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“disallowance under section 14A”

DisallowancesSection 14ASection 14A2,288 judgments

The decision most relied on for disallowance under section 14A is CIT v. Reliance Petroproducts Pvt. Ltd. (322 ITR 158), cited in 2,228 judgments on BharatTax.

Leading authorities on disallowance under section 14A

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

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.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

ACIT v. Vireet Investment Pvt. Ltd.
165 ITD 27 · 2017 · ITAT
882
citing judgments

No disallowance under section 14A can be made while computing book profits under section 115JB unless the expenditure is debited to the profit and loss account and satisfies clause (f) of Explanation 1 to section 115JB(2).

Judgments citing disallowance under section 14A

Tejas Networks Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 468/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

Noida units. 4.1 Disallowance under Rule 8D read with Section 14A 5.1 The learned AO erred in making an additional disallowance under section 14A read with Rule 8D(2)(ii) amounting to Rs. 98,99,166 on the contention that the appellant has earned exempt income in the nature ... account of diversion of business funds to the investments and hence interest on such funds is partially attributable to such investments which are disallowable under section 14A of the Act. 5.3 the learned AO erred in not appreciating the fact that the secured loans were borrowed solely for the purpose

Asst.C.I.T., Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 296/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

Noida units. 4.1 Disallowance under Rule 8D read with Section 14A 5.1 The learned AO erred in making an additional disallowance under section 14A read with Rule 8D(2)(ii) amounting to Rs. 98,99,166 on the contention that the appellant has earned exempt income in the nature ... account of diversion of business funds to the investments and hence interest on such funds is partially attributable to such investments which are disallowable under section 14A of the Act. 5.3 the learned AO erred in not appreciating the fact that the secured loans were borrowed solely for the purpose

DCIT, Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1119/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

Noida units. 4.1 Disallowance under Rule 8D read with Section 14A 5.1 The learned AO erred in making an additional disallowance under section 14A read with Rule 8D(2)(ii) amounting to Rs. 98,99,166 on the contention that the appellant has earned exempt income in the nature ... account of diversion of business funds to the investments and hence interest on such funds is partially attributable to such investments which are disallowable under section 14A of the Act. 5.3 the learned AO erred in not appreciating the fact that the secured loans were borrowed solely for the purpose

Dy CIT -CC-8(1), Mumbai vs. M/S. Niku Mercantile P. Ltd, Mumbai

In the result, the present appeal by the Department stands dismissed

ITA 1040/MUM/2021[2013-14]Status: DisposedITAT Mumbai04 Feb 2022AY 2013-14

Bench: Shri Shamim Yahya, Am & Before Shri Rahul Chaudhary, Jm आयकर अपील सं/ I.T.A. No.1040/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2013-14) Dy. Commissioner Of Income बिधम/ M/S Niku Mercantile Private Tax, Central Circle - 8(1) Limited, Vs. Room No. 656, 6Th Floor, 2Nd Floor, Dhanraj Mahal, Aayakar Bhavan, M.K. Road, Csm Marg, Colaba, Mumbai – 400020 Mumbai - 400001 Pan : Aaacn6871F (अपीलाथी /Appellant) (प्रत्यथी) / Respondent) .. Revenue By: Shri C.T. Mathews, Dr Assessee By: None सुनवाई की तारीख / Date Of Hearing: 01/02/2022 घोषणा की तारीख /Date Of Pronouncement: 04/02/2022

For Appellant: NoneFor Respondent: Shri C.T. Mathews, DR
Section 143(3)Section 14ASection 14A(2)Section 250

which was exempt, however, no expenses were allotted to the earning of exempt income. Accordingly, the Assessee was asked to show-cause why disallowance under Section 14A of the Act should not be made. In response to the aforesaid show-cause notice, the Assessee filed reply contending that the provisions ... 14A of the Act were not applicable to the Assessee and in alternative, raised the ground that the AO erred in determining total disallowance under Section 14A of the Act at INR 3,67,69,856/- as against exempt dividend income of INR.26,91,038/-. It is the aforesaid alternative

M/S Robert Bosch Engineering and Business Solutions Private Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by assessee stands allowed as indicated above and the appeal filed by revenue stands dismissed

ITA 608/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Feb 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 608/Bang/2016 Assessment Year : 2011-12 M/S. Robert Bosch The Deputy Engineering & Business Commissioner Of Solutions Pvt. Ltd., Income Tax, #123, Industrial Layout, Large Tax Payers Unit, Hosur Road, Koramangala, Circle 1, Bangalore – 560095. Vs. Bangalore. Pan: Aaacr7108R Appellant Respondent & It(Tp)A No. 445/Bang/2016 Assessment Year : 2011-12 (By Revenue) : Shri Percy Padiwala, Sr. Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 20-12-2021 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Final Assessment Order Dated 28.01.2016 By The Ld.Dcit, Ltu, Circle -1, Bangalore U/S. 143(3) R.W.S. 144C Of The Act For Assessment Year 2011-12. In Revenue’S Appeal, The Following Grounds Are Raised. “1. The Directions Of Drp Is Opposed To Law & Facts Of The Case.

