How many judgments cite Maxopp Investment Ltd. v. CIT?

516 judgments on BharatTax cite Maxopp Investment Ltd. v. CIT (347 ITR 272), spanning 2013 to 2026.

Which sections of the Income Tax Act does Maxopp Investment Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 14A, Section 143(3), Section 115JB, Section 8D, Section 36(1)(vii), Section 36(1)(iii).

Maxopp Investment Ltd. v. CIT

347 ITR 272High Court2012#129 most cited

What is Maxopp Investment Ltd. v. CIT authority for?

Disallowance under Section 14A cannot exceed the exempt income earned. The Assessing Officer must record satisfaction regarding the assessee's accounts before making any disallowance.

516

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2013 to 2026.

Also referred to as

Maxopp Investment Ltd. v. CIT · section 14A · disallowance under section 14A · exempt dividend income · satisfaction of AO · Rule 8D · disallowance cannot exceed exempt income

Also reported as

203 Taxmann 36415 Taxmann.com 390

Sections most often in play

Section 14A Section 143(3)Section 115JB Section 8D Section 36(1)(vii)Section 36(1)(iii)Section 36(1)(viia)Section 36(1)(viii)

Issues it is cited on

section 14a(2)disallowance under section 14a disallowance u/s 14a section 14a revenue expenditure section 115j section 115jb section 19 section 37(1)section 36 section 37 section 115

Judgments citing Maxopp Investment Ltd. v. CIT

Jaypee Infra Ventures Private Limited, Gautam Buddha Nagar vs. DCIT Circle 13(2), New Delhi

In the result, the appeal of assessee is allowed as above

ITA 3946/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Jun 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14A

…14A of the Act without recording any reason for rejecting the assessee’s working of disallowance under section 14A of the Act. 5. The Ld. AR further placed reliance on the decision of the Hon’ble Supreme Court in the case of Maxopp Investment vs. CIT [2012] 347 ITR 272 and Godrej & Boyce Manufacturing Co. Ltd. v. DCIT (2017) 394 ITR 449 (SC) 3 Jaypee Infra Ventures Pvt. Ltd. to submit that the application of Rule 8D of the Income Tax Rules is not mandatory. Further, it was submitted that the entire investments made by the appellant assessee were very old investment in group concerns and there was no transacti…

Assistant Commissioner of Income Tax, Mumbai vs. Indiabulls Real Estatelimited, Gurgaon

Appeal is dismissed

ITA 2179/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Mar 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarthe Assistant Commissioner Of V/S. M/S Indiabulls Real Income Tax, Central Circle – 6(4), बनाम Estate Limited, M-62 & Mumbai, 63, 1Stfloor, Connaught Vijay Kumar Singh, Deputy Place, New Delhi – 110 001 Commissioner Of Income Tax, Central Circle 6(4), Mumbai, Room No. 453, 4 Th Floor, Kautilya Bhavan, G Block, Bkc, Bandra(E), Mumbai 400 051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabci5194F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri K. Gopal & Shri Om Kandalkar,ARsFor Respondent: Mr. R.A. Dhyani (CIT DR)

Section 143(3)Section 14ASection 37(1)

…IN THE INCOME-TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER The Assistant Commissioner of v/s. M/s Indiabulls Real Income Tax, Central Circle – 6(4), बनाम Estate Limited, M-62 & Mumbai, 63, 1stFloor, Connaught Vijay Kumar Singh, Deputy Place, New Delhi – 110 001 Commissioner of Income Tax, Central Circle 6(4), Mumbai, Room No. 453, 4 th Floor, Kautilya Bhavan, G Block, BKC, Bandra(E), Mumbai 400 051, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AABCI5194F Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant by : Sh…

Dy. Commissioner of Income Tax Circle-7 Pune, Pune vs. John Deere India Private Limited, Pune

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

ITA 1910/PUN/2024[2015-16]Status: DisposedITAT Pune30 Dec 2024AY 2015-16

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Ramnath P. Murkune

Section 143(2)Section 14A

…ection 14A attracts in the case of the appellant. The AO has not brought on record any fact or material to show that any expenditure has been incurred on the activity which has resulted into non taxable income. In the case of Maxopp Investment Ltd reported in 347 ITR 272 (DELHI), Hon’ble Delhi HC 5 has held that AO must first record his satisfaction that assessee’s claim is incorrect that no expenditure was incurred on tax free income, then he should apply rule 8Dto calculate the amount to be disallowed. 3.4 I also would like to mentioned here that the similar issue of disallowance u/s 14A of the Act has been de…

