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

21 judgments on BharatTax cite Maxopp Investment Ltd. v. CIT (15 SCC 523), spanning 2020 to 2025.

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 10(34), Section 115JB, Section 8D, Section 36(1)(viia), Section 28.

Maxopp Investment Ltd. v. CIT

15 SCC 523Reported decision2018#5511 most cited

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

Expenditure incurred in relation to exempt income earned from investments held as stock-in-trade is not includible in the disallowance under Section 14A. If expenditure has no causal connection with exempt income, it is allowed as business expenditure.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2025.

Also referred to as

Maxopp Investment Ltd. v. CIT · section 14A · disallowance · exempt income · stock-in-trade · expenditure · business expenditure · rule 8D

Sections most often in play

Section 14A Section 10(34)Section 115JB Section 8D Section 36(1)(viia)Section 28 Section 36(1)(iii)Section 36(1)(vii)

Issues it is cited on

section 14a disallowance interest on securities section 36(1)(viia)section 91 section 115jb(2)section 80p(2)(a)disallowance under section 14a disallowance u/s 14a section 80p(2)section 80p(2)(a)(i)book profits section 251

Judgments citing Maxopp Investment Ltd. v. CIT

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, appeal of the revenue is dismissed

ITA 1549/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-2014

Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri P. J. Pardiwala, Sr. Advocate and Shri C. Naresh, CAFor Respondent: Shri Satya Pal Kumar, CIT DR

Section 10Section 115JSection 143(3)Section 14ASection 90

…ct that the exempt income was earned by the assessee from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640/2018) 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court Pr. CIT v. State Bank of Patiala [2017] 78 taxmann.com 3/245 Taxman 273/391 ITR 218 and the facts of the said case are para materia to the case in hand. In the case of State Bank of Patiala,…

BANK OF INDIA,MUMBAI vs. THE ACIT-2(1)(1), MUMBAI

ITA 1397/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawal

Section 10Section 115JSection 143(3)Section 14ASection 90

…ct that the exempt income was earned by the assessee from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 91 taxmапп.сот 154/254 Тахтап 325/402 ITR 640/2018) 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court Pr. CIT v. State Bank of Patiala [2017] 78 taxmann.com 3/245 Тахтап 273/391 ITR 218 and the facts of the said case are para materia to the case in hand. In the case of State Bank of Patiala,…

MIRAE ASSET CAPITAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER, WARD 4(3)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed

ITA 2099/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Nov 2025AY 2020-21

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Pratik Poddar, & Shreyas SardesaiFor Respondent: 14.10.2025

Section 143(1)Section 143(1)(a)Section 14ASection 234CSection 250

…fact then the exempt income was earned try the assesses from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Lid v. CIT [2018] 91 taxmann com 154/254 Tam 325-482 ITR 640/2018) 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court P. CIT. Stan Bank of Patiala [2017] 78 taxmann.com 3/245 Taxman 273/391 ITR 218 and the facts of the said case are para materia to the cast in hand. In the case of State Bank of Patiala, (sup…

G R N FINSEC PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal filed by the assessee in ITA No

ITA 5341/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Aug 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of the Delhi High Court. Finally adjudicating the issue…

G R N FINSEC PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CIRCLE 1(1)(2), MUMBAI

In the result, the appeal filed by the assessee in ITA No

ITA 5329/MUM/2024[2015-16]Status: DisposedITAT Mumbai26 Aug 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary

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

DAI-ICHI KARKARIA LIMITED,MUMBAI vs. DCIT, CIRCLE-1(1)(1), MUMBAI

In the result, ground no. 4 of the assessee is allowed

ITA 1588/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jun 2025AY 2017-18

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 115JSection 14ASection 254(1)Section 270A

…t cost etc. Contention of assessee that no direct or indirect cost was incurred in relation to earning tax 2 Dai-Ichi Karkaria Limited free dividend income cannot be excepted. The AO by referring the decision of Hon’ble Apex Court in Maxopp Investments (2018) 15 SCC 523/ AIRONLINE 2018 SC 1470 has noted whether dividend income has earned or not is immaterial. The AO disallowed 1.00 % of average value of investment. The total annual average was worked out by AO at Rs. 25.86 Cr. Thereby the AO worked out disallowance of Rs. 25,86,319/-. Since, the assessee already made disallowance of Rs. 20,56,871/-, thereby AO ma…

DCIT (IT)-2(1)(2), AIR BUILDING, NARIMAN POINT, MUMBAI vs. DBS BANK LIMITED, MUMBAI

ITA 4722/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Nov 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Bleι.Τ.Α. No. 3691/Mum/2023

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income." Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

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

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only when the business…

IL & FS FINANCIAL SERVICES LIMITED,MUMBAI vs. DCIT-CIRCLE-14(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3421/MUM/2023[2012-13]Status: DisposedITAT Mumbai26 Feb 2024AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI AMARJIT SINGH (Accountant Member)

Section 143(3)Section 14A

…was earned by the assessee from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com T [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640/[2018] 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court Pr CIT v. State Bank of Patiala [20171 78 taxmann.com 3/245 Taxman 273/391 ITR 218 and the facts of the said case are para materia to the case in hand. In the case of State Bank of Patiala, (…