Section 10ASection 143(3)Section 144CSection 14ASection 80J

invoked the provisions of Rule 8D of the Income Tax Rules, 1962. 8. The Learned AO and Learned DRP erred in making additional disallowance under section 14A when the Appellant himself had disallowed actual expenditure incurred in earning exempt income. 9. The Learned AO and Learned DRP erred in making ... additional disallowance under section 14A by invoking rule 8D of the Income Tax Rules, 1962, without demonstrating as to how the claim of the Appellant regarding identification/allocation of expenses relatable to income not chargeable to tax is incorrect/insufficient. 10. The Learned DRP without examining the method and manner of computation

DCIT, Bangalore vs. M/S Robert Bosch Engineering & Business Solutions Private Limited, Bangalore

In the result, the appeal filed by assessee stands allowed as indicated above and the appeal filed by revenue stands dismissed

ITA 445/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Feb 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 608/Bang/2016 Assessment Year : 2011-12 M/S. Robert Bosch The Deputy Engineering & Business Commissioner Of Solutions Pvt. Ltd., Income Tax, #123, Industrial Layout, Large Tax Payers Unit, Hosur Road, Koramangala, Circle 1, Bangalore – 560095. Vs. Bangalore. Pan: Aaacr7108R Appellant Respondent & It(Tp)A No. 445/Bang/2016 Assessment Year : 2011-12 (By Revenue) : Shri Percy Padiwala, Sr. Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 20-12-2021 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Final Assessment Order Dated 28.01.2016 By The Ld.Dcit, Ltu, Circle -1, Bangalore U/S. 143(3) R.W.S. 144C Of The Act For Assessment Year 2011-12. In Revenue’S Appeal, The Following Grounds Are Raised. “1. The Directions Of Drp Is Opposed To Law & Facts Of The Case.

Section 10ASection 143(3)Section 144CSection 14ASection 80J

invoked the provisions of Rule 8D of the Income Tax Rules, 1962. 8. The Learned AO and Learned DRP erred in making additional disallowance under section 14A when the Appellant himself had disallowed actual expenditure incurred in earning exempt income. 9. The Learned AO and Learned DRP erred in making ... additional disallowance under section 14A by invoking rule 8D of the Income Tax Rules, 1962, without demonstrating as to how the claim of the Appellant regarding identification/allocation of expenses relatable to income not chargeable to tax is incorrect/insufficient. 10. The Learned DRP without examining the method and manner of computation

Hathway Investment Pvt Ltd., Mumbai vs. Asst CIT Circle-12 (2)(2), Mumbai

In the result, appeal of the assessee is partly allowed, in terms aforesaid

ITA 7106/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Jan 2022AY 2012-13
For Appellant: Sh. Vijay MehtaFor Respondent: Ms. Smitha Nair
Section 143(3)Section 14A

आअसं. 7106/मुं/2019 (िन.व. 2012-13) 2. The assessee in appeal has raised multiple grounds assailing the disallowance under section 14A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 3. Sh. Vijay Mehta appearing on behalf of the assessee submitted at the outset that ... only ground he would be pressing is ground no.3 and other grounds challenging disallowance under section 14A of the Act are not pressed. 4. Ground No.3 of the appeal reads as under: “3. Without prejudice to what has been stated above, the learned CIT-A ought to have restricted disallowance

