South Indian Bank Ltd. v. CIT

438 ITR 1Supreme Court of India2021#132 most cited

What is South Indian Bank Ltd. v. CIT authority for?

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

508

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2011 to 2026.

Also referred to as

South Indian Bank Ltd. v. CIT · South Indian Bank · 438 ITR 1 · Section 14A · disallowance of interest expenditure · mixed fund theory · non-interest bearing funds · tax-free investments · exempt income · Section 8D · expenditure relating to exempt income

Also reported as

130 Taxmann.com 178283 Taxmann 17810 SCC 153228 CTR 440

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 8DSection 153ASection 36(1)(viia)Section 36(1)(vii)Section 36(1)(iii)
Read the full judgment

Issues it is cited on

section 10(33)section 80absection 10(15)section 80msection 54esection 14a(1)section 36(1)(viii)section 54ecsection 14a(2)section 36(1)(vii)disallowance under section 14adisallowance of interest expenditure

Judgments citing South Indian Bank Ltd. v. CIT

Pr. Commissioner of Income Tax, Delhi 1 vs. M/S Amadeus India Pvt. Ltd

Appeal is dismissed being covered

ITA/511/2025HC Delhi10 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 14Section 14ASection 260A

…ITA 511/2025 Page 1 of 12 $~17 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 10.10.2025 + ITA 511/2025 PR. COMMISSIONER OF INCOME TAX, DELHI 1.....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shairwal, Mr. Akshat Singh, JSCs and Mr. Gaoraang Ranjan and Ms Harshita Kotru, Advs. versus M/S AMADEUS INDIA PVT. LTD. .....Respondent Through: Mr. Mayank Nagi and Mr. Tarun Singh, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE…

Gujarat State Petronet Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

The appeal of the assessee is partly allowed

ITA 992/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 143(3)Section 144Section 14ASection 14A(2)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH, AHMEDABAD BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER Assessment Year: 2016-17 Gujarat State Petronet Deputy Commissioner of Limited Income Tax, Wing “A”, Plot No.E-18, Gandhinagar Circle, GSPL Bhavan, Block No.14, GIDC Electronics Estate, Room No.405, Vs. 4th Floor, Udhyog Bhavan, Nr. K-7, Circle, Sector – 26, Gandhinagar – 382 028. Sector – 11, (Gujarat) Gandhinagar – 382 028. [PAN – AABCG 1812 E] (Gujarat) (Appellant) (Respondent) Assessee by Shri S. N. Soparkar, Sr. Advocate Revenue by Shri Alpesh Parmar,…

JCIT OSD Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2260/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)
Section 143(3)Section 144Section 14A

…t of the Punjab and Haryana High Court in State Bank of Patiala case also failed. Thus, though law in this respect has been clarified hereinabove. 8.3 The same view was followed by the hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The hon'ble High Court of Delhi in the case of PCIT vs. Punjab National Bank reported in [2022] 140 taxmann.com 131 (Delhi), had the occasion to consider a similar issue and it held as follows:- "19. The Supreme Court in this judgment uphald the decision of the High Court of Punjab and Haryana arising under section 14A of the Act with respect…

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2259/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 14A

…he treatment of the Punjab and Haryana High Court in State Bank of Patiala also failed. Though law in this respect has been clarified hereinabove. 8.3 The same view was followed by the hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The hon'ble High Court of Delhi in the case of PCIT vs. Punjab National Bank reported in [2022] 140 taxmann.com 131 (Delhi), had the occasion to consider a similar issue and it held as follows:- "19. The Supreme Court in this judgment upheld the decision of the High Court of Punjab and Haryana arising under section 14A of the Act with respect…

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2258/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)
Section 143(3)Section 144Section 14A

…atment of the Punjab and Haryana High Court in State Bank of Patiala case also, though such claim has been clarified in HDFC Bank Limited, Mumbai. 8.3 The same view was followed by the hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The hon'ble High Court of Delhi in the case of PCIT vs. Punjab National Bank reported in [2022] 140 taxmann.com 131 (Delhi), had the occasion to consider a similar issue and it held as follows:- "19. The Supreme Court in this judgment upheld the decision of the High Court of Punjab and Haryana arising under section 14A of the Act with respect…

