Maxopp Investment Ltd. v. CIT

402 ITR 640Supreme Court of India2018#21 most cited

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

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

1,596

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2016 to 2026.

Also referred to as

Maxopp Investment Ltd v CIT · Maxopp SC 2018 · Section 14A disallowance · Rule 8D application · expenditure for exempt income · only dividend bearing investments · satisfaction Section 14A(2) · strategic investment disallowance · disallowance not automatic · 402 ITR 640

Also reported as

91 Taxmann.com 154254 Taxmann 325301 CTR 489

Sections most often in play

Section 14A Section 143(3)Section 115JB Section 8D Section 37(1)Section 1961 Section 250 Section 143(2)

Read the full judgment

Issues it is cited on

section 14a(1)section 14a(2)strategic investment disallowance under section 14a disallowance u/s 14a section 10(34)section 14a section 36(1)(vii)section 40a(2)enduring benefit book profits section 115j

Judgments citing Maxopp Investment Ltd. v. CIT

Asst. Commissioner of Income-Tax 6(1)(2), 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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Taxman 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Asst. Commissioner of Income-Tax 6(1)(2), Mumbai vs. Incred Holdings Limited (Formerly Known As Kkr Capital Markets India Limited)., Mumbai

ITA 4365/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Oct 2024AY 2015-16

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Asst. Commissioner of Income-Tax 6(1)(2), Mumbai vs. Incred Holdings Limited (Formerly Known As Kkr Capital Markets India Limited)., Mumbai

ITA 4364/MUM/2024[2014-15]Status: DisposedITAT Mumbai17 Oct 2024AY 2014-15

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Taxman 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(1), Mumbai

ITA 4254/MUM/2024[AY 2018-19]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(1), Mumbai

ITA 4252/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4250/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4249/MUM/2024[AY 2015-16]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4248/MUM/2024[AY 2014-15]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Тахтап 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

In the result, appeals filed by the assessee in I

ITA 4246/MUM/2024[AY 2013-14]Status: DisposedITAT Mumbai17 Oct 2024

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

…2015] 55 taxmann.com 262/230 Taxman 63 and the Madras High Court in CIT v. Chettinad Logistics (P.) Ltd. [2017] 248 Taxman 55/80 taxmann.com 221. 5. Counsel for the Revenue referring to the decision of the Supreme Court in Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 and an earlier judgment of the Supreme Court in CIT v. Walfort Share & Stock Brokers (P.) Ltd. [2010] 326 ITR 1/192 Taxman 211 submits the ratio and view expressed in Cheminvest Ltd. (Supra) and Holcim India (P.) Ltd. (Supra) has been overruled and atleast requires reconsideration. 6. We have considered the said…

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

…ssee, the fact is that certain shares are held as stock-in-trade. Whether disallowance u/s 14A of the Act can be made in the case of shares held as stock-in-trade was considered by the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT [2018] 402 ITR 640 (SC). The relevant findings read as under:- “36) There is yet another aspect which still needs to be looked into. What happens when the shares are held as ‘stock-in-trade' and not as ‘investment', particularly, by the banks? On this specific aspect, CBDT has issued circular No. 18/2015 dated November 02, 2015. 37) This Circular has already been r…

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

…ssee, the fact is that certain shares are held as stock-in-trade. Whether disallowance u/s 14A of the Act can be made in the case of shares held as stock-in-trade was considered by the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT [2018] 402 ITR 640 (SC). The relevant findings read as under:- “36) There is yet another aspect which still needs to be looked into. What happens when the shares are held as ‘stock-in-trade' and not as ‘investment', particularly, by the banks? On this specific aspect, CBDT has issued circular No. 18/2015 dated November 02, 2015. 37) This Circular has already been r…

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

…ssee, the fact is that certain shares are held as stock-in-trade. Whether disallowance u/s 14A of the Act can be made in the case of shares held as stock-in-trade was considered by the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT [2018] 402 ITR 640 (SC). The relevant findings read as under:- “36) There is yet another aspect which still needs to be looked into. What happens when the shares are held as ‘stock-in-trade’ and not as ‘investment’, particularly, by the banks? On this specific aspect, CBDT has issued circular No. 18/2015 dated November 02, 2015. 37) This Circular has already been r…

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

…ssee, the fact is that certain shares are held as stock-in-trade. Whether disallowance u/s 14A of the Act can be made in the case of shares held as stock-in-trade was considered by the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT [2018] 402 ITR 640 (SC). The relevant findings read as under:- “36) There is yet another aspect which still needs to be looked into. What happens when the shares are held as ‘stock-in-trade’ and not as ‘investment’, particularly, by the banks? On this specific aspect, CBDT has issued circular No. 18/2015 dated November 02, 2015. 37) This Circular has already been r…

