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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

ACIT-2(1)(1), Mumbai vs. Geecee Ventures Limited, Mumbai

The appeal is allowed for statistical purposes

ITA 4119/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

whereas the assessee had computed the disallowable expenses u/s 14A only at Rs 46,67,450/- excluding the strategic investments in group companies? 4. Whether on the facts and in the circumstances of the case and in 2 ITA 3975&4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year ... does not carry any dividend/ exempt income. The appellant further submitted that no disallowance is warranted in case of investment in subsidiary companies as strategic investment. Further the appellant also stated that no 14A disallowance is warranted u/s 115JB of the Act. The appellant relied on Vireet Investment

Geecee Ventures Limited, Mumbai vs. DCIT, Circle 2(1)(1), Mumbai

The appeal is allowed for statistical purposes

ITA 3975/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

whereas the assessee had computed the disallowable expenses u/s 14A only at Rs 46,67,450/- excluding the strategic investments in group companies? 4. Whether on the facts and in the circumstances of the case and in 2 ITA 3975&4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year ... does not carry any dividend/ exempt income. The appellant further submitted that no disallowance is warranted in case of investment in subsidiary companies as strategic investment. Further the appellant also stated that no 14A disallowance is warranted u/s 115JB of the Act. The appellant relied on Vireet Investment

Warden International Private Limited, Mumbai vs. Dy. Commissioner of Income Tax Circle 8(3)(2), Mumbai

Appeal of the assessee is allowed

ITA 1754/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 May 2025AY 2012-13

Bench: Ms Padmavathy S, Am & Rahul Chaudhary, Jm

For Appellant: Shri Sukhsagar Syal / Atul SuraiyaFor Respondent: Shri Bhangepatil Pushkaraj
Section 10(34)Section 143(3)Section 144Section 14ASection 154Section 250

against the order of the AO passed under section 154. The assessee submitted before the CIT(A) that the investments made in subsidiaries are strategic investments and therefore cannot be considered for the purpose of making disallowance under section 14A of the Act. The assessee made a without prejudice submission ... exempt income should be considered. The CIT(A) dismissed the appeal by holding that “4.1 Assessing officer rejected the argument of the taxpayer that strategic investments do not yield exempt income and are not covered under the provisions of section 14A, AO issued a notice under Section 154/155

Gujarat State Financial Services Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

In the result, appeal of the assessee is allowed in part

ITA 1226/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad09 May 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 135(5)Section 143(3)Section 14ASection 37Section 80GSection 80G(2)(a)

directives of Finance Department of Government of Gujarat during the Financial Year 2018-19 and the investment was strategic in nature. Such strategic investment could not have been made without the involvement of top management. Therefore, the Directors’ remunerations and fees along with employees’ cost was also required

Atul Limited, Ahmedabad vs. The ACIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

Supreme Court in Maxopp Investment Ltd. v. CIT [(2018) 402 ITR 640 (SC)], wherein it was held that section 14A applies even to strategic investments if they yield exempt income. It was also submitted that the Rule 8D mechanism is mandatory where the AO, after due consideration, is not satisfied

Addi. CIT Spl. Range-9, New Delhi vs. The Hindustan Times Ltd., New Delhi

In the result, appeal of Revenue in ITA No

ITA 7597/DEL/2019[2015-16]Status: DisposedITAT Delhi08 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri V.K. Dubey, Sr. DR
Section 14Section 14ASection 14A(2)

case on hand. 6.4. Further the argument of the ld. AR that 97.2% of dividend income had been received by the assessee from strategic investments and the same need to be eliminated is misconceived in view of the decision of Hon’ble Supreme Court in the case of Maxopp

Chimanlal Maneklal Securities Private Limited, Mumbai vs. Income Tax Officer, Aayakar Bhawan, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 127/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 May 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Om Kandalkar,ARFor Respondent: Shri Kiran Unavekar, (Sr. DR)
Section 10(34)Section 115JSection 143(3)Section 14A

also contented that out of total investment of Rs.459,84,09,000/- investment of Rs.309,84,09,000/- were strategic in nature. The strategic investments were not to be considered while making disallowance u/s 14A of the Act. Investments in Growth oriented mutual funds amounting to Rs.150

