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

1,596 judgments on BharatTax cite Maxopp Investment Ltd. v. CIT (402 ITR 640), spanning 2016 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 37(1), Section 1961.

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 367,154 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

Shapoorji Pallonji & Company Pvt. Ltd, Mumbai vs. DCIT Cir 3(3) (1), Mumbai

In the result, both the appeals of the assessee are partly allowed and cross objections are dismissed

ITA 2027/MUM/2021[2016-17]Status: DisposedITAT Mumbai06 Mar 2025AY 2016-17

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Rajan Vora a/w Shri Nikhil Tiwari & Ms. Palak MehtaFor Respondent: Shri Ajay Chandra, CIT/DR

Section 115JSection 14ASection 36(1)(iii)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 2232/Mum/2021 (A.Y. 2016-17) DCIT, Central Circle- M/s. Shapoorji Pallonji and Co. 8(3), Aayakar Bhavan, Pvt. Ltd. Mumbai Vs. First Floor, Shapoorji Pallonji Centre, 41/44, Minoo Desai Marg, Colaba, Mumbai-400005. PAN: AAACS 6994 C (Appellant) (Respondent) ITA No. 2027/Mum/2021 (A.Y. 2016-17) M/s. Shapoorji Pallonji and Co. DCIT, Central Circle- Pvt. Ltd. 8(3), Aayakar Bhavan, Mumbai First Floor, Shapoorji Pallonji Vs. Centre, 41/44, Minoo Desai Marg, Col…

Shapoorji Pallonji and Company Pvt. Ltd, Mumbai vs. DCIT Cir 3(3) (1), Mumbai

In the result, both the appeals of the assessee are partly allowed and cross objections are dismissed

ITA 2026/MUM/2021[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Rajan Vora a/w Shri Nikhil Tiwari & Ms. Palak MehtaFor Respondent: Shri Ajay Chandra, CIT/DR

Section 115JSection 14ASection 36(1)(iii)Section 92C

National Stock Exchange of India Limited, Mumbai vs. Dy Commissioner of Income Tax -Circle 7(1)(1), Mumbai

ITA 1092/MUM/2022[2012-13]Status: DisposedITAT Mumbai28 Feb 2025AY 2012-13

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawal

For Respondent: Shri J.D.Mistry, Sr. Advocate

Section 14A

…disalowance and reasoning given by Assessing Officer for invoking Rule 8D are also on similar lines. 25. The above finding arrived at by us is further fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) (2018) 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as: “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 Assessing Officer needs to record satisfaction that havin…

National Stock Exchange of India Limited, Mumbai vs. Dy Commissioner of Income Tax -Circle 7(1)(1), Mumbai

In the result, all the five appeals of the assessee are partly allowed and the appeal of the Revenue is dismissed

ITA 1091/MUM/2022[2011-12]Status: DisposedITAT Mumbai28 Feb 2025AY 2011-12

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawalassessment Year: 2006-07

For Appellant: Shri J.D.Mistry, Sr. Advocate and Shri Harsh KapadiaFor Respondent: Shri Kailash C. Kanojiya, CIT DR and Ms Monika H. Pande, Sr.AR

Section 1Section 14A

…disallowance and reasoning given by Assessing Officer for invoking Rule 8D are also on similar lines. 25. The above finding arrived at by us is further fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) (2018) 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as under: "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 Assessing Officer needs to record satisfaction that…

National Stock Exchange of India Ltd, Mumbai vs. Dy CIT -Circle 7(1) (1), Mumbai

ITA 1089/MUM/2022[2006-07]Status: DisposedITAT Mumbai28 Feb 2025AY 2006-07

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawal

For Respondent: Shri J.D.Mistry, Sr. Advocate

Section 14A

…disallowance and reasoning given by Assessing Officer for invoking Rule 8D are also on similar lines. 25. The above finding arrived at by us is further fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) (2018) 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as under: “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 Assessing Officer needs to record satisfaction that…