Hdfc Bank Limited, Mumbai vs. DCIT - 2 (3) (1), Mumbai

In the result, both the above stated appeals of the

ITA 1573/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)
Section 143(3)Section 144Section 14A

…judgment of the Punjab and Haryana High Court in State Bank of Patiala case also, that though law in this respect has been clarified hereinabove. 8.3 The same view was followed by the hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC).The hon'ble High Court of Delhi in the case of PCIT vs. Punjab National Bank reported in [2022] 140 taxmann.com 131 (Delhi), had the occasion to consider a similar issue and it held as follows:- “19. The Supreme Court in this judgment upheld the decision of the High Court of Punjab and Haryana arising under Section 14A of the Act with respect…

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax - 2 (3) (1), Mumbai

ITA 1555/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)
Section 143(3)Section 144Section 14A

…e judgment of Punjab and Haryana High Court in State Bank of Patiala case, also failed, though law in this respect has been clarified hereinabove. 8.3 The same view was followed by the hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The hon'ble High Court of Delhi in the case of PCIT vs. Punjab National Bank reported in [2022] 140 taxmann.com 131 (Delhi), had the occasion to consider a similar issue and it held as follows:- "19. The Supreme Court in this judgment upheld the decision of the High Court of Punjab and Haryana arising under section 14A of the Act with respect…

Kapil Foods and Structures Private Limited, Warangal vs. DCIT., Circle-3(1), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 206/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Sept 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/S. Kapil Foods & Structures Dy. Commissioner Of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. Pan: Aacck2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 26/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By M/S. Kapil Foods & Structures Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Both Dated 09.12.2024 For The A.Ys. 2016-17 & 2017-18. Since The Issues Involved In Both These Appeals Are Identical & Belong To The Same Assessee, One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 36(1)(iii)

…C), wherein it was held that if interest-free funds are sufficient to cover investments, presumption is that investments are from such funds. The assessee also relied on the decision of Hon'ble Supreme Court in the case of South Indian Bank Ltd. v. CIT (2021) 438 ITR 1 (SC), wherein the same principle was reiterated. Accordingly, it was argued that no disallowance could be made u/s 36(1)(iii) of the Act. 8. Per contra, the Learned Department Representative (“Ld. DR”) strongly supported the orders of lower authorities. It was submitted that the assessee has paid interest on advances refunded on cancellation of pr…

Kapil Foods and Structures Private Limited, Warangal vs. DCIT., Circle-3(1), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 205/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Sept 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.205 & 206/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2016-17 & 2017-18) M/S. Kapil Foods & Structures Dy. Commissioner Of Income Tax, Vs. Circle-3(1), Hyderabad. Pvt. Ltd., Warangal. Pan: Aacck2614F (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 26/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By M/S. Kapil Foods & Structures Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Both Dated 09.12.2024 For The A.Ys. 2016-17 & 2017-18. Since The Issues Involved In Both These Appeals Are Identical & Belong To The Same Assessee, One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 36(1)(iii)

…C), wherein it was held that if interest-free funds are sufficient to cover investments, presumption is that investments are from such funds. The assessee also relied on the decision of Hon'ble Supreme Court in the case of South Indian Bank Ltd. v. CIT (2021) 438 ITR 1 (SC), wherein the same principle was reiterated. Accordingly, it was argued that no disallowance could be made u/s 36(1)(iii) of the Act. 8. Per contra, the Learned Department Representative (“Ld. DR”) strongly supported the orders of lower authorities. It was submitted that the assessee has paid interest on advances refunded on cancellation of pr…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…s not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. 015 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were sufficient to meet to its investment, it will be presumed t…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

…s not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. 015 ITA No. 1090, 1097 ΤΟ 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were sufficient to meet to its investment, it will be presumed t…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were sufficient to meet to its investment, it will be presumed…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were sufficient to meet to its investment, it will be presumed…