Deputy Commissioner of Income Tax, Circle- V (I), Kolkata vs. Birla Corporation Limited, Birla Building

In the result, both the appeals of the revenue is dismissed, as also the cross objection filed by the assessee for both the years

ITA 1024/KOL/2023[2016-17]Status: DisposedITAT Kolkata24 Dec 2024AY 2016-17

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH” KOLKATA SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A. No. 1024/Kol/2023 Assessment Year: 2016-17 Deputy Commissioner of Income Tax, Circle V(1), Kolkata Aayakar Bhawan, 8th Floor, P-7 Chowringhee Square, Kolkata - 700069 .....................…...…………….... Appellant vs. Birla Corporation Limited, 9/1 R.N. Mukherjee Road, Birla Building, 3rd Floor, Kolkata - 700001 [PAN: AABCB2075J] ...............…..….................... Respondent C.O. No. 04/Kol/2024 (Arising out of ITA No. 1024/Kol/2023) Assessment Year: 2016-17 Birla Corpo…

ACIT 1(1), Mumbai vs. Bennett Coleman & Co. Ltd, Mumbai

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal filed by the revenue stands dismissed

ITA 6538/MUM/2012[2009-10]Status: DisposedITAT Mumbai17 Dec 2024AY 2009-10

Bench: Smt. Beena Pillai & Smt Renu Jauhriassessment Year: 2009-10

For Appellant: RespondentFor Respondent: Shri Kailash C. Kanojiya, CIT DR

Section 143(2)Section 14ASection 14A(1)Section 14A(2)

…on 14A(2) and (3) read with Rule 8D of the Rules or a best judgment determination, as earlier prevailing, would become applicable." (Emphasis Supplied). 12. Similar view was expressed by the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT: 347 ITR 272: "41. Having regard to the language of Section 14A(2) of the Act, read with Rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance under Section 14A was not correct. It will be in those cases where the a…

Pr. Commissioner of Income Tax -7, Delhi vs. Punjab National Bank

ITA/193/2024HC Delhi06 Dec 2024

Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE THE ACTING CHIEF JUSTICE

Section 143(3)Section 14ASection 260ASection 36(1)(viii)Section 43B

…offered by the Assessee, the AO made an addition of ₹133.16 crores. 10. The learned CIT(A) allowed the Assessee’s appeal, relying on the decision of this court in Maxopp Investments Ltd. v. Commissioner of Income Tax and Other Connected Appeals: (2012) 347 ITR 272. The learned ITAT confirmed the learned CIT(A)’s finding, relying upon decision of the Supreme Court in Maxopp Investment Limited v. CIT, New Delhi: (2018) 402 ITR 640 (SC) as well as PCIT v. State Bank of Patiala: (2017) 78 taxmann.com 3 (SC). The relevant extract of the said order is set out below: “8. We have carefully perused the decis…

Dbs Bank Ltd (Dbs Bank Ltd., India Branches Now Converted Into Dbs Bank India Ltd), Mumbai vs. DCIT (Int Txt)-2(1)(2), Mumbai

In the result, appeal of the assessee in ITA No

ITA 3691/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Nov 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sunil Kumar Singh, Hon’Ble

For Appellant: Shri P.J. Pardiwala/Shri Madhur Agarwal, A/RsFor Respondent: Shri Vivek Permpurna, CIT, D/R

Section 143(3)Section 14ASection 28Section 36Section 36(1)(vii)Section 36(1)(viia)Section 36(2)Section 37(1)Section 44C

…by the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT, 2011 SCC OnLine Del 4855 : (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of I.T.A. No. 3691/Mum/2023 I.T.A. No. 4722/Mum/2023 16 investing…

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 724/MUM/2016[2007-08]Status: DisposedITAT Mumbai30 Oct 2024AY 2007-08

Bench: Smt Beena Pillai & Smt Renu Jauhri[Assessment Year: 2009-10] [Assessment Year: 2008-09] [Assessment Year: 2007-08] Dy. Commissioner Of M/S. Antony Motors Pvt. Income-Tax- 15(1)(1) Ltd. Room No.517, A-390/391, 5Th Floor, Midc, Ttc, Vs. Aayakar Bhavan, Industrial Zone, Maharshi Karve Road, Navi Mumbai- 400701. Mumbai- 400020. Pan: Aaaca4719K (Appellant) (Respondent)