Bombay Oxygen Investments Limited, Mumbai vs. Commisioner of Income Tax, Mumbai

In the result, appeal of the assessee is allowed

ITA 4406/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Feb 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Ronak Doshi, CAFor Respondent: Ms. Monika H. Pande, Sr. AR

Section 10(34)Section 115JSection 143(3)Section 14A

…assessee under section 14A of the Act. Accordingly, ground taken by the assessee in this respect is allowed. 7.5. The above finding arrived at by us is fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) (2018) 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as under: "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 Assessing Officer needs to record satisfaction that…

Jaikishan Bhagchandka, Andheri (West) vs. ACIT 24(2), Mumbai, Parel

In the result, the present appeal is allowed

ITA 6370/MUM/2024[2017-18]Status: DisposedITAT Mumbai25 Feb 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarvs. Acit, 24(2), Jaikishanbhagchandka, Mumbai –400012 503, Highland Park, New Link Road, Lokhandwala Complex Andheri (W), Mumbai – 400053. Pan/Gir No. Adjpb1765F (Applicant) (Respondent)

Section 10(38)Section 14Section 14ASection 14A(2)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER Vs. ACIT, 24(2), JaikishanBhagchandka, Mumbai –400012 503, Highland Park, New Link Road, Lokhandwala Complex Andheri (W), Mumbai – 400053. PAN/GIR No. ADJPB1765F (Applicant) (Respondent) Assessee by Sh. Ashok Bansal, Revenue by Sh. Sunil Mathews, Sr. DR सुनवाई क" तारीख/Date of Hearing 15.01.2025 घोषणा क" तारीख/Date of Pronouncement 25.02.2025 आदेश / ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order u/s 250 dated…

Assistant Commissioner of Income Tax 3(4), Mumbai, Aaykar Bhavan vs. Idbi Bank Ltd, Parth Plazamorbi

In the result, all the aforesaid appeals of the Revenue and CO of the assessee are dismissed

ITA 5959/MUM/2024[2013-14]Status: DisposedITAT Mumbai24 Feb 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Vs. Idbi Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024) Assessment Year: 2013-14 Idbi Bank Ltd., Vs. Assistant Commissioner Apulki Cornermenon, Of Income Tax -3(4), Piston Compound, Mumbai Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri C. Naresh, ARFor Respondent: Shri R.A. Dhyani, CIT,DR

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “C’ BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.5900, 5958 & 5959/MUM/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 and 2013-14) Assistant Commissioner of Vs. IDBI Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, TOAP 416122, Kolhapur Maharashtra स्थायी लेखा सं./PAN No. : AABCI8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/MUM/2024 (Arising out of ITA No. 5959/MUM/2024) Assessment Year: 2013-14 IDBI Bank Ltd., Vs. Assistan…

Assistant Commissioner of Income Tax 3(4), Mumbai vs. Idbi Bank Ltd, Panchanantala Road

In the result, all the aforesaid appeals of the

ITA 5958/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Feb 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ष / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Income Tax -3(4), Mumbai Vs. Idbi Bank Ltd., Apulki Cornermenon, Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलार्थी/Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024)

For Respondent: Shri C. Naresh, AR

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.5900, 5958 & 5959/MUM/2024 (निर्धारण वर्ष / Assessment Years : 2021-22, 2018-19 and 2013-14) Assistant Commissioner of Income Tax -3(4), Mumbai Vs. IDBI Bank Ltd., Apulki Cornermenon, Piston Compound, TOAP 416122, Kolhapur Maharashtra स्थायी लेखा सं./PAN No. : AABCI8842G (अपीलार्थी/Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/MUM/2024 (Arising out of ITA No. 5959/MUM/2024) Assessment Year: 2013-14 IDBI Bank Ltd., Apulki Cornerm…