DCIT, 4(1)(1), Mumbai vs. Icici Securities Primary Dealership Ltd, Mumbai

In the result, the appeal of the Revenue and the assessee is dismissed

ITA 2695/MUM/2019[2002-03]Status: DisposedITAT Mumbai31 Jan 2022AY 2002-03

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantआअसं. 2695/मुं/2019(िन.व. 2002-03) Dcit-4(1)(1), Room No. 640, 6Th Floor, Aayakar Bhavan, M.K. Road, Mumbai-400020. ...... अपीलाथ" /Appellant बनाम Vs. Icici Securities Primary Dealership Ltd. 4Th Floor, Icici Centre, H.T. Parekh Marg, Churchgate, Mumbai-400020 Pan: Aaaci0995H ..... "ितवादी/Respondent आअसं. 3072/मुं/2019(िन.व. 2002-03) Icici Securities Primary Dealership Ltd. 4Th Floor, Icici Centre, H.T. Parekh Marg, Churchgate, Mumbai-400020 Pan: Aaaci0995H ..... अपीलाथ" /Appellant बनाम Vs. Dcit-4(1)(1), Room No. 640, 6Th Floor, Aayakar Bhavan, M.K. Road, Mumbai-400020. ...... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Sh. J. Sarvanan, Dr "ितवादी "ारा/Respondent By : Sh. Krupa Gandhi, Ar सुनवाई की ितिथ/ Date Of Hearing : 27/01/2022 घोषणा की ितिथ/ Date Of Pronouncement : 31/01/2022

For Appellant: Sh. J. Sarvanan, DRFor Respondent: Sh. Krupa Gandhi, AR
Section 14A

that the disallowance @5% u/s 14A out of indirect expenses.” 4. The asssessee in appeal has also raised single issue with respect to disallowance under section 14A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). The ground raised by the asssessee in appeal reads as under ... second round held that in so far as exempt income earned from shares held as stock-in-trade, no disallowance under section 14A is called for and as regards shares held other than stock-in-trade, the CIT(A) held that indirect expenses under section 14A

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 146/BANG/2021[2017-18]Status: DisposedITAT Bangalore31 Jan 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

heard rival submissions and perused the material on record. We find that the assessee had not received any exempt income therefore, no disallowance under. section 14A is to be made. We have also carefully examined the computation of income and the Balance Sheet and find that the assessee ... made. Therefore, we are of the view that when the assesee had not received any exempt income, no disallowance under section 14A can be made. We accordingly set aside the order of the CIT(A) and delete the additions made invoking the provisions of section 14A

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 145/BANG/2021[2015-16]Status: DisposedITAT Bangalore31 Jan 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

heard rival submissions and perused the material on record. We find that the assessee had not received any exempt income therefore, no disallowance under. section 14A is to be made. We have also carefully examined the computation of income and the Balance Sheet and find that the assessee ... made. Therefore, we are of the view that when the assesee had not received any exempt income, no disallowance under section 14A can be made. We accordingly set aside the order of the CIT(A) and delete the additions made invoking the provisions of section 14A

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 144/BANG/2021[2014-15]Status: DisposedITAT Bangalore31 Jan 2022AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

heard rival submissions and perused the material on record. We find that the assessee had not received any exempt income therefore, no disallowance under. section 14A is to be made. We have also carefully examined the computation of income and the Balance Sheet and find that the assessee ... made. Therefore, we are of the view that when the assesee had not received any exempt income, no disallowance under section 14A can be made. We accordingly set aside the order of the CIT(A) and delete the additions made invoking the provisions of section 14A

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 143/BANG/2021[2013-14]Status: DisposedITAT Bangalore31 Jan 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

heard rival submissions and perused the material on record. We find that the assessee had not received any exempt income therefore, no disallowance under. section 14A is to be made. We have also carefully examined the computation of income and the Balance Sheet and find that the assessee ... made. Therefore, we are of the view that when the assesee had not received any exempt income, no disallowance under section 14A can be made. We accordingly set aside the order of the CIT(A) and delete the additions made invoking the provisions of section 14A

Universal Stock Brokers P.Ltd, Ghaziabad vs. DCIT, Circle-27(1), New Delhi

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

ITA 2495/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2022AY 2013-14

Bench: Shri N. K. Billaiyaa N D Shri Amit Shukla(Through Video Conferencing)

For Appellant: Shri Tarun Rohatgi, C. AFor Respondent: Shri Kumar Pranav, Sr. DR
Section 143(3)Section 14A

earned share profit of Rs.2,13,45,332/- and brokerage income of Rs.12,92,152/-.The assessee for the purpose of calculation of disallowance under Section 14A of the Act had suo moto disallowed Rs.2,58,386/-, working of which was given as under:- Direct Expenses Related to Turnover Amount ... salary to the staff and 1% of the other expenses would be reasonable for 7 attributing the disallowance for the purpose of disallowance under Section 14A of the Act. Thus, the Assessing Officer is directed to be compute disallowance out of Employees expenses and other expenses

