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“strategic investment”

DisallowancesSection 14ASection 14A426 judgments

The decision most relied on for strategic investment is Maxopp Investment Ltd. v. CIT (402 ITR 640), cited in 1,596 judgments on BharatTax.

Leading authorities on strategic investment

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.

Garware Wall Ropes Ltd. v. ACIT
65 SOT 86 · 2014 · ITAT
74
citing judgments

Disallowance under Section 14A read with Rule 8D(2)(iii) does not apply to long-term investments, including those in subsidiary/group concerns or strategic investments, and such investments should be excluded from the calculation.

Mazagaon Dock Ltd. v. CIT & Excess Profits Tax
34 ITR 368 · 1958 · Supreme Court
57
citing judgments

Investments made by a holding company in its subsidiary can be considered a business activity, allowing related business expenditures to be deducted and not disallowed.

Southern Petro Chemical Industries v. DCIT
3 SOT 157 · 2005 · ITAT
34
citing judgments

Proportionate management expenses are deductible when computing exempt dividend income, as investment decisions are strategic and involve top management.

Gareware Wall Ropes Ltd. v. ACIT
46 Taxmann.com 18 · 2014 · ITAT
22
citing judgments

Strategic investments in wholly-owned subsidiaries are to be excluded when calculating the disallowance under Section 14A, which pertains to expenses incurred in relation to exempt income. This exclusion applies even when these investments are made for holding a controlling stake rather than for earning dividends.

Pr. Commissioner of Income Tax-2 v. Enrich Agro Food Products Pvt. Ltd.
148 Taxmann.com 26 · 2023 · High Court
20
citing judgments

The Delhi High Court confirms that when shares are issued at a premium to investors, the valuation of such shares must be assessed based on established methods like the NAV or DCF method, and the revenue cannot arbitrarily determine the fair market value.

Mahindra & Mahindra Limited v. JCIT
36 SOT 348 · 2010 · ITAT
14
citing judgments

Investments on which no exempt income was received during the year, and investments in subsidiaries considered strategic, are excluded from average investment calculations for determining disallowance of interest expenses.

366 ITR 505 (Bom), CIT v. Reliance Utilities and Power
239 ITR 735 · High Court
13
citing judgments

Investments made by an assessee are presumed to be out of interest-free funds, and no disallowance under Section 14A is warranted if no dividend income is received from such strategic investments.

Judgments citing strategic investment

Assisstant Commissioner of Income Corporate Circle 1-1, Chennai vs. Fl Smidth Private Limited, Kanchipuram

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

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] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) 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

Assisstant Commisioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16

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] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) 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

DCIT, Mumbai vs. Sahyadri Agencies Limited, Moothedath House Arikanniyur

ITA 4257/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jan 2026AY 2018-19

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(2)Section 14ASection 36(1)(iii)

I.T.A. No. 4257/Mum/2025 IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI GIRISH

Rivet Health Club Pvt Ltd, Faridabad vs. ITO Ward - 2(2), Faridabad

In the result, the appeal of the assessee is allowed

ITA 6182/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

Section 142(1)Section 143(2)Section 143(3)Section 68

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

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance_u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

In the result, the Revenue’s appeal in ITA No

ITA 1696/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

M/S Coal India Ltd., Kolkata vs. DCIT, Cir-5(1), Kolkata

ITA 1407/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 1Section 115JSection 250

purpose of making the investment is not applicable and disallowance u/s 14A of the Act is to be made even in the case of strategic investment and also the decision of the Hon'ble jurisdictional High Court in the case of Dhanuka & Sons (supra) relied upon ... only the income from dividend yielding investment is to be considered. However, Hon'ble Supreme Court have given a different finding in respect of strategic investment in which case it has been held that even in respect of investment from which no dividend was earned, could be considered

M/S. Coal India Limited, Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, the Revenue’s appeal in ITA No

ITA 1406/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 623/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance_u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance_u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

Coal India Limited, Kolkata vs. DCIT, Circle - 5(1), Kolkata

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

obtain controlling interest in the said subsidiary companies and hence it could be safely concluded that the same would fall under the ambit of strategic investments. The law now is well settled that for the purpose of computing disallowance U/S.14A r.w. rule 8D of the rules, strategic investments should ... held that while computing the disallowance_u/s.14A the AO while adopting the average value of investment has to exclude the investments which are strategic investments. Hence respectfully following the said decisions we find no disallowances U/S.14A is warranted in the facts and circumstances of the case as admittedly the assessee

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 2037/KOL/2019[2015-16]Status: DisposedITAT Kolkata12 Jan 2026AY 2015-16

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

during the years under consideration dividend incomes were received by the assessee out of which the substantive part of receipt from subsidiaries in which strategic investment had been made many years ago. The assessee in its return of income offered disallowance ... Rules. During the course of the appeal proceedings, however, the assessee recomputed the amount of average investment (other than foreign and strategic investments) for the four assessment years involved arriving at revised average investments figures, e.g., at ₹37,70,781/- for AY 2012-13 and revised amounts to be considered

