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 366,470 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 14ASection 143(3)Section 115JBSection 8DSection 37(1)Section 1961Section 250Section 143(2)
Read the full judgment

Issues it is cited on

section 14a(1)section 14a(2)strategic investmentdisallowance under section 14adisallowance u/s 14asection 10(34)section 14asection 36(1)(vii)section 40a(2)enduring benefitbook profitssection 115j

Judgments citing Maxopp Investment Ltd. v. CIT

Matrix Clothing Private Limited, Gurgaon vs. ACIT-CC-18, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 3805/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

…mputed the disallowance of Rs. 6,15,435/- by adopting 1% of average value of investments thereon. This action of the ld AO was upheld by the ld CIT(A). The law is now very well settled by the Hon’ble Supreme Court in the case of Maxopp Investments reported in 402 ITR 640 (SC) that only dividend bearing investments are to be considered for the purpose of making disallowance u/s 14A of the Act. Hence, we direct the ld AO to consider only 1% of average value of dividend bearing investments and make disallowance u/s 14A accordingly. Ground Nos. 11 to 14 are partly allowed. 34. In the result, the appeal of the assess…

Matrix Clothing Private Limited, Gurgaon vs. ACIT, Central Circle-18, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 760/DEL/2022[2017-18]Status: DisposedITAT Delhi01 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

…mputed the disallowance of Rs. 6,15,435/- by adopting 1% of average value of investments thereon. This action of the ld AO was upheld by the ld CIT(A). The law is now very well settled by the Hon’ble Supreme Court in the case of Maxopp Investments reported in 402 ITR 640 (SC) that only dividend bearing investments are to be considered for the purpose of making disallowance u/s 14A of the Act. Hence, we direct the ld AO to consider only 1% of average value of dividend bearing investments and make disallowance u/s 14A accordingly. Ground Nos. 11 to 14 are partly allowed. 34. In the result, the appeal of the assess…

JCIT, OSD, Delhi vs. Ace Insurance Brokers Pvt Ltd, Delhi

The appeal is dismissed

ITA 3063/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year : 2020-21 Jcit, Osd, Vs. Ace Insurance Brokers Pvt. Ltd., Delhi. B-17, Ashadeep Building, 9 Hailey Road, New Delhi. Pan: Aadca9488L Assessee By : Shri D.C. Agrawal, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 17.11.2025 Date Of Pronouncement : 28.11.2025

For Appellant: Shri D.C. Agrawal, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 14ASection 14A(2)Section 195Section 3Section 40Section 9

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : C : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER Assessment Year : 2020-21 JCIT, OSD, Vs. Ace Insurance Brokers Pvt. Ltd., Delhi. B-17, Ashadeep Building, 9 Hailey Road, New Delhi. PAN: AADCA9488L Assessee by : Shri D.C. Agrawal, Advocate Revenue by : Shri Om Prakash, Sr. DR Date of Hearing : 17.11.2025 Date of Pronouncement : 28.11.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Revenue against the order dated 14.03.2025 of the Ld. Commissioner of Income-tax (Appeals), NFAC, Delhi (herein…

Asia Investments Pvt.. Ltd., Mumbai vs. DCIT, Circle 2 (1)(1), Mumbai

In the result, all the three appeal

ITA 6209/MUM/2019[2014-15]Status: DisposedITAT Mumbai27 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Mr. Kalpesh Unadkat &
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) ITA No. 4529, 6353/MUM/2017, 6209/MUM/2019 Assessment Year: 2012-13, 2013-14, 2014-15 Asia Investments Pvt. Ltd., Asst. CIT Circle 2(1)(1), 10, Prasad Chambers, Opera Dy. CIT Circle 2(1)(1), Vs. House, Aayakar Bhavan, M.K. Road, Mumbai-400004. Mumbai-400020. PAN NO. AAACA 4539 K Appellant Respondent : Mr. Kalpesh Unadkat & Assessee by Mr. Hasmukh Ravaria : Mr. Rajesh Kumar Yadav, CIT-DR Revenue by Date of Hearing : 29/09/2025 : 27/11/2025 Date of pronounceme…