Income Tax Officer-Ward-6(3)(1), Mumbai vs. Kohinoor Planet Constructions Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is partly allowed for statistical purpose

ITA 1495/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Apr 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am & Kohinoor Planet Constructions Pvt. Assistant Commissioner Of Income Ltd. Tax, Circle 6(3)(1) 506, 5Th Floor, Aayakar Bhavan, Kohinoor Corporate Office, Senapati Vs. Bapat Marg, Dadar West, Mumbai – Maharishi Karve Road, Mumbai – 400028. 400020. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) & Income Tax Officer, Ward-6(3)(1) Kohinoor Planet Constructions Room No. 524, 5Th Floor, Aayakar Pvt. Ltd. Bhavan, M. K. Road, Mumbai – 3, Kohinoor Corporate Office, Vs. 400020. Senapati Bapat Marg, Dadar West, Mumbai – 400028. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) Assessee By : Shri. Jayesh Dadia : Shri. Biswanath Das – Cit Dr. Respondent By : 30.01.2025 Date Of Hearing Date Of Pronouncement : 29.04.2025 O R D E R Per Bench: These Are Cross Appeals Filed By The Assessee & Revenue, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short)

For Appellant: Shri. Jayesh DadiaFor Respondent: 30.01.2025
Section 143(2)Section 143(3)Section 250Section 36(2)Section 37Section 43CSection 68

engaged in the business of property development and constructions of buildings, and power generation with the help of wind power turbines, thereby making strategic investments. The assessee had e-filed its return of income dated 28.09.2017, declaring a loss at Rs. 33,570/- and had filed revised return dated

Income Tax Officer Ward-6(3)(1), Mumbai vs. Kohinoor Planet Constructions Private Limited, Mumbai

In the result, the appeal filed by the revenue is partly allowed for statistical purpose

ITA 1493/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Apr 2025AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am & Kohinoor Planet Constructions Pvt. Assistant Commissioner Of Income Ltd. Tax, Circle 6(3)(1) 506, 5Th Floor, Aayakar Bhavan, Kohinoor Corporate Office, Senapati Vs. Bapat Marg, Dadar West, Mumbai – Maharishi Karve Road, Mumbai – 400028. 400020. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) & Income Tax Officer, Ward-6(3)(1) Kohinoor Planet Constructions Room No. 524, 5Th Floor, Aayakar Pvt. Ltd. Bhavan, M. K. Road, Mumbai – 3, Kohinoor Corporate Office, Vs. 400020. Senapati Bapat Marg, Dadar West, Mumbai – 400028. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) Assessee By : Shri. Jayesh Dadia : Shri. Biswanath Das – Cit Dr. Respondent By : 30.01.2025 Date Of Hearing Date Of Pronouncement : 29.04.2025 O R D E R Per Bench: These Are Cross Appeals Filed By The Assessee & Revenue, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short)

For Appellant: Shri. Jayesh DadiaFor Respondent: 30.01.2025
Section 143(2)Section 143(3)Section 250Section 36(2)Section 37Section 43CSection 68

engaged in the business of property development and constructions of buildings, and power generation with the help of wind power turbines, thereby making strategic investments. The assessee had e-filed its return of income dated 28.09.2017, declaring a loss at Rs. 33,570/- and had filed revised return dated

Kohinoor Planet Constructions Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

In the result, the appeal filed by the revenue is partly allowed for statistical purpose

ITA 1159/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai29 Apr 2025

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am & Kohinoor Planet Constructions Pvt. Assistant Commissioner Of Income Ltd. Tax, Circle 6(3)(1) 506, 5Th Floor, Aayakar Bhavan, Kohinoor Corporate Office, Senapati Vs. Bapat Marg, Dadar West, Mumbai – Maharishi Karve Road, Mumbai – 400028. 400020. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) & Income Tax Officer, Ward-6(3)(1) Kohinoor Planet Constructions Room No. 524, 5Th Floor, Aayakar Pvt. Ltd. Bhavan, M. K. Road, Mumbai – 3, Kohinoor Corporate Office, Vs. 400020. Senapati Bapat Marg, Dadar West, Mumbai – 400028. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) Assessee By : Shri. Jayesh Dadia : Shri. Biswanath Das – Cit Dr. Respondent By : 30.01.2025 Date Of Hearing Date Of Pronouncement : 29.04.2025 O R D E R Per Bench: These Are Cross Appeals Filed By The Assessee & Revenue, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short)

