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

Addl.CIT, Special Range-9, New Delhi vs. Candor Gurgaon Two Developers and Project Pvt Ltd, Mumbai

ITA 4597/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No. & Appellant Respondent Assessment Year 3154/Del/2019 Candor Gurgaon One Realty Addl. CIT, 2015-15 Projects Private Limited, Spl Range-2, 1102, Tower B, 11th Floor, New Delhi Peninsula Business Park, Senapati Bapat Road, Lower Parel, Mumbai – 400 013. PAN: AAACU8046K 4598/Del/2019 Addl. CIT, Candor Gurgaon One Realty 2015-16 Spl Range-2, Projects Private Limited, New Delhi 1005, Roots Tower, Plot No.7, District Centre, Laxmi Nagar, Delhi – 110 092. PAN: A…

Candor Kolkata One Hi- Tech Structures Pvt. Ltd., Maharashtra vs. ACIT Spl. Rnage-2, New Delhi

ITA 3211/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No. & Appellant Respondent Assessment Year 3154/Del/2019 Candor Gurgaon One Realty Addl. CIT, 2015-15 Projects Private Limited, Spl Range-2, 1102, Tower B, 11th Floor, New Delhi Peninsula Business Park, Senapati Bapat Road, Lower Parel, Mumbai – 400 013. PAN: AAACU8046K 4598/Del/2019 Addl. CIT, Candor Gurgaon One Realty 2015-16 Spl Range-2, Projects Private Limited, New Delhi 1005, Roots Tower, Plot No.7, District Centre, Laxmi Nagar, Delhi – 110 092. PAN: A…

Candor Gurgaon Two Developers & Project Pvt Ltd (Formerly Knwon As Unitech Developers and Projects Pvt. Ltd.), Delhi vs. Addl. CIT, Special Range- 2, New Delhi

ITA 3155/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No. & Appellant Respondent Assessment Year 3154/Del/2019 Candor Gurgaon One Realty Addl. CIT, 2015-15 Projects Private Limited, Spl Range-2, 1102, Tower B, 11th Floor, New Delhi Peninsula Business Park, Senapati Bapat Road, Lower Parel, Mumbai – 400 013. PAN: AAACU8046K 4598/Del/2019 Addl. CIT, Candor Gurgaon One Realty 2015-16 Spl Range-2, Projects Private Limited, New Delhi 1005, Roots Tower, Plot No.7, District Centre, Laxmi Nagar, Delhi – 110 092. PAN: A…

Candor Gurgaon One Realty Projects Pvt. Ltd. (Formerly Known As Unitech Realty Projects Pvt. Ltd.), Mumbai vs. Addl. CIT, Range- 2, New Delhi

ITA 3154/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No. & Appellant Respondent Assessment Year 3154/Del/2019 Candor Gurgaon One Realty Addl. CIT, 2015-15 Projects Private Limited, Spl Range-2, 1102, Tower B, 11th Floor, New Delhi Peninsula Business Park, Senapati Bapat Road, Lower Parel, Mumbai – 400 013. PAN: AAACU8046K 4598/Del/2019 Addl. CIT, Candor Gurgaon One Realty 2015-16 Spl Range-2, Projects Private Limited, New Delhi 1005, Roots Tower, Plot No.7, District Centre, Laxmi Nagar, Delhi – 110 092. PAN: A…

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)

…416/Mum/2024 and others, dt. 16-10-2024. It was submitted that the Tribunal in the said case has dealt with a similar assessee registered as an NBFC and after following the decision of the Hon‟ble Supreme Court in the case of Maxopp Investments Ltd. vs. CIT, 402 ITR 640 as well as various other decisions held that shares held as stock-in- trade are to be excluded for the purposes of computation of disallowance u/s. 14A of the Act. It was accordingly submitted that the shares that are held as stock in trade should be excluded for the purposes of computation u/s. 14A r.w. Rule 8D of the Rules. It was further submi…

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)

…416/Mum/2024 and others, dt. 16-10-2024. It was submitted that the Tribunal in the said case has dealt with a similar assessee registered as an NBFC and after following the decision of the Hon‟ble Supreme Court in the case of Maxopp Investments Ltd. vs. CIT, 402 ITR 640 as well as various other decisions held that shares held as stock-in- trade are to be excluded for the purposes of computation of disallowance u/s. 14A of the Act. It was accordingly submitted that the shares that are held as stock in trade should be excluded for the purposes of computation u/s. 14A r.w. Rule 8D of the Rules. It was further submi…