Asia Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, all the three appeals are allowed partly

ITA 6353/MUM/2017[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Kalpesh Unadkat &For Respondent: Mr. Rajesh Kumar Yadav, CIT-DR
Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) ITA No. 4529, 6353/MUM/2017, 6209/MUM/2019 Assessment Year: 2012-13, 2013-14, 2014-15 Asia Investments Pvt. Ltd., 10, Prasad Chambers, Opera House, Mumbai-400004. PAN NO. AAACA 4539 K Appellant Vs. Asst. CIT Circle 2(1)(1), Dy. CIT Circle 2(1)(1), Aayakar Bhavan, M.K. Road, Mumbai-400020. Respondent Assessee by : Mr. Kalpesh Unadkat & Mr. Hasmukh Ravaria Revenue by : Mr. Rajesh Kumar Yadav, CIT-DR Date of Hearing : 29/09/2025 Date of pronouncement : 27/11/2…

Asia Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, all the three appeals are allowed partly

ITA 4529/MUM/2017[2012-13]Status: DisposedITAT Mumbai27 Nov 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Kalpesh Unadkat &For Respondent: Mr. Rajesh Kumar Yadav, CIT-DR
Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) ITA No. 4529, 6353/MUM/2017, 6209/MUM/2019 Assessment Year: 2012-13, 2013-14, 2014-15 Asia Investments Pvt. Ltd., 10, Prasad Chambers, Opera House, Mumbai-400004. PAN No. AAACA 4539 K Appellant Vs. Asst. CIT Circle 2(1)(1), Dy. CIT Circle 2(1)(1), Aayakar Bhavan, M.K. Road, Mumbai-400020. Respondent Assessee by : Mr. Kalpesh Unadkat & Mr. Hasmukh Ravaria Revenue by : Mr. Rajesh Kumar Yadav, CIT-DR Date of Hearing : 29/09/2025 Date of pronouncement : 27/11/2025…

DCIT, Circle -3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 314/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2014-15

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

…eafter been dismissed in Pr. CIT Vs, Caraf Builders & Constructions (P) Ltd. (2019) 112 taxmann.com 322 (SC). Also, the aforesaid view is supported by the judgment of the Hon’ble Supreme Court in Maxopp Investments Ltd. Vs. CIT (2018) Private Limited vs. DCIT 402 ITR 640 (SC). Further, a similar view has been taken by the Hon’ble High Court of Madras in the case of Pr. CIT Vs. Envestor Ventures Ltd. (2021 123 taxmann.com 378 (Madras) and CIT Vs. Tidel Park Limited, Tax Case No. 732 & 733 of 2018, dated 07.07.2020. Also, we find that the Hon’ble High Court of Karnataka in the case of Pragathi Krishna Gramin Bank V…

DCIT, Circle - 3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 206/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

…eafter been dismissed in Pr. CIT Vs, Caraf Builders & Constructions (P) Ltd. (2019) 112 taxmann.com 322 (SC). Also, the aforesaid view is supported by the judgment of the Hon’ble Supreme Court in Maxopp Investments Ltd. Vs. CIT (2018) Private Limited vs. DCIT 402 ITR 640 (SC). Further, a similar view has been taken by the Hon’ble High Court of Madras in the case of Pr. CIT Vs. Envestor Ventures Ltd. (2021 123 taxmann.com 378 (Madras) and CIT Vs. Tidel Park Limited, Tax Case No. 732 & 733 of 2018, dated 07.07.2020. Also, we find that the Hon’ble High Court of Karnataka in the case of Pragathi Krishna Gramin Bank V…

Dodla Dairy Limited, Hyderabad vs. DCIT Circle -8(1), Hyderabad

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144Section 80Section 801BSection 80J