For Appellant: Shri. Jayesh DadiaFor Respondent: 30.01.2025
Section 143(2)Section 143(3)Section 250Section 36(2)Section 37Section 43CSection 68

engaged in the business of property development and constructions of buildings, and power generation with the help of wind power turbines, thereby making strategic investments. The assessee had e-filed its return of income dated 28.09.2017, declaring a loss at Rs. 33,570/- and had filed revised return dated

Kohinoor Planet Constructions Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(1), Mumbai

In the result, the appeal filed by the revenue is partly allowed for statistical purpose

ITA 1158/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai29 Apr 2025

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am & Kohinoor Planet Constructions Pvt. Assistant Commissioner Of Income Ltd. Tax, Circle 6(3)(1) 506, 5Th Floor, Aayakar Bhavan, Kohinoor Corporate Office, Senapati Vs. Bapat Marg, Dadar West, Mumbai – Maharishi Karve Road, Mumbai – 400028. 400020. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) & Income Tax Officer, Ward-6(3)(1) Kohinoor Planet Constructions Room No. 524, 5Th Floor, Aayakar Pvt. Ltd. Bhavan, M. K. Road, Mumbai – 3, Kohinoor Corporate Office, Vs. 400020. Senapati Bapat Marg, Dadar West, Mumbai – 400028. Pan/Gir No. Aabcr6994E (Assessee) : (Respondent) Assessee By : Shri. Jayesh Dadia : Shri. Biswanath Das – Cit Dr. Respondent By : 30.01.2025 Date Of Hearing Date Of Pronouncement : 29.04.2025 O R D E R Per Bench: These Are Cross Appeals Filed By The Assessee & Revenue, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short)

For Appellant: Shri. Jayesh DadiaFor Respondent: 30.01.2025
Section 143(2)Section 143(3)Section 250Section 36(2)Section 37Section 43CSection 68

engaged in the business of property development and constructions of buildings, and power generation with the help of wind power turbines, thereby making strategic investments. The assessee had e-filed its return of income dated 28.09.2017, declaring a loss at Rs. 33,570/- and had filed revised return dated

Income Tax Officer, Ward-16(1), Hyderabad vs. Nsl Nagapatnam Power Ventures Private Limited, Hyderabad

In the result, the appeal filed by the Revenue being devoid of any substance is dismissed

ITA 28/HYD/2025[2018-19]Status: DisposedITAT Hyderabad23 Apr 2025AY 2018-19

Bench: Us :

For Appellant: Shri A.V. RaghuramFor Respondent: Dr.Sachin Kumar, Sr.DR
Section 143(2)Section 143(3)Section 14A

Circular No.05/2014 dt. 11.02.2014. 3. The learned CIT(A) ought to have sensed there is an income in the nature of dividend earned from strategic investments made in the subsidiary companies.” 2. Succinctly stated, the assessee company had filed its return of income for A.Y. 2017-18 on 27.10.2017 declaring

Income Tax Officer, Ward-16(1), Hyderabad vs. Nsl Nagapatnam Power Ventures Private Limited, Hyderabad

In the result, the appeal filed by the Revenue being devoid of any substance is dismissed

ITA 27/HYD/2025[2017-18]Status: DisposedITAT Hyderabad23 Apr 2025AY 2017-18

Bench: Us :

For Appellant: Shri A.V. RaghuramFor Respondent: Dr.Sachin Kumar, Sr.DR
Section 143(2)Section 143(3)Section 14A

Circular No.05/2014 dt. 11.02.2014. 3. The learned CIT(A) ought to have sensed there is an income in the nature of dividend earned from strategic investments made in the subsidiary companies.” 2. Succinctly stated, the assessee company had filed its return of income for A.Y. 2017-18 on 27.10.2017 declaring

