Maruti Udyog v. DCIT

92 ITD 119Income Tax Appellate Tribunal2005#1305 most cited

What is Maruti Udyog v. DCIT authority for?

The onus is on the revenue to establish the nexus between expenses incurred and exempt income before making a disallowance under section 14A.

87

judgments rely on this decision, according to BharatTax’s citation analysis of 366,469 Indian tax judgments — from 2016 to 2026.

Also referred to as

Maruti Udyog v. DCIT · 92 ITD 119 · section 14A · disallowance · exempt income · nexus · onus on revenue · expenditure

Sections most often in play

Section 14ASection 143(3)Section 194CSection 194ISection 32Section 36(1)(viii)Section 40(a)(ia)Section 41(1)

Issues it is cited on

section 8d(2)(ii)section 14a(3)section 14(2)section 14a(1)section 8dsection 33bsection 134section 198section 80ia(5)section 36(1)(viii)section 194imanagement fees

Judgments citing Maruti Udyog v. DCIT

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

…ni Mills Ltd vs. DCIT [2012] 20 taxmann.com 117 (Kolkata) d. Relaxo Footwear Ltd. v. ACIT [(2012) 50 SOT 102 (Del ITAT) e. West Bengal Infrastructure Development Finance Corporation Ltd [2023] 149 taxmann.com 181 (Calcutta) f. Maruti Udyog Ltd. v. DCIT (2005) 92 ITD 119 (Del) (A. Y. 1999- 2000) g. Jindal Saw Pipes Ltd. [2008] 118 TTJ 228 (Delhi) h. ACIT v. Eicher Ltd. [(2006) 101 TTJ 369 (Del)] i. Impulse (India) (P) Ltd v. ACIT[(2008) 22 SOT 368 (Del)] Page 35 ITA Nos.: 466, 622, 467, 623/KOL/2018 & 1406, 1696, 1407, 1697/KOL/2019 AYs: 2011-12 to 2014-15 M/s. Coal India Ltd. 7.7 It is also submitted that no disa…

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

…ni Mills Ltd vs. DCIT [2012] 20 taxmann.com 117 (Kolkata) d. Relaxo Footwear Ltd. v. ACIT [(2012) 50 SOT 102 (Del ITAT) e. West Bengal Infrastructure Development Finance Corporation Ltd [2023] 149 taxmann.com 181 (Calcutta) f. Maruti Udyog Ltd. v. DCIT (2005) 92 ITD 119 (Del) (A. Y. 1999- 2000) g. Jindal Saw Pipes Ltd. [2008] 118 TTJ 228 (Delhi) h. ACIT v. Eicher Ltd. [(2006) 101 TTJ 369 (Del)] i. Impulse (India) (P) Ltd v. ACIT[(2008) 22 SOT 368 (Del)] 7.7 It is also submitted that no disallowance u/s 14A of the Act can be made as the Apex Charges from its subsidiary companies due to various management, supervis…

DCIT, Circle - 5(1), 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

…ni Mills Ltd vs. DCIT [2012] 20 taxmann.com 117 (Kolkata) d. Relaxo Footwear Ltd. v. ACIT [(2012) 50 SOT 102 (Del ITAT) e. West Bengal Infrastructure Development Finance Corporation Ltd [2023] 149 taxmann.com 181 (Calcutta) f. Maruti Udyog Ltd. v. DCIT (2005) 92 ITD 119 (Del) (A. Y. 1999- 2000) g. Jindal Saw Pipes Ltd. [2008] 118 TTJ 228 (Delhi) h. ACIT v. Eicher Ltd. [(2006) 101 TTJ 369 (Del)] i. Impulse (India) (P) Ltd v. ACIT[(2008) 22 SOT 368 (Del)] 7.7 It is also submitted that no disallowance u/s 14A of the Act can be made as the Apex Charges from its subsidiary companies due to various management, supervis…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2917/DEL/2024[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2916/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2915/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2914/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2913/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2912/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2911/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

DCIT, Circle-10(1), Delhi vs. Indian Renewable Energy Development Agency Limited, Delhi

ITA 2910/DEL/2024[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2573/DEL/2024[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2572/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2571/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2570/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2569/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2568/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2567/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2566/DEL/2024[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…

Hari Kishan Rathi, New Delhi vs. ACIT, Central Circle-14, New Delhi

ITA 2566/DEL/2022[2018-19]Status: DisposedITAT Delhi08 Apr 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

…be 'business income'.Further reliance as placed on the decision of Co-ordinate Bench of the Tribunal in the case of P a g e | 17 ITA Nos. 2566 to 2573 & 2910 to 2917/Del/2024 Indian Renewable Energy Development Agency Ltd. Maruti Udyog Limited V. DCIT: [2005] 92 ITD 119 also held assessee wherein it has been held that interest on loan/advances to employees is assessable as ‘business income’. 12. Taking the case of income from business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fe…