…d by the revenue has thereafter been dismissed in Pr. CIT Vs, Caraf Builders & Constructions (P) Ltd. (2019) 112 taxmann.com 322 (SC). Also, the aforesaid view is supported by the judgment of the Hon’ble Supreme Court in Maxopp Investments Ltd. Vs. CIT (2018) 402 ITR 640 (SC). Further, a similar view has been taken by the Hon’ble High Court of Madras in the case of Pr. CIT Vs. 89 ITA TP 466/Hyd/2022 and 1301/Hyd/2024 Dodla Dairy Limited. Envestor Ventures Ltd. (2021 123 taxmann.com 378 (Madras) and CIT Vs. Tidel Park Limited, Tax Case No. 732 & 733 of 2018, dated 07.07.2020. Also, we find that the Hon’ble High…

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…assessee has already disallowed Rs. 11.39 crores so disallowance should be restricted to 5.59 crores. The assessee claim for exclusion of securities held as stock in trade is supported by the judgment of the Apex Court in Maxopp Investment Ltd. vs CIT (2018) 402 ITR 640 (SC) and only those investment which yielded exempt income should be considered for making disallowance as has been held by special bench of Mumbai Tribunal in ACIT vs Vireet Investment P Ltd. (2017) 82 taxmann.com 415. 21. We have considered the rival submissions of both the parties and have gone through the orders of lower authorities carefull…

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…assessee has already disallowed Rs. 11.39 crores so disallowance should be restricted to 5.59 crores. The assessee claim for exclusion of securities held as stock in trade is supported by the judgment of the Apex Court in Maxopp Investment Ltd. vs CIT (2018) 402 ITR 640 (SC) and only those investment which yielded exempt income should be considered for making disallowance as has been held by special bench of Mumbai Tribunal in ACIT vs Vireet Investment P Ltd. (2017) 82 taxmann.com 415. 21. We have considered the rival submissions of both the parties and have gone through the orders of lower authorities carefull…

Capricon Realty Private Limited, Mumbai vs. Income Tax Officer, Central Circle Mumbai

In the result, the appeal of the assessee is allowed

ITA 5696/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Nov 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2018-19

For Appellant: Ms. Neha ParanjpeFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER Assessment Year : 2018-19 Capricon Realty Private Limited, Income Tax Officer, 3rd Floor, Central Circle-1(4), Sir Vithaldas Chambers, vs. Central Building, 16, Mumbai Samachar Marg, Mumbai-400020. Fort, Mumbai-400001. PAN : AAACC4297J (Appellant) (Respondent) For Assessee : Ms. Neha Paranjpe For Revenue : Shri Virabhadra Mahajan, Sr.DR Date of Hearing : 11-11-2025 Date of Pronouncement : 18-11-2025 O R D E R PER VIKRAM SINGH YADAV, A.M : This is an appea…

Nilesh Ishwar Mehta, Mumbai vs. Deputy Commissioner of Income Tax-17(1), Mumbai

In the result, the appeal is of the assessee is partly allowed

ITA 4931/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Nov 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarnilesh Ishwar Mehta V/S. Deputy Commissioner Of 2301/A, 23Rd Floor, बनाम Income Tax-17(1) Parthenon Building, J.P. Room No. 117, Kautilya Road, Mumbai – 400 053, Bhavan, C-41 To C-43, G-Block, Maharashtra Bandra Kurla Complex, Bandra (East), Mumbai 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacpm2417P Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Himanshu Gandhi,ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr.AR)
Section 143(3)Section 14ASection 234BSection 56(2)(vii)

…rplus fund was also negated as the disallowance made P a g e | 3 A.Y. 2014-15 Nilesh Ishwar Mehta, Mumbai pertained to Administrative and General expenses only. Reliance was placed in the case of Hon’ble Supreme Court in Maxopp Investment Ltd. v. CIT (2018) 402 ITR 640 (SC), in which it was held that disallowance under Section 14A is permissible even in cases where the assessee claims that no expenditure was incurred, if the AO records dissatisfaction. 4. Before us, the ld.AR has made the same contentions as ,made before the ld.CIT(A).We find no merit therein as the Rule being mandatory, the addition was justi…