ACIT 3(4), Mumbai vs. Idbi Bank Limited, Mumbai

In the result, all the aforesaid appeals of the Revenue and CO of the assessee are dismissed

ITA 5900/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Feb 2025AY 2021-22

For Appellant: Shri C. Naresh, ARFor Respondent: Shri R.A. Dhyani, CIT,DR

Section 250

Amit Kumar, Panipat Haryana vs. DCIT, NFAC (Delhi)

ITA 193/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Feb 2025AY 2017-18

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…

Bajaj Holdings & Investment Ltd ( Formerly Bajaj Auto Ltd), Mumbai vs. ACIT Ltu, Mumbai

ITA 5299/MUM/2010[2006-07]Status: DisposedITAT Mumbai17 Feb 2025AY 2006-07

Section 143(3)

…ITA No. 6838/Mum/2008, ITA No.6674/Mum/2008 ITA No.1223/Mum/2010, ITA No. 535/Mum/2010 ITA No.5299/Mum/2010, ITA No.4632/Mum/2010 Assessment Years 2004-05, 2005-06 & 2006-07 11 DCIT [2010] 328 ITR 81 (Bombay) & Maxopp Investments Vs. CIT [2018] 402 ITR 640 (SC)]. 6. 11. Further, on perusal of Assessment Order we find that the Assessing Officer has concluded that interest of INR.15,79,260/- was incurred in relation to investment made in tax free investments aggregating to INR.1296.70 Crores. A perusal of financial statements of the Assessee for the relevant previous year shows that Own Fund…

Bajaj Holdings & Investments Ltd ( Formerly Known As Bajaj Auto Ltd), Mumbai vs. Addl CIT RG 3(1), Mumbai

The appeals are partly allowed

ITA 6838/MUM/2008[2004-2005]Status: DisposedITAT Mumbai17 Feb 2025AY 2004-2005

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Ankush Kapoor

Section 143(3)

…fg Co. Ltd. Vs. ITA No. 6838/Mum/2008, ITA No.6674/Mum/2008 ITA No.1223/Mum/2010, ITA No. 535/Mum/2010 ITA No.5299/Mum/2010, ITA No.4632/Mum/2010 Assessment Years 2004-05, 2005-06 & 2006-07 DCIT [2010] 328 ITR 81 (Bombay) & Maxopp Investments Vs. CIT [2018] 402 ITR 640 (SC)]. 6.11. Further, on perusal of Assessment Order we find that the Assessing Officer has concluded that interest of INR.15,79,260/- was incurred in relation to investment made in tax free investments aggregating to INR.1296.70 Crores. A perusal of financial statements of the Assessee for the relevant previous year shows that Own Funds (Share…

ACIT Cir 2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2777/MUM/2019[2016-17]Status: DisposedITAT Mumbai06 Feb 2025AY 2016-17

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailbank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra Kurla Complex, Bandra (East), Mumbai-400051. ……………. Appellant Pan: Aaacb 1534 F V/S Acit, 2(1)(1), ……………. Respondent Mumbai-400051. Acit, Circle - 2(1)(1), Room No. 561, 5Th Floor, Aayakar Bhavan, M.K. Road, ……………. Appellant Mumbai-400020. V/S Bank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra ……………. Respondent Kurla Complex, Bandra (East), Mumbai-400051. Pan: Aaacb 1534 F

For Appellant: Mr. C. NareshFor Respondent: Mr. Kailash C. Kanojiya, CIT-DR

Section 115JSection 143(3)Section 14ASection 250

…tax free income and that in the absence of any expenditure incurred in relation to earning tax free income no disallowance u/s 14A is warranted. 1.1 The CIT(A) ought to have followed the decision of hon'ble Supreme Court in the case of State Bank of Patiala (402 ITR 640) and allowed the claim of appellant that no disallowance is warranted u/s 14A. ITA Nos. 1649 & 2777/M/2019 Bank of Baroda 3 1.2 Without prejudice to above, as appellant does not hold any investments but only stock in trade, the disallowance under Rule 8D can only be nil since the disallowance is to be computed based on average value of investme…

