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“strategic investment”

DisallowancesSection 14ASection 14A426 judgments

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

In the result, the appeal filed by the Assessee is allowed

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

some instrument which could have yielded return/ profit in the revenue projection made at the time of issuance of shares, without understanding that strategic investments and risks are undertaken for appreciation of capital and larger returns and not simply dividend and interest. Any businessman or entrepreneur, visualise the business based

BOMBAY MINERALS LIMITED,KHAMBHALIA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue

ITA 5410/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

Assessee reported exempt income of ₹53,83,764/- but offered no reported exempt income of but offered no suo motu disallowance, contending that its strategic invest disallowance, contending that its strategic investments in 'Orient ments in 'Orient Abrasives Ltd.' were funded entirely by its own interest-free capital Abrasives ... interest and reserves (amounting to ₹116.86 Crores). The Assessing Officer and reserves (amounting to 116.86 Crores). The Assessing Officer (AO) rejected this "strategic investment" plea, citing the Hon’ble (AO) rejected this "strategic investment" plea, citing the Hon’ble (AO) rejected this "strategic investment" plea, citing the Hon’ble Bombay

DY. COMMISSIONER OF INCOME TAX, CENTRAL CICLE-3(3), MUMBAI, MUMBAI vs. BOMBAY MINERALS LIMITED, GUJARAT

In the result, appeal of the Revenue

ITA 5409/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

Assessee reported exempt income of ₹53,83,764/- but offered no reported exempt income of but offered no suo motu disallowance, contending that its strategic invest disallowance, contending that its strategic investments in 'Orient ments in 'Orient Abrasives Ltd.' were funded entirely by its own interest-free capital Abrasives ... interest and reserves (amounting to ₹116.86 Crores). The Assessing Officer and reserves (amounting to 116.86 Crores). The Assessing Officer (AO) rejected this "strategic investment" plea, citing the Hon’ble (AO) rejected this "strategic investment" plea, citing the Hon’ble (AO) rejected this "strategic investment" plea, citing the Hon’ble Bombay

BOMBAY MINERALS LIMITED,KHAMBHALIYA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue for AY 2016-17 is\ndismissed whereas appeal of the assessee for AY 2016-17 is partly\nallowed and appeal for AY 2018-19 is dismissed

ITA 5408/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17
Section 143(3)Section 14ASection 35Section 35(1)(i)Section 36(1)(iii)

issue in dispute are that the Assessee\nreported exempt income of ₹53,83,764/- but offered no suo motu\ndisallowance, contending that its strategic investments in 'Orient\nAbrasives Ltd.' were funded entirely by its own interest-free capital\nand reserves (amounting to *116.86 Crores). The Assessing Officer\n(AO) rejected ... this "strategic investment" plea, citing the Hon'ble\nBombay Minerals Ltd. 5\nITA No. 5408, 5409 & 5410/MUM/2025\nSupreme Court's ruling in Maxopp Investment Ltd. v. CIT, and\napplied Rule 8D to disallow ₹1,08,53,323/- (Interest) and\n₹46,51,891/- (Administrative Expenses). According to the Assessing\nOfficer

NUVAMA WEALTH MANAGEMENT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), MUMBAI

In the result, both the appeals of the assessee are

ITA 6761/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16
Section 10(34)Section 14ASection 14A(2)

contended that the investments trade in the wholly owned subsidiary/associate companies is purely and solely for the business purpose and in the nature of strategic investment. The assessee has made the disallowance u/s 14A as under: (i) (ii) Rs.50000/- on account of salary of a mid level employee handling investments

NUVAMA WEALTH MANAGEMENT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), MUMBAI

In the result, both the appeals of the assessee are

ITA 6760/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Feb 2026AY 2014-15

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal ()

For Respondent: Shri Ravikant Pathak
Section 10(34)Section 14ASection 14A(2)

contended that the investments trade in the wholly owned subsidiary/associate companies is purely and solely for the business purpose and in the nature of strategic investment. The assessee has made the disallowance u/s 14A as under: (i) (ii) Rs.50000/- on account of salary of a mid level employee handling investments

ACIT-6(1)(1),MUMBAI, MUMBAI vs. M/S ESSAR POWER LTD, MUMBAI

In the result, the appeal filed by the Revenue stands dismissed

ITA 8222/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Feb 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 115JSection 143(3)Section 14A