Mirae Asset Capital Markets (India) Private Limited, Mumbai vs. Income Tax Officer, Ward 4(3)(1), 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

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM& MS PADMAVATHY S, AM I.T.A. No. 2099/Mum/2025 (Assessment Year: 2020-21) Mirae Asset Capital Markets Income Tax Officer, Ward 4(3)(1), (India) Private Limited Mumbai 1st Room No. 648, 6th Floor, Aayakar Floor, Tower 4, Equinox business Park, LBS Marg, Off BKC, Vs. Bhavan, Maharshi Karve Road, New Kurla (W), Mumbai 400070 Marine Lines, Churchgate, Mumbai 400020 PAN: AALCM3742K Appellant) : Respondent) Assessee by : Shri Pratik Poddar, & Shreyas Sardesai : Shri. Leyaqat Ali Aafaqui, Sr. AR Revenue by : 14.10.2025 Date of Hearing : 0…

ACIT 16(1), Mumbai vs. Aishwarya Rai Bachchan, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 5403/MUM/2025[2022-23]Status: DisposedITAT Mumbai31 Oct 2025AY 2022-23

Bench: Shri Pawan Singh & Smt.Renu Jauhriacit 16(1) Vs. Aishwarya Rai Bachchan Room No. 439, Aaykar Jalsa B-2 Kapole Chs V L Bhavan, Mk Road, Marine Mehta Road Jvpd Scheme Lines, Juhu, Mumbai-400020. Mumbai-400049. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Adlpr35537P Appellant .. Respondent

For Appellant: Shri Mani JainFor Respondent: Shri Surendra Mohan- Sr. DR
Section 143(3)Section 14ASection 250

…transaction tax of Rs. 1,65,189/-, STT of Rs. 4,95,328/- and indirect expenses of Rs. 4,88,422/- being 5% of the total expenses. As per the settled legal position, in view decision of Hon’ble Apex Court in the case of Maxopp Investments Ltd. Vs. CIT(2018) 402 ITR 640, ld. AO had to record his satisfaction as to why the suo-moto disallowance made by the assessee was not acceptable which has not been done and, therefore, ld. CIT(A) has righty allowed relief to the assessee. 5.2 Further, the assessee had submitted the working as per section 14A r.w.r 8D after considering only those investments from which exe…

ACIT, Mumbai vs. K Raheja Corporate Services Private Limited, Mumbai

In the result, appeal filed by the revenue is hereby dismissed

ITA 5349/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, SR DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, AM AND MS. KAVITHA RAJAGOPAL, JM ITA No. 5349 & 5350/Mum/2025 (Assessment Years: 2014-15 & 2015-16) ACIT, Mumbai K Raheja Corporate Services Pvt. Ltd. Plot No. C, 30 Block G, Bandra Vs. Kurla Complex, Bandra East, Mumbai – 400051. PAN/GIR No. AABCN9309B (Appellant) : (Respondent) Assessee by : Shri Madhur Agrawal Respondent by : Shri Hemanshu Joshi, SR DR Date of Hearing : 27.10.2025 Date of Pronouncement : 31.10.2025 O R D E R Per Kavitha Rajagopal, J M: The captioned appeals have been filed by the revenue, challenging the ord…

Hpl Mercantile Pvt Ltd, Delhi vs. ITO Ward 11(1), Delhi

Appeal is partly allowed

ITA 5759/DEL/2025[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

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

…ing the impugned exempt income; and, therefore, the administrative expenditure amount disallowed herein is not sustainable in law. This tribunal finds no merit in the assessee’s instant second argument as well in light of Maxopp Investment Ltd. Vs. CIT (2018) 402 ITR 640 (SC) that the impugned computation comes into play 2 | P a g e the moment an assessee declares it’s exempt income. Rejected accordingly. 5. Lastly comes the third important aspect of quantification of the impugned disallowance itself. The Revenue could hardly dispute that the case law Joint Investment Pvt. Ltd. Vs. CIT (2015) 372 ITR 694 (Del) h…

