mumbai24 Dec 2024AY 2001-2002

Bench: Shri Amit Shukla & Smt.Renu Jauhri, Accountan Member

For Appellant: Ms. Vasanti Patel, Adv &For Respondent: Shri Heera Ram Choudhary, Sr. DR
Section 143(3)

…ning of interest and dividend was a indivisible activity carried out by the appellant since there was commonness of management and control and accordingly the ratio of the decision of the Supreme Court in the case of Rajasthan Warehousing Corporation vs. CIT (242 ITR 450) was squarely applicable. VI. DISALLOWANCE OUT OF INTEREST PAID: Rs. 4.47.51.665/- Page 4 ITA Nos. 3456 & 4099/Mum/2004 Α.Υ. 2000-01 M/s United Phosphorous Ltd.) 6.1 On the facts and in the circumstances of the case and in law, the Commissioner of Income-tax (Appeals) erred in upholding the action of the Deputy Commissioner of Income-tax in disal…

THE DY CIT CC-38, MUMBAI vs. M/S. UNITED PHOSPHOUROUS LTD., MUMBAI

ITA 4099/MUM/2004[2000-2001]Status: DisposedITAT Mumbai24 Dec 2024AY 2000-2001

Bench: Shri Amit Shukla & Smt.Renu Jauhri, Accountan Member

For Appellant: Ms. Vasanti Patel, Adv &For Respondent: Shri Heera Ram Choudhary, Sr. DR
Section 143(3)

…ning of interest and dividend was a indivisible activity carried out by the appellant since there was commonness of management and control and accordingly the ratio of the decision of the Supreme Court in the case of Rajasthan Warehousing Corporation vs. CIT (242 ITR 450) was squarely applicable. VI. DISALLOWANCE OUT OF INTEREST PAID: Rs. 4.47.51.665/- Page 4 ITA Nos. 3456 & 4099/Mum/2004 Α.Υ. 2000-01 M/s United Phosphorous Ltd.) 6.1 On the facts and in the circumstances of the case and in law, the Commissioner of Income-tax (Appeals) erred in upholding the action of the Deputy Commissioner of Income-tax in disal…

M/S. UNITED PHOSPHORUS LTD,MUMBAI vs. THE DY CIT CEN CIR-38, MUMBAI

ITA 3456/MUM/2004[2000-2001]Status: DisposedITAT Mumbai24 Dec 2024AY 2000-2001

Bench: Shri Amit Shukla & Smt.Renu Jauhri, Accountan Member

For Appellant: Ms. Vasanti Patel, Adv &For Respondent: Shri Heera Ram Choudhary, Sr. DR
Section 143(3)

…ning of interest and dividend was a indivisible activity carried out by the appellant since there was commonness of management and control and accordingly the ratio of the decision of the Supreme Court in the case of Rajasthan Warehousing Corporation vs. CIT (242 ITR 450) was squarely applicable. VI. DISALLOWANCE OUT OF INTEREST PAID: Rs. 4.47.51.665/- Page 4 ITA Nos. 3456 & 4099/Mum/2004 Α.Υ. 2000-01 M/s United Phosphorous Ltd.) 6.1 On the facts and in the circumstances of the case and in law, the Commissioner of Income-tax (Appeals) erred in upholding the action of the Deputy Commissioner of Income-tax in disal…

ASST. COMMISSIONER OF INCOME-TAX 6(1)(2), MUMBAI, MUMBAI vs. INCRED HOLDINGS LIMITED (FORMERLY KNOWN AS KKR CAPITAL MARKETS INDIA LIMITED)., MUMBAI

In the result, appeals filed by the assessee in I

ITA 4366/MUM/2024[2016-17]Status: DisposedITAT Mumbai17 Oct 2024AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…he provisions of section 14A were inserted as a response to the judgments of the Supreme Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited [1971] 82 ITR 452 and Rajasthan State Ware Housing Corporation v. Commissioner of Income-tax [2002] 242 ITR 450 in terms of which, expenditure incurred by an assessee carrying on a composite business giving rise to both taxable as well as non-taxable income, was allowable in entirety without apportionment. It was thus that s.14A was inserted providing that no deduction shall be allowable in respect of expenditure incurred in relation to the earning of inco…

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