Tribunal’s orders in assessee’s own case, recorded a 6 Essar Power Ltd., categorical finding that the investments made by the assessee were strategic investments in subsidiary companies and that the assessee had not earned any exempt income during the relevant previous year. 9. The learned CIT(A) specifically

BESMAK COMPONENTS P LTD,KANCHIPURAM vs. ACIT,CORPORATE CIRCLE 1(2), CHENNAI

The appeal of the assessee is allowed

ITA 3373/CHNY/2025[2016-17]Status: DisposedITAT Chennai06 Feb 2026AY 2016-17

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3373/Chny/2025 निर्धारण वर्ष / Assessment Year: 2016-17 Besmak Components P. Ltd., Plot No.A-45, Sipcot Industrial Vs. Growth Centre, Sriperumbudur, Oragadam, Kanchipuram District – 602 105. Pan: Aaacb 2531N (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से /Respondent By The Asst. Commissioner Of Income Tax, Corporate Circle-1(2), Chennai. (प्रत्यर्थी/Respondent) Mr. M.K. Rangaswamy, C.A Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 28.01.2026 घोषण की तारीख /Date Of Pronouncement 06.02.2026 आदेश / Order Per Padmavathy.S, A.M: This Appeal By The Assessee Is Against The Order Of The Commissioner Of Income Tax (Appeals), Addl./Jcit(A), Agra (In Short "Faa") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") Dated 09.06.2025 For

Section 14ASection 250

received the exempt income. The Ld. AR also submitted that the investment made by the assessee in CNH Moulds Pvt. Ltd. is a strategic investment since the company is a 100% wholly owned subsidiary of the assessee. 5. We heard the parties and perused the material on record. During ... those investments which have earned exempt income have been considered. The AO also rejected the submission the investment made in 100% subsidiary is a strategic investment and has not resulted in any exempt income. From the perusal of the orders of the lower authorities we notice that the disallowance

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

ITA 2552/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

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

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

Assessee that no disallowance could be made under Section 14A of the Act since exempt income was earned by the Assessee from the strategic investment made by the Assessee in the joint venture Assessment Year 2016-2017 company. The Learned CIT(A) relied upon the judgment

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

ITA 2093/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

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

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

Assessee that no disallowance could be made under Section 14A of the Act since exempt income was earned by the Assessee from the strategic investment made by the Assessee in the joint venture Assessment Year 2016-2017 company. The Learned CIT(A) relied upon the judgment

AMBUJA CEMENTS LIMITED,MUMBAI vs. PCIT, MUMBAI-3, MUMBAI

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sourabh Soparkar, AR (virtually appear)For Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)
Section 143(3)Section 14ASection 263

made a suo motu disallowance of only Rs.1,82,21,8671/-under section 14A of the Act. It was noticed that the assessee had Strategic Investments of Rs.11813.76 cr., on which no proportionate disallowance was computed as per Rule 8D. The Pr.CIT opined that correct disallowance should have been Rs.118.13 ... during the year but had made a disallowance of only Rs.1.82 cr. under section 14A of the Act. Further, the assessee had made strategic investments amounting to Rs 11,813.76 cr., on which proportionate expenditure was clearly attributable under section 14A read with Rule Page | 8 ITA No. 3474/Mum/2025

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

ITA 831/HYD/2024[2018-19]Status: DisposedITAT Hyderabad04 Feb 2026AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 115JSection 14ASection 14A(3)

invoked to disallow the expenditure. In response, the assessee company stated that all the investments made by the assessee company are long term strategic investments in the group companies only and no expenses had been incurred for maintaining the portfolio of the investment or for holding the same. The purpose

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

ITA 830/HYD/2024[2018-19]Status: DisposedITAT Hyderabad04 Feb 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 115JSection 14ASection 14A(3)

invoked to disallow the expenditure. In response, the assessee company stated that all the investments made by the assessee company are long term strategic investments in the group companies only and no expenses had been incurred for maintaining the portfolio of the investment or for holding the same. The purpose

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

ITA 829/HYD/2024[2017-18]Status: DisposedITAT Hyderabad04 Feb 2026AY 2017-18

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 115JSection 14ASection 14A(3)

invoked to disallow the expenditure. In response, the assessee company stated that all the investments made by the assessee company are long term strategic investments in the group companies only and no expenses had been incurred for maintaining the portfolio of the investment or for holding the same. The purpose