Prasad Film Laboratories Private Limited, Hyderabad vs. ACIT., Circle-6(1), Hyderabad

In the result appeal of the assessee is dismissed

ITA 113/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Aug 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Sri V. Siva Kumar, AdvocateFor Respondent: Sri Vinodh Kannan, Sr. AR
Section 10(34)Section 115JSection 14ASection 14A(2)

…ce made under section 14A is not correct, having regard to the books of accounts of the assessee for the relevant assessment year. This principle is also supported by the decision of Hon’ble Supreme Court in the case of Maxopp Investment Ltd., vs., CIT (2018) 402 ITR 640 (SC) where the Hon’ble Supreme Court in para-41 observed that, “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 Assessing Officer needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance…

Compact Agencies Pvt. Ltd., Kolkata vs. DCIT/ACIT, Circle 3(1), Kolkata

Appeal of the assessee is allowed

ITA 1259/KOL/2025[2018-2019]Status: DisposedITAT Kolkata13 Aug 2025AY 2018-2019

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

Section 115JSection 14ASection 250

…ring a particular year. 1.2 Aggrieved with this action of Ld. AO, the assessee approached the CIT(A) where also he could not succeed mainly on account of CBDT’s Circular (supra). Reliance has also been placed on the case of Maxopp Investment Ltd. reported in 402 ITR 640 (SC) and reliance has also been placed on the case of Williamson Financial Services Ltd. reported in 140 taxmann.com 164 (Guwahati-Tribunal) by the Ld. CIT(A). 1.2 In light of the adverse findings in the impugned order, the assessee has approached the ITAT with the following grounds: “1.) That on the facts and in the circumstances of the case,…

Didu Investments Private Limited, Kolkata vs. D.C.I.T., Circle-6(1), Kolkata

The appeal of the assessee is partly allowed

ITA 2585/KOL/2024[2014-15]Status: DisposedITAT Kolkata13 Aug 2025AY 2014-15

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

Section 115JSection 14ASection 250

…ck, for which no effort or expenses have been incurred during the year under consideration, should be outside of the purview of the provision of section 14A of the Act, deserves to be discussed in the light of the case of Maxopp Investment Limited reported in 402 ITR 640 (SC). In this case law, the relevant paragraphs 33 and 34 deserve to be extracted as under: “33. here is no quarrel in assigning this meaning to section 14A of the Act. In fact, all the High Courts, whether it is the Delhi High Court on the one hand or the Punjab and Haryana High Court on the other hand, have agreed in providing this interpretat…

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

ITA 1185/BANG/2025[2018-19]Status: DisposedITAT Bangalore11 Aug 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

…n law and in facts in not appreciating the fact that the decisions referred to by, the learned Assessing officer including the Hon'ble Supreme court's decision in the case of Maxopp Investment Ltd. Vs. Commissioner of Income-tax (2018) 91 taxmann.com 154 (SC)/402 ITR 640 does not apply to the facts of the assessee. e) The Hon'ble Commissioner of Income-tax should have appreciated that the learned Assessing officer's general comments that “when an investment is made it involves certain indirect expenses like administrative expenses as well” does not hold good in the case of assessee as all these investments were m…

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

ITA 1184/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Aug 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

…n law and in facts in not appreciating the fact that the decisions referred to by, the learned Assessing officer including the Hon'ble Supreme court's decision in the case of Maxopp Investment Ltd. Vs. Commissioner of Income-tax (2018) 91 taxmann.com 154 (SC)/402 ITR 640 does not apply to the facts of the assessee. e) The Hon'ble Commissioner of Income-tax should have appreciated that the learned Assessing officer's general comments that “when an investment is made it involves certain indirect expenses like administrative expenses as well” does not hold good in the case of assessee as all these investments were m…

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

In the result, this ground-7 of appeal is dismissed

ITA 190/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17

Bench: Shri. Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Satyaprakash R Singh, CIT DR
Section 10(38)Section 143(3)Section 144(2)Section 14ASection 14A(2)Section 250Section 43C