Moorgate Industries India Pvt Ltd, Mumbai vs. DCIT Central Circle 3(3), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 4282/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Oct 2025AY 2011-12

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 14ASection 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SHRI ARUN KHODPIA (ACCOUNTANT MEMBER) I.T.A. No. 4282/Mum/2025 Assessment Year: 2011-12 Moorgate Industries Vs. DCIT Central Circle- India Pvt Ltd 3(3) 1505, 15th Floor, Plot No B Central Circle 3(3), 3, Maurya Garden, N R Kautilya Bhavan Shalimar Maurya bldg, N Bandra-Kurla R Shalimar Maurya Bldg, Complex, Mumbai- Linking Road, Andheri, 400051 Mumbai-400102 PAN: AAHCS9299R (Appellant) (Respondent) Appellant by Shri Gunjan Kakkad Respondent by Shri Annavaran Kosuri, SR. A.R. Date of Hearing 04.09.2025 Date…

Deputy Commissioner of Income Tax, Chennai vs. M/S. Sanmar Speciality Chemicals Limited, Chennai

In the result, both the appeals of the revenue are dismissed

ITA 2287/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2286 & 2287/Chny/2025 यनिाारणवर्ा / Assessment Years:2017-18 & 2018-19 The Deputy Commissioner Of M/S.Sanmar Speciality Income Tax, Vs. Chemicals Limited, Non-Corporate Circle-8(1), No.9, Cathedral Road Chennai, Chennai. [Pan:Aabcs0201P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.R.Vijayaraghavan, Advocate, प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit

For Appellant: Mr.R.Vijayaraghavan, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 14A

…and Rs.13,41,580/- for assessment years 2017-18 and 2018-19 respectively. Aggrieved by this action, the revenue is in appeals before us. 5.0 The issue in dispute is already decided by the decision of Hon’ble Supreme Court in the Maxopp Investment reported in 402 ITR 640 wherein it was held that disallowance u/s 14A of the Act r.w.s. 8D of the Income Tax Rules account exceed the actual exempt income. Respectfully following the same, we do not find any infirmity in the order of the Ld.CIT(A). Accordingly , the grounds raised by the revenue in both the years are dismissed. 6.0 In the result, both the appeals of the…

Deputy Commissioner of Income Tax, Chennai vs. M/S. Sanmar Speciality Chemicals Limited, Chennai

In the result, both the appeals of the revenue are dismissed

ITA 2286/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Oct 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2286 & 2287/Chny/2025 यनिाारणवर्ा / Assessment Years:2017-18 & 2018-19 The Deputy Commissioner Of M/S.Sanmar Speciality Income Tax, Vs. Chemicals Limited, Non-Corporate Circle-8(1), No.9, Cathedral Road Chennai, Chennai. [Pan:Aabcs0201P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.R.Vijayaraghavan, Advocate, प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit

For Appellant: Mr.R.Vijayaraghavan, AdvocateFor Respondent: Mr.C.P.Solomon, JCIT
Section 14A

…and Rs.13,41,580/- for assessment years 2017-18 and 2018-19 respectively. Aggrieved by this action, the revenue is in appeals before us. 5.0 The issue in dispute is already decided by the decision of Hon’ble Supreme Court in the Maxopp Investment reported in 402 ITR 640 wherein it was held that disallowance u/s 14A of the Act r.w.s. 8D of the Income Tax Rules account exceed the actual exempt income. Respectfully following the same, we do not find any infirmity in the order of the Ld.CIT(A). Accordingly , the grounds raised by the revenue in both the years are dismissed. 6.0 In the result, both the appeals of the…