ACIT., CIRCLE-5(1), HYDERABAD vs. ENGENRIN HYDRO POWER LIMITED, HYDERABAD

In the result, all the four appeals filed by the Revenue are dismissed

ITA 828/HYD/2024[2016-17]Status: DisposedITAT Hyderabad04 Feb 2026AY 2016-17

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 115JSection 14ASection 14A(3)

invoked to disallow the expenditure. In response, the assessee company stated that all the investments made by the assessee company are long term strategic investments in the group companies only and no expenses had been incurred for maintaining the portfolio of the investment or for holding the same. The purpose

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. VASCON ENGINEERS LIMITED, PUNE

In the result, Appeal of the Revenue is Dismissed

ITA 1105/PUN/2025[2013-14]Status: DisposedITAT Pune27 Jan 2026AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1105/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 Deputy Commissioner Vs. Vascon Engineers Limited, Of Income Tax, Pune. Vascon Weikfileld Chamber, Opposite Hyatt Hotel, Nagar Road, Pune – 411014. Pan: Aaacv1249F Appellant/ Revenue Respondent /Assessee Assessee By Shri Ajit Tolani & Darpan Kriplani Revenue By Smt. Indira R. Adakil – Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 05.02.2025Emanating From The Assessment Order Under Section 143(3) R.W.S 144C(3/4) Of The Act, 1961 Dated 23.01.2017 For The A.Y.2013-14. The Revenue Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 14ASection 14A(2)Section 250Section 36(1)(u)

under Rule 8D(2)(iii) on account of administration and general expenses being 0.5% of the average value of investments, investments considered to be 'strategic investment' by the Appellant, if any. need to be excluded for computing the disallowance under the above referred rule. For holding the above, in addition ... Since the Appellant has already made a suo-moto disallowance the same should be considered while computing the disallowance. In absence of any such strategic investments which ought to be excluded, the disallowance made by the AO would stand. The AO is directed to recompute the disallowance

LADDERUP FINANCE LIMITED,MUMBAI vs. CIRCLE 14(1)(1), MUMBAI, MUMBAI

In the result the appeal filed by the assessee is allowed

ITA 7404/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Jan 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarladderup Finance Circle 14(1)(1), Limited Mumbai 1St Floor Hallmark Vs. Aayakar Bhavan, Business Plaza, Mumbai-400 020 Gurunanak Hospital Road, Bandra (East), Mumbai- 400051 Pan/Gir No. Aaacl0882G (Applicant) (Respondent) Assessee By Shri Rushabh Mehta Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 27.01.2026

Section 10(34)Section 10(38)Section 111ASection 115JSection 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 271(1)(c)

amounting to Rs. 12,39,367/- under Rule 8D(2)(iii) without appreciating the fact that no disallowance was called for in relation to strategic investments. 4. (a) Without prejudice to disallowance made u/s. 14A r.w.r 8D, the ld. CIT(A) erred in facts and law in upholding the addition

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1084/HYD/2024[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19
For Appellant: Shri Sourabh Soparkar, Advocate Represented by Department : Dr. Narendra Kumar NFor Respondent: Dr. Narendra Kumar Naik, CIT-DR Date of Conclusion of Hearing : 11/11/2025
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

thereof. 3.2 In the instant case the appellant had invested in subsidiary cement companies as part of expansion of business which are strategic investments and not for the purpose of earning exempt income. As on 31.03.2017 Investment in Pioneer Cement Industries Ltd was Rs.58.32 crores. Pioneer was incorporated

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1083/HYD/2024[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

thereof. 3.2 In the instant case the appellant had invested in subsidiary cement companies as part of expansion of business which are strategic investments and not for the purpose of earning exempt income. As on 31.03.2017 Investment in Pioneer Cement Industries Ltd was Rs.58.32 crores. Pioneer was incorporated

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

were not made from borrowed funds but were made out of internal accruals 8.5 Without prejudice to the above, the AO erred in including strategic investments in wholly owned subsidiaries while computing the disallowance tender Rule 8D. The AO ought to have appreciated that strategic investments in wholly owned subsidiaries ... have not earned any dividend income and these subsidiaries have since merged with the Company. Therefore, such strategic investments should be excluded while considering investments for computing disallowance under Rule 8D. 8.6 Without prejudice to the above, the All-erred in disallowing an amount of Rs. 31,35,846/- which

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