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

…not come to the aid of the appellant. 34. In para 17.2 of the common order dated 13.05.2022, the Coordinate Bench, relied on decisions in the case title as CIT vs. Reliance Industries limited (2019) 410 ITR 466 and in Sought Indian Bank limited case, (2021) 438 ITR 1. o15 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 35. In the same paragraph, the ratio decidendi recorded in Reliance Industries Limited case was relied on that where there is finding of fact that interest free funds available to the assessee were sufficient to meet to its investment, it will be presumed…

Raj Kumar Goenka, Kolkata vs. DCIT, Circle 11(1), Kolkata

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

ITA 815/KOL/2025[2020-2021]Status: DisposedITAT Kolkata26 Aug 2025AY 2020-2021

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 234ASection 250Section 57

…case of the entities which were related to the assessee, either no interest was charged or NIL interest was charged. It was submitted by the Ld. AR that in view of the decision of the Hon'ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 10 SCC 153 (SC), where the funds come out of a mixed bag bearing interest free as well interest bearing funds, the right of appropriation is to the assessee and the copy of the order was also enclosed in which it has been held as under: “The proportionate disallowance of interest is not warranted under S. 14-A for investments made in tax-free bonds/securitie…

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)

…g the judgment of the Punjab and Haryana High Court in State Bank of Patiala also fail, though law in this respect has been clarified hereinabove.” 7. The same view was followed by the Hon‟ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The relevant findings read as follows:- “23. It would now be appropriate to advert in some detail to Maxopp Investment Ltd. v. CIT10. This case interestingly is relied by both sides‟ counsel. Writing for the Bench, Justice Dr. A.K. Sikri noted the objective for incorporation of Section 14A in the Act in the following words: - “3…………. The purp…

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)

…g the judgment of the Punjab and Haryana High Court in State Bank of Patiala also fail, though law in this respect has been clarified hereinabove.” 7. The same view was followed by the Hon‟ble Supreme Court in the case of South Indian Bank Ltd. vs. CIT [2021] 438 ITR 1 (SC). The relevant findings read as follows:- “23. It would now be appropriate to advert in some detail to Maxopp Investment Ltd. v. CIT10. This case interestingly is relied by both sides‟ counsel. Writing for the Bench, Justice Dr. A.K. Sikri noted the objective for incorporation of Section 14A in the Act in the following words: - “3…………. The purp…

The Dy.CIT, Central Circle-1, Vadodara vs. Pawan Edifice Pvt. Ltd., Vadodara

Appeals are partly allowed for

ITA 529/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ “C”, अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD सुश्री सुचित्रा काम्बले, न्यायिक सदस्य एवं श्री मकरंद वसंत महादेवकर, लेखा सदस्य के समक्ष । BEFORE Ms SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं/ITA Nos.477-478/Ahd/2023 निर्धारण वर्ष / Assessment Years : (2013-14 & 2014-15) Pawan Edifice Pvt. Ltd., 224, Golden Trade Centre, Nr. S.T Depot, Vadodara-390002. बनाम / v/s. The Deputy Commissioner of Income Tax, Circle-2(1)(2), Vadodara. स्थायी लेखा सं./PAN: AADCS3122R And आयकर अपील सं/ITA No.529/Ahd/2023 न…

Pawan Edifice Pvt. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

ITA 477/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ “C”, अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD सुश्री सुचित्रा काम्बले, न्यायिक सदस्य एवं श्री मकरंद वसंत महादेवकर, लेखा सदस्य के समक्ष । BEFORE Ms SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं/ITA Nos.477-478/Ahd/2023 निर्धारण वर्ष / Assessment Years : (2013-14 & 2014-15) Pawan Edifice Pvt. Ltd., 224, Golden Trade Centre, Nr. S.T Depot, Vadodara-390002. बनाम / v/s. The Deputy Commissioner of Income Tax, Circle-2(1)(2), Vadodara. स्थायी लेखा सं./PAN: AADCS3122R And आयकर अपील सं/ITA No.529/Ahd/2023 न…

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…