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

ITA 4105/MUM/2014[2007-08]Status: DisposedITAT Mumbai11 Oct 2024AY 2007-08

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

Section 14Section 143Section 36Section 41

…used to earn exempt income, it is duty of the assessee to prove with documentary evidence that the cost bearing funds were not used to earn exempt income. It is well established principle laid down by Hon. Supreme Court in case of Maxop Investment Ltd Vs CIT (402 ITR 640) that where the mixed funds are used and the assessee cannot established with documentary evidence that cost free funds were used to earn exempt income, in such situation proportionate disallowance of the expenditure incurred by the assessee for exempted income shall be made. The Hon’ble Supreme Court also held that the purpose for which the inve…

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

…used to earn exempt income, it is duty of the assessee to prove with documentary evidence that the cost bearing funds were not used to earn exempt income. It is well established principle laid down by Hon. Supreme Court in case of Maxop Investment Ltd Vs CIT (402 ITR 640) that where the mixed funds are used and the assessee cannot established with documentary evidence that cost free funds were used to earn exempt income, in such situation proportionate disallowance of the expenditure incurred by the assessee for exempted income shall be made. The Hon’ble Supreme Court also held that the purpose for which the inve…

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

…o earn exempt income, it is duty of the assessee to prove with documentary evidence that the cost bearing funds were not used to earn exempt income. It is well established principle laid down by Hon. Supreme Court in case of Maxop Investment Ltd Vs CIT (402 ITR 640) that where the mixed funds are used and the assessee cannot established with documentary evidence that cost free funds were used to earn exempt income, in such situation proportionate disallowance of the expenditure incurred by the assessee for exempted income shall be made. The Hon’ble Supreme Court also held that the purpose for which…

Mega Engineers & Builders, Port Blair vs. DCIT, Cir. 3(2), Port Blair

In the result, the appeal of assessee is allowed

ITA 312/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Oct 2024AY 2017-18

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

…ls) deleting the similar disallowance made by the Assessing Officer under section 14A read with Rule 8D. At the time of hearing before us, the ld. D.R. has relied on the decision of the Hon’ble Supreme Court in the case of Maxopp Investment Limited –vs.- CIT [402 ITR 640] to contend that the relevant shares having been held by the assessee as stock-in-trade, disallowance under section 14A is liable to be made as rightly held by the Assessing Officer. It is, however, observed that this aspect has already been considered by the Tribunal while deciding a similar issue in favour of the assessee for A.Y. 2012-13, as i…

Reliance Brands Limited, Mumbai vs. PCIT-8, Mumbai

ITA 2423/MUM/2024[2018-19]Status: DisposedITAT Mumbai09 Oct 2024AY 2018-19

Bench: MS. PADMAVATHY S, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Nimesh VoraFor Respondent: Shri Nayanjyoti Nath

Section 143(3)Section 144BSection 14ASection 263Section 263(1)

…-Company had not 4 A.Y.2018-19 received or earned any income and therefore, no disallowance under Section 14A of the Act was warranted. Reliance was placed on the judgment of Hon’ble Supreme Court in the case of CIT Vs. Vs. Maxopp Investment Private Limited [402 ITR 640 SC] to contend that disallowance under Section 14A of the Act shall be restricted to the exempt income earned by the Assessee. Reliance was also placed on the Judgment of Hon’ble Supreme Court in the case of GVK Project and Technical Services Ltd. Vs. PCIT [2019] 106 taxmann.com 181 and the Judgment of Hon’ble Delhi High Court in PCIT Vs. McDonal…

DCIT, Central Circle- 1(3), Ahmedabad vs. M/S Lok Prakashan Ltd., Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 480/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 143(3)Section 14ASection 250

…आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “डी“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ D ” BENCH, AHMEDABAD "ी टी.आर. से""ल कुमार, "ाियक सद" एवं "ी मकरंद वसंत महादेवकर, लेखा सद" के सम#। ] ] BEFORE SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं /ITA Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 respectively Lok Prakashan Limited The ACIT बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) v/s. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./PAN: AAACL 2742 F…

DCIT, Central Circle - 1(3), Ahmedabad vs. M/S Lok Prakashan Ltd., Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 479/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR

Section 143(3)Section 14ASection 250

…आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “डी“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ D ” BENCH, AHMEDABAD "ी टी.आर. से""ल कुमार, "ाियक सद" एवं "ी मकरंद वसंत महादेवकर, लेखा सद" के सम#। ] ] BEFORE SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं /ITA Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 respectively Lok Prakashan Limited The ACIT बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) v/s. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./PAN: AAACL 2742 F…