Redington (India) Ltd. v. Addl. CIT

77 Taxmann.com 257High Court2017#201 most cited

What is Redington (India) Ltd. v. Addl. CIT authority for?

No disallowance under Section 14A can be made in the absence of actual exempt income, as Section 14A relates to the earning of actual income, not notional or anticipated income, thereby declining to apply the CBDT Circular dated 11th May 2014 in such cases.

370

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

Redington (India) Ltd. v. Addl. CIT · Section 14A disallowance · absence of exempt income · actual income · notional income · CBDT Circular 11 May 2014 · expenditure for exempt income · Madras High Court · 392 ITR 633 · 77 taxmann.com 257

Also reported as

392 ITR 633

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 8DSection 250Section 35ADSection 35AD(7B)Section 37(1)

Issues it is cited on

strategic investmentdisallowance of interest expendituredisallowance u/s 14adisallowance under section 14asection 14amercantile system of accountingsection 32section 9(1)commercial expediencysection 43section 43bsection 37

Judgments citing Redington (India) Ltd. v. Addl. CIT

Hansa Vision India Private Limited, Chennai vs. DCIT, Chennai

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 3443/CHNY/2019[2014-15]Status: DisposedITAT Chennai05 May 2022AY 2014-15

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3443/Chny/2019 िनधा"रण वष"/Assessment Year:2014-15 M/S. Hansa Vision India P. Ltd., The Deputy Commissioner Of No. 19, Wheatcroft Road, Vs. Income Tax, Nungambakkam, Chennai 600 034. Corporate Circle 2(2), [Pan:Aabct3770E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.04.2022 घोषणा की तारीख /Date Of Pronouncement : 05.05.2022 आदेश /O R D E R Per V. Durga Rao,: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai, Dated 29.11.2019 Relevant To The Assessment Year 2014-15. 2. The First Ground & Ground No. 12 Raised In The Appeal Are General In Nature & Requires No Adjudication.

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl. CIT
Section 115JSection 14A

…xempt income in the assessment year under appeal and therefore, the Assessing Officer cannot make any disallowance under section 14A of the Act in view of the decision of the Hon’ble Jurisdictional High Court in the case Redington India Limited v. ACIT [2017] 77 Taxmann.com 257 (Mad) and prayed for deleting the addition made under section 14A of the Act. It was further submitted that no disallowance under section 14A of the Act could be made while computing book profits under section 115JB of the Act in view of the 3 I.T.A. No.3443/Chny/19 decision in the case of Sobha Developers Ltd. v. DCIT 434 ITR 266 (Kar).…

M/S.Kal Airways Private Ltd, Chennai vs. DCIT, Corporate Circle 4(2), Chennai

The appeal stand allowed in terms of our above order

ITA 135/CHNY/2022[2015-2016]Status: DisposedITAT Chennai18 Apr 2022AY 2015-2016

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri K. Ramakrishnan (FCA) – Ld. ARFor Respondent: Shri ARV Sreenivasan (Addl. CIT) – Ld. DR
Section 143(3)Section 14A

…sition of law that in the absence of any exempt income earned by the assessee during the year, no disallowance u/s 14A could have been made by revenue authorities. The ratio of decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633)as well as the decision in CIT V/s Chettinad Logistics Private Ltd. (248 Taxman 55) is squarely applicable to the fact of the case. In the case of CIT V/s Chettinad Logistics Private Ltd. (supra), the Hon’ble Court has already considered CBDT Circular No.5 dated 11.02.2014. Further, revenue’s Special Leave Petition (SLP) against this order has al…

DCIT Corporate Circle 1(2), Chennai vs. Consul Neowatt Power Solution Pvt. Ltd., Chennai

In the result, appeal filed by the revenue and cross

ITA 1290/CHNY/2018[2013-14]Status: DisposedITAT Chennai28 Mar 2022AY 2013-14

Bench: Shri V. Durga Rao & Shri G. Manjunatha

Section 14A

…h is in excess of dividend income earned for the year. It is well settled principle of law by the decision of various courts, including decision of the Hon'ble Jurisdictional High Court of Madras in the case of M/s. Redington India Ltd. Vs. Addl.CIT (2017) 77 Taxmann.com 257 (Mad), where it has been clearly held that disallowance contemplated u/s.14A r.w. Rule 8D cannot exceed exempt income. The learned CIT(A), after considering relevant facts has rightly directed the Assessing Officer to recompute disallowance u/s.14A of the Act, but 10 & C.O.No.102/Chny/2018 restrict disallowance to the extent of exempt…

The DCIT, Kochi vs. M/S.Sfo Technologies P. Ltd, Aluva

In the result, this appeal filed by Revenue in ITA

ITA 404/COCH/2020[2016-17]Status: DisposedITAT Cochin24 Feb 2022AY 2016-17

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George Mathan, JM & Shri Ramit Kochar, AM ITA No. A.Y. Appellant Respondent 400/Coch/2020 2010-11 M/s.SFO Technologies Pvt. Ltd., Deputy Commissioner 401/Coch/2020 2012-13 XIX/346, Stone House, of Income Tax, Corporate Circle-2(1), Aluva, 402/Coch/2020 2013-14 Ernakulam-683101 3rd Floor, C R Building I.S. Press Road, Kochi- 403/Coch/2020 2014-15 [PAN: AADCS3318K] 682018 404/Coch/2020 2016-17 Appellant by: Smt. Jamunna Devi, Sr.DR Respondent by: Shri Anil D. Nair& Smt. Telma Date of Hearing: 22.02.2022& 24.02.2022 Date of Pronouncement: 24.0…