…er is not satisfied on an objective criteria in the context of its accounts, that suo motu disallowance claimed by the assessee is not proper. 12. In fact, the Supreme Court in the case of Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640 while upholding the view of the Delhi High Court has held that the Assessing Officer needs to record his nonsatisfaction having regard to the sou motu disallowances claimed by the assessee in the context of its accounts. It is only thereafter, the occasion to apply rule 8D of the Rules for apportionment of expenses can arise 13. In the present fa…

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

In the result, this ground-7 of appeal is dismissed

ITA 189/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16

Bench: Shri. Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Satyaprakash R Singh, CIT DR
Section 10(38)Section 143(3)Section 144(2)Section 14ASection 14A(2)Section 250Section 43C

…er is not satisfied on an objective criteria in the context of its accounts, that suo motu disallowance claimed by the assessee is not proper. 12. In fact, the Supreme Court in the case of Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640 while upholding the view of the Delhi High Court has held that the Assessing Officer needs to record his nonsatisfaction having regard to the sou motu disallowances claimed by the assessee in the context of its accounts. It is only thereafter, the occasion to apply rule 8D of the Rules for apportionment of expenses can arise 13. In the present fa…

Ponni Sugars (Erode) Ltd., Chennai vs. DCIT, Circle-1, Ltu, Chennai

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

ITA 23/CHNY/2025[2009-10]Status: DisposedITAT Chennai06 Aug 2025AY 2009-10

Bench: Shri George George Kand Shri Amitabh Shuklaआयकर अपील सं./Ita No.: 23/Chny/2025 िनधा"रण वष"/Assessment Year:2009-10 Ponni Sugars (Erode) Limited, The Deputy Commissioner Esvin House, No.13, Vs. Of Income Tax, Rajiv Gandhi Salai (Omr), Circle-1, Ltu, Perungudi, Chennai. Chennai – 600 096. Pan: Aaccp 2779A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N.R. Suresh, C.A. ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 05.08.2025 घोषणा क" तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Shri N.R. Suresh, C.AFor Respondent: Ms. Anitha, Addl.CIT
Section 115JSection 14ASection 250

…आयकर अपील"य अ"धकरण,‘सी’ "यायपीठ,चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी जॉज" जॉज" के, उपा"य" एवं "ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.: 23/CHNY/2025 िनधा"रण वष"/Assessment Year:2009-10 Ponni Sugars (Erode) Limited, The Deputy Commissioner ESVIN House, No.13, Vs. of Income Tax, Rajiv Gandhi Salai (OMR), Circle-1, LTU, Perungudi, Chennai. Chennai – 600 096. PAN: AACCP 2779A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri N.R. Suresh, C.A. ""यथ" क" ओर से/Respo…

Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru vs. Infosys Limited, Bengaluru

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR
Section 1Section 10ASection 155Section 250

…ITA No.881/Bang/2023 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year: 2019-20 Infosys Limited Dy. Commissioner of Income Tax Plot 44, Konappana Agrahara Circle – 3(1)(1) Hosur Road, Konappana BMTC Building, 80 Feet Road Bangalore – 560100 Vs. Koramangala, Bangalore – 560095 Karnataka Karnataka PAN: AAACI4798L APPELLANT RESPONDENT Assessment Year: 2019-20 Jt. Commissioner of Income Tax (OSD) Infosys Limited Circle – 3(1)(1) Plot 44, Konappana Agrahara Room NO. 241, 2nd Floor Hosur Road…

Dy..C.I.T., Bangalore vs. M/S State Bank of Mysore, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 683/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

…have yielded exempt Income during the year. In this regard, the Ld.AR drew our attention to the following illustrative list of decisions which, after considering the decision of the Apex Court in the case of Maxopp Investment Ltd. v/s. CIT reported in [2018] 402 ITR 640 have held that section 14A is not applicable to Banks where investments are held as stock in trade: • PCIT v/s. Punjab and Sind. Bank [ITA Nos.904 and 906/2019] (Delhi High Court); • MUFG Bank Ltd. v/s. ACIT [ITA Nos.7895/Del/2019] (Delhi-Tribunal); • Union Bank of India v/s. DCIT [ITA Nos.1804 to 1807/Mum/2018 and 2227 to 2230/Mum2018] Tribunal)…