Bank of Baroda, Mumbai vs. ACIT 2 (1)(1), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1649/MUM/2019[2016-17]Status: DisposedITAT Mumbai06 Feb 2025AY 2016-17

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Mr. C. NareshFor Respondent: Mr. Kailash C. Kanojiya, CIT-DR

Section 115JSection 143(3)Section 14ASection 250

…tax free income and that in the absence of any expenditure incurred in relation to earning tax free income no disallowance u/s 14A is warranted. 1.1 The CIT(A) ought to have followed the decision of hon'ble Supreme Court in the case of State Bank of Patiala (402 ITR 640) and allowed the claim of appellant that no disallowance is warranted u/s 14A. 1.2 Without prejudice to above, as appellant does not hold any investments but only stock in trade, the disallowance under Rule 8D can only be nil since the disallowance is to be computed based on average value of investments, the income from which shall not or does no…

Preeti Goyal, New Delhi vs. DCIT Central Circle-31, New Delhi

ITA 1240/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Rohit Kapoor, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr. DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘E’: NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No.1244/Del/2025 (Assessment Year: 2016-17) DCIT, vs. M/s. Bright Buildtech Pvt. Ltd., Central Circle 1, Noida Flat No.14, Ground Floor, DDA MIG Suraj Apartment, PulPehladPur, New Delhi – 110 044. (PAN :AACCB7981J) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Rohit Kapoor, Advocate Shri Virsain Aggarwal, AR REVENUE BY : Shri Abhijeet Kumar, Sr. DR Date of Hearing : 09.10.2025 Date of Order : 22.12.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :…

ACIT-1(1), Indore vs. Flexituff Ventures International Limited, Dhar

Appeal is dismissed

ITA 195/IND/2024[2013-14]Status: DisposedITAT Indore30 Jan 2025AY 2013-14

Bench: Us Assailing The Order Of First-

Section 10ASection 143(3)Section 14A

…आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER Assessment Year:2013-14 ACIT-1(1), M/s Flexituff Ventures Indore International Limited, C-41-50, SEZ, Sector-3, बनाम/ Pithampur, Vs. Dhar (Revenue/Appellant) (Assessee/Respondent) PAN: AAACN5986H Assessee by Shri Manjeet Sachdeva AR Revenue by Shri Ram Kumar Yadav, CIT-DR Date of Hearing 08.01.2025 Date of Pronouncement 30.01.2025 आदेश/ O R D E R Per B.M. Biyani, A.M.: Feeling aggrieved by order of first appeal dated 30.01.2024 passed by…

ACIT-2(3)(1), Mumbai vs. Hdfc Bank Ltd ( Merged Entity Hdfc Investments Limited ), Mumbai

ITA 2980/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Jan 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate a

…ce made by the assessee. Accordingly, grounds raised by both assessee and revenue are partly allowed. 10. 7. The above finding arrived at by us is fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) [2018] 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as under: "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 Assessing Officer needs to record satisfaction…

Hdfc Bank Limited (As Successor to Hdfc Ltd), Mumbai vs. DCIT 2(3)(1), Mumbai

ITA 2665/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jan 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Section 143(3)

…nce made by the assessee. Accordingly, grounds raised by both assessee and revenue are partly allowed. 10. 7. The above finding arrived at by us is fortified by the decision of Hon'ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT(A) [2018] 402 ITR 640 (SC) while emphasising on aspect of recording of satisfaction by the ld. Assessing Officer for which it observed as under: "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 Assessing Officer needs to record satisfaction t…

ACIT-2(3)(1), Mumbai vs. Hdfc Bank Limited (Merged Entity Housing Development Finance Corporation Limited), Mumbai

In the result, appeals of both, assessee and revenue are decided

ITA 2597/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Jan 2025AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

Section 1