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “B”, MUMBAI BEFORE SMT BEENA PILLAI, JUDICIAL MEMBER AND SMT RENU JAUHRI, ACCOUNTANT MEMBER [Assessment Year: 2009-10] [Assessment Year: 2008-09] [Assessment Year: 2007-08] Dy. Commissioner of M/s. Antony Motors Pvt. Income-Tax- 15(1)(1) Ltd. Room No.517, A-390/391, 5th Floor, MIDC, TTC, Vs. Aayakar Bhavan, Industrial Zone, Maharshi Karve Road, Navi Mumbai- 400701. Mumbai- 400020. PAN: AAACA4719K (Appellant) (Respondent) C. O. No. 150/M/2017 (Arises out of the ITA No.724/M/2016) [Assessment Year: 2007-08] C. O. No. 151/M/2017 (Arises out of the ITA No.723/Mum/20…

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 723/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Oct 2024AY 2008-09

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

DCIT 15(1)(1), Mumbai vs. Antony Motors P.Ltd, Navi Mumbai

In the result the appeals filed by the assessee & revenue stands partly allowed

ITA 722/MUM/2016[2009-10]Status: DisposedITAT Mumbai30 Oct 2024AY 2009-10

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Paresh Deshpande – Sr. A.R

Section 133(6)Section 143(3)Section 145(3)Section 148

Infina Finance Private Limited, Mumbai vs. ACIT Circle 2(2)(1), Mumbai

ITA 416/MUM/2024[2016-2017]Status: DisposedITAT Mumbai16 Oct 2024AY 2016-2017

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Honbleι.Τ.Α. No. 413/Mum/2024

For Appellant: Shri Madhur Agarwal, A/RFor Respondent: Shri Krishna Kumar, Sr. D/R

Section 14A

…d by the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT, 2011 SCC OnLine Del 4855: (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of investing into those shares, the assessee knows that it may gen…

Infina Finance Private Limited, Mumbai vs. ACIT Circle 2(2)(1), Mumbai

ITA 415/MUM/2024[2017-2018]Status: DisposedITAT Mumbai16 Oct 2024AY 2017-2018

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Honbleι.Τ.Α. No. 413/Mum/2024

For Appellant: Shri Madhur Agarwal, A/RFor Respondent: Shri Krishna Kumar, Sr. D/R

Section 14A

Infina Finance Private Limited, Mumbai vs. ACIT Circle 2(2)(1), Mumbai

In the result, the captioned appeals are allowed for statistical purposes

ITA 414/MUM/2024[2018-2019]Status: DisposedITAT Mumbai16 Oct 2024AY 2018-2019

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

For Appellant: Shri Madhur Agarwal, A/RFor Respondent: Shri Krishna Kumar, Sr. D/R

Section 14A

…by the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT, 2011 SCC OnLine Del 4855 : (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of investing into those shares, the assessee knows that it may gen…

Infina Finance Private Limited, Mumbai vs. Neac, Delhi

In the result, the captioned appeals are allowed for statistical purposes

ITA 413/MUM/2024[2020-2021]Status: DisposedITAT Mumbai16 Oct 2024AY 2020-2021

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

For Appellant: Shri Madhur Agarwal, A/RFor Respondent: Shri Krishna Kumar, Sr. D/R

Section 14A

…by the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT, 2011 SCC OnLine Del 4855 : (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of investing into those shares, the assessee knows that it may gen…

Angelic Construction Private Limited, New Delhi vs. ACIT, Central Circle-8

In the result, the appeal of the assessee is dismissed

ITA 2424/DEL/2022[2011-12]Status: DisposedITAT Delhi16 Oct 2024AY 2011-12

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2011-12 Angelic Construction Private Vs Acit Central Circle -8 Limited New Delhi, H.No. 119 New Delhi G/F Gali No -1Kh No Khajuri Khas Near Shiv Mandir New Delhi-110094 Pan No. Aaacc1080F (Appellant) (Respondent) Appellants By None Present Respondent By Sh. Amit Katoch, Sr. Dr. Date Of Hearing: 11/09/2024 Date Of Pronouncement: 16/10/2024 Order Per Sudhir Kumar, Jm:

Section 142(1)Section 143(3)Section 14A

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2011-12 Angelic Construction Private Vs ACIT Central Circle -8 Limited New Delhi, H.No. 119 New Delhi G/F Gali no -1KH No Khajuri khas near Shiv Mandir New Delhi-110094 PAN No. AAACC1080F (APPELLANT) (RESPONDENT) Appellants by None present Respondent by Sh. Amit Katoch, Sr. DR. Date of hearing: 11/09/2024 Date of Pronouncement: 16/10/2024 ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order of Commissioner of…