State Bank of Mysore, Bangalore vs. JCIT, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 660/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

…have yielded exempt Income during the year. In this regard, the Ld.AR drew our attention to the following illustrative list of decisions which, after considering the decision of the Apex Court in the case of Maxopp Investment Ltd. v/s. CIT reported in [2018] 402 ITR 640 have held that section 14A is not applicable to Banks where investments are held as stock in trade: • PCIT v/s. Punjab and Sind. Bank [ITA Nos. 904 and 906/2019] (Delhi High Court); • MUFG Bank Ltd. v/s. ACIT [ITA Nos. 7895/Del/2019] (Delhi-Tribunal); 37 ITA 660 & 683/Bang /2015 State Bank of India / State Bank of Mysore • Union Bank of India v/…

Fortune Gourmet Specalities Private Limted, Mumbai vs. ACIT Circle 6(3)(1), Mumbai

In the result, appeal of the assessee allowed

ITA 4010/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Gunjan Kakkad, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R
Section 14ASection 14A(2)

…er is not satisfied on an objective criteria in the context of its accounts, that suo motu disallowance claimed by the assessee is not proper. 12. In fact, the Supreme Court in the case of Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154/254 Taxman 325/402 ITR 640 while upholding the view of the Delhi High Court has held that the Assessing Officer needs to record his non- satisfaction having regard to the sou motu disallowances claimed by the assessee in the context of its accounts. It is only thereafter, the occasion to apply rule 8D of the Rules for apportionment of expenses can arise. 13. In the present…

DCIT, Central Circle-4, New Delhi vs. G N International P.Ltd, New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2851/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumarg. N. International Pvt. Ltd, Vs. Acit, 3721/1, First Floor, Netaji Circle-10(2), Subhash Marg, Daryaganj, New Delhi New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Dcit, Vs. G. N. International Pvt. Ltd, Central Circle-4, 3721/1, First Floor, Netaji New Delhi Subhash Marg, Daryaganj, New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Assessee By : Shri Salil Agarwal, Sr. Adv Shri Shailesh Gupta, Ca Shri Dadhur Agarwal, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Ms. Neeju Gupta, Sr. Dr Date Of Hearing 25/07/2025 Date Of Pronouncement 30/07/2025

For Appellant: Shri Salil Agarwal, Sr. AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 144Section 68

…We find that the action of the Learned CIT(A) was supported by the decision of Hon’ble Jurisdictional High Court in the case of Joint Investments reported in 372 ITR 694 (Del) and decision of Hon’ble Supreme Court in the case of Maxopp Investments reported in 402 ITR 640 (SC) wherein it was categorically held that disallowance under section 14A of the Act cannot exceed the exempt income. Further, the Hon’ble Jurisdictional High Court in the case of PCIT vs ERA Infrastructure India Limited in Income Tax Appeal No. 204/2022 had categorically held that the amendment made to the provisions of section 14A of the Act v…

G N International P.Ltd, New Delhi vs. ACIT, Circle-10(2), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2676/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumarg. N. International Pvt. Ltd, Vs. Acit, 3721/1, First Floor, Netaji Circle-10(2), Subhash Marg, Daryaganj, New Delhi New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Dcit, Vs. G. N. International Pvt. Ltd, Central Circle-4, 3721/1, First Floor, Netaji New Delhi Subhash Marg, Daryaganj, New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Assessee By : Shri Salil Agarwal, Sr. Adv Shri Shailesh Gupta, Ca Shri Dadhur Agarwal, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Ms. Neeju Gupta, Sr. Dr Date Of Hearing 25/07/2025 Date Of Pronouncement 30/07/2025

For Appellant: Shri Salil Agarwal, Sr. AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 144Section 68

…We find that the action of the Learned CIT(A) was supported by the decision of Hon’ble Jurisdictional High Court in the case of Joint Investments reported in 372 ITR 694 (Del) and decision of Hon’ble Supreme Court in the case of Maxopp Investments reported in 402 ITR 640 (SC) wherein it was categorically held that disallowance under section 14A of the Act cannot exceed the exempt income. Further, the Hon’ble Jurisdictional High Court in the case of PCIT vs ERA Infrastructure India Limited in Income Tax Appeal No. 204/2022 had categorically held that the amendment made to the provisions of section 14A of the Act v…