DCIT, NEW DELHI vs. M/S. ALPHA G. CORP. DEVELOPMENT LTD., NEW DELHI

In the result, the appeal of the Revenue being devoid of merit is dismissed

ITA 6049/DEL/2015[2008-09]Status: DisposedITAT Delhi21 Dec 2023AY 2008-09

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2008-09

For Appellant: Mr. Debesh Panda, AdvocateFor Respondent: S/Shri Sanjay Kumar &

Section 143(3)Section 147Section 148Section 14A

…AO was not in accordance with the settled position of law. He pointed out that the decision of Hon’ble Delhi High Court in Maxopp Investment Ltd. vs. CIT 347 ITR 272 (Del) has been affirmed by the Hon’ble Supreme Court in Maxopp Investment Ltd. vs. CIT (2018) 15 SCC 523 wherein it is held that the expression “expenditure incurred” in section 14A means “actual expenditure and not to some imagined expenditure”. Therefore, if no expenditure is incurred in relation to the exempt income, no disallowance can be made. This squarely applies to 6 the assessee’s case. The Hon’ble Supreme Court further added that if an expe…

BANK OF INDIA,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX-2(1)(1), MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 929/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Jun 2023AY 2012-13

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.929/मुं/ 2023 ("न.व.2012-13) Bank Of India, 8Th Floor, Taxation Department, Star House, C-5, G.Block, Badra –Kurla Complex, Bandra (East), Mumbai 400 051 Pan: Aaacb-0472-C ...... अपीलाथ" /Appellant बनाम Vs. The Asstt. Commissioner Of Income Tax 2(1)(1),Mumbai. Mumbai. ..... ""तवाद"/Respondent आअसं.973/मुं/ 2023 ("न.व.2012-13) The Asstt. Commissioner Of Income Tax 2(1)(1),Mumbai. Mumbai. ...... अपीलाथ" /Appellant बनाम Vs. Bank Of India, 8Th Floor, Taxation Department, Star House, C-5, G.Block, Badra –Kurla Complex, Bandra (East), Mumbai 400 051 Pan: Aaacb-0472-C ..... ""तवाद"/Respondent Assessee By : Shri C. Naresh Revenue By : Shri H.N.Singh, Cit-Dr सुनवाई क" "त"थ/ Date Of Hearing : 27/06/2023 घोषणा क" "त"थ/ Date Of Pronouncement : 28/06/2023

For Appellant: Shri C. NareshFor Respondent: Shri H.N.Singh, CIT-DR

Section 10Section 14ASection 90

…t that the exempt income was earned by the assessee from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640/[2018] 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court Pr. CIT v. State Bank of Patiala [2017] 78 taxmann.com 3/245 Taxman 273/391 ITR 218 and the facts of the said case are para materia to the case in hand. In the case of State Bank of Patiala,…

PR. COMMISSIONER OF INCOME TAX vs. MS. PNB HOUSING FINANCE LTD

In the result, the appeals filed by the

ITA/308/2022HC Delhi07 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

Section 14ASection 36(1)(viii)

…issue is no longer res integra.It is an admitted fact that the exempt income was earned by the assessee from the investment held by it as stock-in-trade. This issue has been conclusively determined by the Supreme Court in Maxopp Investment Ltd. v. CIT, [2018] 15 SCC 523. In this matter, the Supreme Court was concerned with a batch of appeals which also included a challenge to the judgment of the Punjab and Haryana High Court reported in CIT v. State Bank of Patiala [2017] 391 ITR 218 (P&H)and the facts of the said case are para materia to the case in hand. In the case of State Bank of Patiala, the AO restricted t…

THE SHRI BAJRANG ALLOYS LTD.,RAIPUR (CG) vs. THE DY. COMMISSIONER OF INCOME TAX 1(2), RAIPUR (CG)

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 174/BIL/2016[2012-13]Status: DisposedITAT Raipur21 Feb 2022AY 2012-13

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 174/Rpr/2016 "नधा"रण वष" / Assessment Year : 2012-13 Shri Bajrang Alloys Limited 521/Cit(A), Industrial Area, Urla, Raipur (C.G) Pan : Aaecs9218D .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri Amit M Jain, A.RFor Respondent: Shri G.N Singh, D.R

Section 143(2)Section 143(3)Section 14A

…आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR (Through Virtual Court at Pune) BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI JAMLAPPA D BATTULL, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No. 174/RPR/2016 "नधा"रण वष" / Assessment Year : 2012-13 Shri Bajrang Alloys Limited 521/CIT(A), Industrial Area, Urla, Raipur (C.G) PAN : AAECS9218D .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax 1(2), Raipur. ……""यथ" / Respondent Assessee by : Shri Amit M Jain, A.R Revenue by : Shri G.N Singh, D.R सुनवाई क" तार"ख / Date of Hearing : 03.02.2022 घोष…

KOTHARI PRODUCTS LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX, KANPUR

In the result, both the appeals of the assessee stand allowed for statistical purposes

ITA 255/LKW/2015[2009-10]Status: DisposedITAT Lucknow20 Oct 2021AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2009-10 &

Section 14ASection 14A(2)Section 4A

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 Page 15 of 22 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only whe…

KOTHARI PRODUCTS LTD.,KANPUR vs. ASSTT. COMMISSIONER OF INCOME TAX, KANPUR

In the result, both the appeals of the assessee stand allowed for statistical purposes

ITA 928/LKW/2014[2010-11]Status: DisposedITAT Lucknow20 Oct 2021AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2009-10 &

Section 14ASection 14A(2)Section 4A

…has no causal connection with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 Page 15 of 22 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of expenditure only whe…

THE SOUTH INDIAN BANK LTD. vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-009606-009606 - 2011Supreme Court09 Sept 2021

Bench: HON'BLE MR. JUSTICE HRISHIKESH ROY

Section 14Section 14A

…n with the exempted income, then such an expenditure would obviously be treated as not related to the income that is exempted from tax, and such expenditure would be allowed as business expenditure. To put it differently, such 10 (2018) 15 SCC 523 Page 15 of 22 expenditure would then be considered as incurred in respect of other income which is to be treated as part of the total income.” Adverting to the law as it stood earlier, this Court rejected the theory of dominant purpose suggested by the Punjab & Haryana High Court and accepted the principle of apportionment of…

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