The DCIT, Kochi vs. M/S.Sfo Technologies P. Ltd, Aluva

In the result, this appeal filed by Revenue in ITA

ITA 403/COCH/2020[2014-15]Status: DisposedITAT Cochin24 Feb 2022AY 2014-15

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George Mathan, JM & Shri Ramit Kochar, AM ITA No. A.Y. Appellant Respondent 400/Coch/2020 2010-11 M/s.SFO Technologies Pvt. Ltd., Deputy Commissioner 401/Coch/2020 2012-13 XIX/346, Stone House, of Income Tax, Corporate Circle-2(1), Aluva, 402/Coch/2020 2013-14 Ernakulam-683101 3rd Floor, C R Building I.S. Press Road, Kochi- 403/Coch/2020 2014-15 [PAN: AADCS3318K] 682018 404/Coch/2020 2016-17 Appellant by: Smt. Jamunna Devi, Sr.DR Respondent by: Shri Anil D. Nair& Smt. Telma Date of Hearing: 22.02.2022& 24.02.2022 Date of Pronouncement: 24.0…

The DCIT, Kochi vs. M/S.Sfo Technologies P. Ltd, Aluva

In the result, this appeal filed by Revenue in ITA

ITA 402/COCH/2020[2013-14]Status: DisposedITAT Cochin24 Feb 2022AY 2013-14

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George Mathan, JM & Shri Ramit Kochar, AM ITA No. A.Y. Appellant Respondent 400/Coch/2020 2010-11 M/s.SFO Technologies Pvt. Ltd., Deputy Commissioner 401/Coch/2020 2012-13 XIX/346, Stone House, of Income Tax, Corporate Circle-2(1), Aluva, 402/Coch/2020 2013-14 Ernakulam-683101 3rd Floor, C R Building I.S. Press Road, Kochi- 403/Coch/2020 2014-15 [PAN: AADCS3318K] 682018 404/Coch/2020 2016-17 Appellant by: Smt. Jamunna Devi, Sr.DR Respondent by: Shri Anil D. Nair& Smt. Telma Date of Hearing: 22.02.2022& 24.02.2022 Date of Pronouncement: 24.0…

The DCIT, Kochi vs. M/S.Sfo Technologies P. Ltd, Ernakulam

In the result, this appeal filed by Revenue in ITA

ITA 401/COCH/2020[2012-13]Status: DisposedITAT Cochin24 Feb 2022AY 2012-13

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George Mathan, JM & Shri Ramit Kochar, AM ITA No. A.Y. Appellant Respondent 400/Coch/2020 2010-11 M/s.SFO Technologies Pvt. Ltd., Deputy Commissioner 401/Coch/2020 2012-13 XIX/346, Stone House, of Income Tax, Corporate Circle-2(1), Aluva, 402/Coch/2020 2013-14 Ernakulam-683101 3rd Floor, C R Building I.S. Press Road, Kochi- 403/Coch/2020 2014-15 [PAN: AADCS3318K] 682018 404/Coch/2020 2016-17 Appellant by: Smt. Jamunna Devi, Sr.DR Respondent by: Shri Anil D. Nair& Smt. Telma Date of Hearing: 22.02.2022& 24.02.2022 Date of Pronouncement: 24.0…

The DCIT, Kochi vs. M/S.Sfo Technologies P. Ltd, Aluva

In the result, this appeal filed by Revenue in ITA

ITA 400/COCH/2020[2010-11]Status: DisposedITAT Cochin24 Feb 2022AY 2010-11

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

For Appellant: Smt. Jamunna Devi, Sr.DRFor Respondent: Shri Anil D. Nair& Smt. Telma
Section 143(3)Section 14ASection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George Mathan, JM & Shri Ramit Kochar, AM ITA No. A.Y. Appellant Respondent 400/Coch/2020 2010-11 M/s.SFO Technologies Pvt. Ltd., Deputy Commissioner 401/Coch/2020 2012-13 XIX/346, Stone House, of Income Tax, Corporate Circle-2(1), Aluva, 402/Coch/2020 2013-14 Ernakulam-683101 3rd Floor, C R Building I.S. Press Road, Kochi- 403/Coch/2020 2014-15 [PAN: AADCS3318K] 682018 404/Coch/2020 2016-17 Appellant by: Smt. Jamunna Devi, Sr.DR Respondent by: Shri Anil D. Nair& Smt. Telma Date of Hearing: 22.02.2022& 24.02.2022 Date of Pronouncement: 24.0…

DCIT Corporate Circle 2 (2), Chennai vs. Iss Sdb Security Services Private Limited, Chennai