DCIT 2(2), Mumbai vs. State Bank of India, Mumbai

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

ITA 4952/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

Section 14Section 143Section 36Section 41

…d by the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT 2011 SCC OnLine Del 4855 : (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of investing into those shares, the assessee knows that it may gen…

State Bank of India, Mumbai vs. Addl CIT Cir 2(2), Mumbai

In the result appeal filed by the assessee for assessment

ITA 3868/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

Section 14Section 143Section 36Section 41

…the assessee, though the assessee has to ultimately trade those shares by selling them to earn profits. The situation here is, therefore, different from the case like Maxopp Investment Ltd. [Maxopp Investment Ltd. v. CIT 2011 SCC OnLine Del 4855 : (2012) 347 ITR 272] where the assessee would continue to hold those shares as it wants to retain control over the investee company. In that case, whenever dividend is declared by the investee company that would necessarily be earned by the assessee and the assessee alone. Therefore, even at the time of investing into those shares, the assessee knows that it ma…

Safal Properties Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(2), Kolkata

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

ITA 1334/KOL/2024[2016-2017]Status: DisposedITAT Kolkata23 Sept 2024AY 2016-2017

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2016-17

For Appellant: Saurabh Bagaria, ARFor Respondent: P.P Barman, Addl. CIT, Sr. DR

Section 115JSection 143(3)Section 14ASection 250Section 263Section 40Section 57

…the current year and the investment made was out of current accruals of the company. The assessee has relied upon the judgement of Hon'ble Bomaby High Court in CIT vs. Delite Enterprises (Tax Appeal No.110 of 2009 order dated 26 Feb. 2009), Hero Cycles Ltd. (320 ITR 518), M/s. Lakhani Marketing Incl (ITA No.970 of 2008) dated 2/4/2014 and CIT Vs. Winsome Textile Industries Ltd. (319 ITR 204) of the Hon'ble Punjab & Haryana High Court wherein it is held that where there is no claim for exemption of income, in such situation section 14A of the Act has no application. In the present assessment also, since the Asses…

DCIT, New Delhi vs. M/S. Net 4 India Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed, in the terms indicated herein above

ITA 3657/DEL/2017[2010-11]Status: DisposedITAT Delhi09 Sept 2024AY 2010-11

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2010-11] Dcit, Vs M/S. Net 4 India Ltd., Circle-18(1), Ab-11, Community Centre, New Delhi. Safdarjung Enclave, New Delhi-110029. Pan-Aaact0291M Appellant Respondent Appellant By Shri Subhra Jyoti Chakraborty, Cit Dr Respondent By None Date Of Hearing 29.08.2024 Date Of Pronouncement 09.09.2024 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By Ld.Cit(A)-42, New Delhi Dated 17.03.2017 For The Assessment Year 2010-11. 2. The Revenue Has Raised Following Grounds Of Appeal:-

Section 14Section 145(3)

…ied in not upholding the disallowance u/s 14 A of the Act r.w. R SD of the Rule of Rs. 79,41,003/- without considering ratio decidendi as upheld in cases of CIT Vs Walfort Share and Stock Brokers P Ltd [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT [2012] 347 ITR 272 (Delhi) on application of provisions of section 14 A of the Act? 9. That the appellant craves leave to add, amend, alter or forgo any ground/(s) of appeal either before or at the time of hearing of the appeal.” 3. At the time of hearing, no one attended the proceedings on behalf of the assessee. It is seen from the records that no one has been at…

DCIT, New Delhi vs. M/S. M2K Entertainment Pvt. Ltd., New Delhi

In the result, Revenue’s appeal is partly allowed

ITA 6725/DEL/2016[2012-13]Status: DisposedITAT Delhi14 Aug 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singhasstt. Yr: 2012-13

Section 143(3)Section 14ASection 2(24)(x)Section 24Section 36(1)(va)Section 43B

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E”: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER Asstt. Yr: 2012-13 DCIT, Circle-16(1), Vs M2K Entertainment Pvt. Ltd., E-34, 2nd Floor, Connaught Circus, New Delhi. New Delhi-110001. PAN: AADCM 0608 C APPELLANT RESPONDENT Assessee represented by Shri Vartik Choksi, AR Department represented by Shri Amit Shukla, Sr. DR Date of hearing 08.08.2024 14.08.2024 Date of pronouncement O R D E R PER KUL BHARAT, JM: This appeal, by the Revenue, is directed against the order of the learned Commissioner of Income-tax…