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

ITA 276/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Jan 2022AY 2014-15

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

For Appellant: Shri Rahul PrabhakarFor Respondent: Shri P.C. Maurya, CIT
Section 115JSection 14A

assessee-company is tonnage tax company whatever income earned which is exempt would be automatically enhancing the tonnage tax income in case any disallowance under section 14A is made. Thus, there is no tax effect if any disallowance is made. However, the A.O. was not satisfied with the arguments advanced ... years is allowed.” 15 ITA.Nos.1001 & 1002/Del./2016 And ITA.No.276/Del./2017 M/s. Jagson International Ltd., New Delhi. 3.2. So far as the disallowance under section 14A is concerned, the Ld. CIT(A) deleted the addition by observing as under : “4.2. I have given careful consideration to the submissions filed

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

ITA 1002/DEL/2016[2013-14]Status: DisposedITAT Delhi31 Jan 2022AY 2013-14

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

For Appellant: Shri Rahul PrabhakarFor Respondent: Shri P.C. Maurya, CIT
Section 115JSection 14A

assessee-company is tonnage tax company whatever income earned which is exempt would be automatically enhancing the tonnage tax income in case any disallowance under section 14A is made. Thus, there is no tax effect if any disallowance is made. However, the A.O. was not satisfied with the arguments advanced ... years is allowed.” 15 ITA.Nos.1001 & 1002/Del./2016 And ITA.No.276/Del./2017 M/s. Jagson International Ltd., New Delhi. 3.2. So far as the disallowance under section 14A is concerned, the Ld. CIT(A) deleted the addition by observing as under : “4.2. I have given careful consideration to the submissions filed

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

ITA 1001/DEL/2016[2012-13]Status: DisposedITAT Delhi31 Jan 2022AY 2012-13

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

For Appellant: Shri Rahul PrabhakarFor Respondent: Shri P.C. Maurya, CIT
Section 115JSection 14A

assessee-company is tonnage tax company whatever income earned which is exempt would be automatically enhancing the tonnage tax income in case any disallowance under section 14A is made. Thus, there is no tax effect if any disallowance is made. However, the A.O. was not satisfied with the arguments advanced ... years is allowed.” 15 ITA.Nos.1001 & 1002/Del./2016 And ITA.No.276/Del./2017 M/s. Jagson International Ltd., New Delhi. 3.2. So far as the disallowance under section 14A is concerned, the Ld. CIT(A) deleted the addition by observing as under : “4.2. I have given careful consideration to the submissions filed

DCIT-9(3)(2), Mumbai vs. Future Corporate Resources Ltd, Mumbai

In the result, appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 4145/MUM/2019[2015-16]Status: DisposedITAT Mumbai28 Jan 2022AY 2015-16
For Appellant: Dinkle HariyaFor Respondent: Achal Sharma
Section 115JSection 143(2)Section 14A

erred in confirming the disallowance u/s. 14A made by the Assessing Officer of Rs. 6,13,42,833/- on the ground that the disallowance under section 14A r.w. Rule 8D is to be restricted to the extent of dividend income. 1.2 While doing so, the CIT(A) failed to appreciate

Ircon International Ltd., New Delhi vs. Addl.CIT, Special Range- 4, New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 7155/DEL/2017[2013-14]Status: DisposedITAT Delhi28 Jan 2022AY 2013-14

Bench: Sh. A. D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Rakesh Gupta, Adv. &For Respondent: Ms. Meenakshi J. Goswami, CIT(DR)
Section 801ASection 80I

that is why the AO had asked the appellant to explain ITA No. 2401 & Ors 19 M/s. Ircon International Ltd. as to why disallowance under section 14A may not be made. The Ld. Counsel referred to the decision of the Ld. CIT(A) in the case of the appellant

Ircon International Ltd., New Delhi vs. Addl. CIT, Circle-12(2), New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 5460/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Jan 2022AY 2012-13

Bench: Sh. A. D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Rakesh Gupta, Adv. &For Respondent: Ms. Meenakshi J. Goswami, CIT(DR)
Section 801ASection 80I

that is why the AO had asked the appellant to explain ITA No. 2401 & Ors 19 M/s. Ircon International Ltd. as to why disallowance under section 14A may not be made. The Ld. Counsel referred to the decision of the Ld. CIT(A) in the case of the appellant

DCIT, New Delhi vs. M/S. Ircon International Ltd., New Delhi

In the result, the appeal of the assessee on this ground is allowed

ITA 528/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2022AY 2007-08

Bench: Sh. A. D. Jaindr. B. R. R. Kumar

For Appellant: Sh. Rakesh Gupta, Adv. &For Respondent: Ms. Meenakshi J. Goswami, CIT(DR)
Section 801ASection 80I

that is why the AO had asked the appellant to explain ITA No. 2401 & Ors 19 M/s. Ircon International Ltd. as to why disallowance under section 14A may not be made. The Ld. Counsel referred to the decision of the Ld. CIT(A) in the case of the appellant