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1248/KOL/2019[2014-15]Status: DisposedITAT Kolkata12 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA 'C' BENCH, KOLKATA Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1247/KOL/2019[2013-14]Status: DisposedITAT Kolkata12 Jan 2026AY 2013-14

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

during the years under consideration dividend incomes were received by the assessee out of which the substantive part of receipt from subsidiaries in which strategic investment had been made many years ago. The assessee in its return of income offered disallowance ... Rules. During the course of the appeal proceedings, however, the assessee recomputed the amount of average investment (other than foreign and strategic investments) for the four assessment years involved arriving at revised average investments figures, e.g., at ₹37,70,781/- for AY 2012-13 and revised amounts to be considered

D.C.I.T Cir - 10(1), Kolkata vs. M/S Eureka Forbs Ltd, Kolkata

The appeal is dismissed

ITA 1246/KOL/2019[2012-13]Status: DisposedITAT Kolkata12 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 14ASection 250Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C' BENCH, KOLKATA Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5417/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

DCIT VS.THE SARASWAT CO- OPERATIVEBANK LTD.(ITA No.1140&694/Mum/2012;ITA No.5627/Mum/2003& ITA No.1/ Mum/ 2014, dt.31/10/2016) the ITAT, 'E' Bench held that the strategic investment made by the assessee in its subsidiary as well in the other securities which are capable of yielding exempt income i.e. by way of Dividend ... exempt from tax shall be INCLUDED while computing disallowance u/s.14A of the Act AS THE STATUTE DOES NOT GRANT ANY EXEMPTION TO THE STRATEGIC INVESTMENTS WHICH ARE CAPABLE OF YIELDING EXEMPT INCOME TO BE EXCLUDED ITA Nos. 5416 & 5417/Del/2017 along with other cases WHILE COMPUTING DISALLOWANCE U/S.14A

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5416/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

DCIT VS.THE SARASWAT CO- OPERATIVEBANK LTD.(ITA No.1140&694/Mum/2012;ITA No.5627/Mum/2003& ITA No.1/ Mum/ 2014, dt.31/10/2016) the ITAT, 'E' Bench held that the strategic investment made by the assessee in its subsidiary as well in the other securities which are capable of yielding exempt income i.e. by way of Dividend ... exempt from tax shall be INCLUDED while computing disallowance u/s.14A of the Act AS THE STATUTE DOES NOT GRANT ANY EXEMPTION TO THE STRATEGIC INVESTMENTS WHICH ARE CAPABLE OF YIELDING EXEMPT INCOME TO BE EXCLUDED ITA Nos. 5416 & 5417/Del/2017 along with other cases WHILE COMPUTING DISALLOWANCE U/S.14A

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3158/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

DCIT VS.THE SARASWAT CO- OPERATIVEBANK LTD.(ITA No.1140&694/Mum/2012;ITA No.5627/Mum/2003& ITA No.1/ Mum/ 2014, dt.31/10/2016) the ITAT, 'E' Bench held that the strategic investment made by the assessee in its subsidiary as well in the other securities which are capable of yielding exempt income i.e. by way of Dividend ... exempt from tax shall be INCLUDED while computing disallowance u/s.14A of the Act AS THE STATUTE DOES NOT GRANT ANY EXEMPTION TO THE STRATEGIC INVESTMENTS WHICH ARE CAPABLE OF YIELDING EXEMPT INCOME TO BE EXCLUDED ITA Nos. 5416 & 5417/Del/2017 along with other cases WHILE COMPUTING DISALLOWANCE U/S.14A

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3157/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

DCIT VS.THE SARASWAT CO- OPERATIVEBANK LTD.(ITA No.1140&694/Mum/2012;ITA No.5627/Mum/2003& ITA No.1/ Mum/ 2014, dt.31/10/2016) the ITAT, 'E' Bench held that the strategic investment made by the assessee in its subsidiary as well in the other securities which are capable of yielding exempt income i.e. by way of Dividend ... exempt from tax shall be INCLUDED while computing disallowance u/s.14A of the Act AS THE STATUTE DOES NOT GRANT ANY EXEMPTION TO THE STRATEGIC INVESTMENTS WHICH ARE CAPABLE OF YIELDING EXEMPT INCOME TO BE EXCLUDED ITA Nos. 5416 & 5417/Del/2017 along with other cases WHILE COMPUTING DISALLOWANCE U/S.14A

G S Strategic Investments Limited, Mumbai vs. ACIT International Tax Circle 2(3)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5644/MUM/2025[2023-24]Status: DisposedITAT Mumbai30 Dec 2025AY 2023-24

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 112Section 143(3)Section 144C(13)Section 74

INCOME TAX APPELLATE TRIBUNAL, ‘I’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER GS Strategic Investments Vs. Assistant Commissioner of Limited Income Tax, International C/o. Sehajpreet Kaur Tax Circle- 2(3)(2), BBSR & Associates Mumbai 14th Floor, Central Wing Tower 4, Nesco Centre Western Express ... directions issued by the Ld. Dispute Resolution Panel-1, Mumbai, dated 27 June 2025 for the assessment year 2023- 24. 2 GS Strategic Investments Limited 2. At the threshold, we deem it appropriate to crystallise, with precision, the controversy which travels to us in the present appeal, for the dispute