The appeal stands dismissed

ITA 3536/CHNY/2018[2014-15]Status: DisposedITAT Chennai21 Feb 2022AY 2014-15

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri MP Lohia (CA) – Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) –Ld. DR
Section 143(3)Section 14ASection 32(1)(ii)Section 36(1)(va)Section 43B

…verage investments. The same was added while computing income under normal provisions as well as while computing Book Profits u/s 115JB. The Ld. CIT(A), inter-alia, relying on the decision of Hon’ble High Court of Madras in Redington India Ltd. V/s Addl. CIT (392 ITR 633) directed Ld. AO to delete the disallowance if no exempt income was earned by the assessee during the year. It was also held that disallowance could not be added back to Book Profits u/s 115JB as per the decision of Special Bench of Delhi Tribunal in ACIT V/s Vireet Investment (P) Ltd. (165 ITD 27). Aggrieved, the revenue is in further appeal bef…

DCIT Corporate Circle 2(2), Chennai vs. Iss Sdb Security Services Pvt. Limited, Chennai

The appeal stands dismissed

ITA 2707/CHNY/2017[2011-12]Status: DisposedITAT Chennai21 Feb 2022AY 2011-12

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri MP Lohia (CA) – Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) –Ld. DR
Section 143(3)Section 14ASection 32(1)(ii)Section 36(1)(va)Section 43B

…verage investments. The same was added while computing income under normal provisions as well as while computing Book Profits u/s 115JB. The Ld. CIT(A), inter-alia, relying on the decision of Hon’ble High Court of Madras in Redington India Ltd. V/s Addl. CIT (392 ITR 633) directed Ld. AO to delete the disallowance if no exempt income was earned by the assessee during the year. It was also held that disallowance could not be added back to Book Profits u/s 115JB as per the decision of Special Bench of Delhi Tribunal in ACIT V/s Vireet Investment (P) Ltd. (165 ITD 27). Aggrieved, the revenue is in further appeal bef…

Shriram City Union Finance Ltd., Chennai vs. PCIT Corporeate Circle-6(1), Chennai

The appeal stand allowed in terms of our above order

ITA 1717/CHNY/2019[2014-15]Status: DisposedITAT Chennai21 Jan 2022AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Sivaraman, (Advocate)-Ld. ARFor Respondent: Shri G. Johnson (Addl.CIT) – Ld. DR
Section 143(3)Section 14ASection 263

…आयकर अपीलीय अिधकरण ‘सी’ "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, CHENNAI माननीय "ी वी. दुगा" राव, "ाियक सद" एवं माननीय "ी मनोज कुमार अ"वाल ,लेखा सद" के सम"। BEFORE HON’BLE SHRI V. DURGA RAO, JUDICIAL MEMBER AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.1717/Chny/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/s. Shriram City Union Finance Ltd. Pr. CIT-6 Mookambika Complex, 2nd Floor बनाम/ Chennai. No.4, Lady Desika Road, Mylapore, Vs. Chennai – 600 004. "थायी लेखा सं./जीआइ आर सं./PAN/GIR No. AAACS-7703-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओरसे/ Appellant…

ACIT, Madurai vs. J.K.Fenner (India) Limited, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 967/CHNY/2017[2013-14]Status: DisposedITAT Chennai21 Jan 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

J.K.Fenner (India) Limited, Chennai vs. ACIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 947/CHNY/2017[2013-14]Status: DisposedITAT Chennai21 Jan 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

ACIT Corporate Circle 1, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1883/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Jan 2022AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

J.K.Fenner (India) Limited, Madurai vs. ACIT Corporate Circle 1, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1846/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Jan 2022AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1272/CHNY/2016[2012-13]Status: DisposedITAT Chennai21 Jan 2022AY 2012-13

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1078/CHNY/2016[2010-11]Status: DisposedITAT Chennai21 Jan 2022AY 2010-11

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1077/CHNY/2016[2009-10]Status: DisposedITAT Chennai21 Jan 2022AY 2009-10

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

ACIT, Madurai vs. J.K.Fenner (India) Ltd., Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1076/CHNY/2016[2008-09]Status: DisposedITAT Chennai21 Jan 2022AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…

J.K.Fenner (India) Limited, Chennai vs. JCIT, Madurai

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

ITA 1063/CHNY/2016[2012-13]Status: DisposedITAT Chennai21 Jan 2022AY 2012-13

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Vijayaraghavan (Advocate) – Ld. ARFor Respondent: Shri M. Murali, Ld. CIT-DR
Section 14ASection 32(2)

…allowance u/r 8D(2)(iii) was to be computed only by considering those investments which have yielded exempt income during the year. These propositions are duly supported by the decision of Hon’ble Madras High Court in the case of Redington India Private Ltd. (392 ITR 633) as well as another decision of Hon’ble Court in CIT V/s Chettinad Logistics Private Ltd. (95 Taxman.com 250). 21. The assessee’s plea that the investments were strategic investment and therefore, no disallowance was to be computed, is to be disregarded in the light of decision of Hon’ble Supreme Court in the case of Maxopp Investment Limited V/s…