M/S. Jindal Brugs Private Limited, Mumbai vs. Principal Commissioner of Income Tax -3, Mumbai

In the result, the appeal of the Assessee is allowed

ITA 947/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Apr 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2020-21

For Appellant: Shri Rahul Hakkani, Ld. A.RFor Respondent: Shri Byomakesh Pradipta Kumar
Section 142(1)Section 143(3)Section 14ASection 263

owned subsidiary in 2014 for the purpose of investing specifically in treasury instruments as a dedicated line of business. This was a long term strategic investment where the subsidiary operated independently and was assessed to tax as a separate entity. This subsidiary has never declared any dividends since inception till ... also not applicable.” 6. The Assessee has claimed that it had made investment in its subsidiary in the year 2014 as a long term strategic investment and no dividend is declared by the subsidiary. No expenses were incurred with respect to investment in subsidiary during the year 7 M/s. Jindal

Unitech Holdings Ltd., New Delhi vs. DCIT, Circle- 27(1), New Delhi

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

ITA 4410/DEL/2019[2014-15]Status: DisposedITAT Delhi22 Apr 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldy. Cit, M/S Unitech Holdings Ltd., Circle-27(1), Basement-6, Community Vs. New Delhi. Centre, Saket, Delhi-110017. Pan-Aaacu0237C (Appellant) (Respondent)

NBFC and claim of the assessee was that the investment was made in the group company M/s Gurgaon Recreation Park Ltd. (GRPL) as strategic investment in terms of the Assisted Sector agreement. The assessee in order to save the project undertaken by the company GRPL, had transferred its equity ... shares and thus incurred loss of Rs. Unitech Holdings Ltd. vs. DCIT 1,49,75,269/-. Since the assessee is regularly engaged in making strategic investment in group companies, the loss incurred due to transfer of shares under compelling circumstances to save the company and was a business loss. However

Deputy Commissioner of Income Tax, Nagpur vs. Avantha Holdings Limited, Chandrapur

ITA 354/NAG/2023[2012-13]Status: DisposedITAT Nagpur04 Apr 2025AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member Avantha Holdings Ltd. Ballarpur Paper Mills S.O. Ballarpur 442 901 Pan – Aabcb6134E

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 251

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Avantha Holdings Limited, New Delhi vs. A.C.I.T. Cir-5, Nagpur

ITA 45/NAG/2016[2011-12]Status: DisposedITAT Nagpur04 Apr 2025AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member Avantha Holdings Ltd. Ballarpur Paper Mills S.O. Ballarpur 442 901 Pan – Aabcb6134E Appellant Dy. Commissioner Of Income Tax Circle-4, Nagpur Respondent V/S

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 251

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Dy. C.I.T. Cir-.5, Nagpur vs. M/S Avantha Holdings Ltd., Chandrapur

ITA 248/NAG/2016[2011-12]Status: DisposedITAT Nagpur04 Apr 2025AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member Avantha Holdings Ltd. Ballarpur Paper Mills S.O. Ballarpur 442 901 Pan – Aabcb6134E Appellant

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 251

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

JCIT(OSD)-14(1)(1), Mumbai vs. Avendus Capital Pvt. Ltd., Mumbai

Appeal is allowed

ITA 404/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Mar 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jcit (Osd)-14(1)(1), M/S Avendus Capital Pvt. Ltd., Room No. 432, 4Th Floor, 901, Platina, 9Th Floor, Plot No. Vs. Aayakar Bhavan, M.K. Road, C59, Bandra Kurla Complex, Mumbai-400020. Bandra East, Mumbai-400051. Pan No.Aabcc 2404 Q Appellant Respondent

For Appellant: Mr. Ashish Mehta &For Respondent: Dr. K.R. Subhash, CIT-DR
Section 14ASection 37(1)

mutual fund debt growth plan, mutual fund debt growth plan, Secondly, investment in equity investment in equity shares of Indian companies being a strategic investment, thirdly shares of Indian companies being a strategic investment, shares of Indian companies being a strategic investment, investment in compulsorily convertible debenture and fourthly investment ... made in the year where there is no dividend income, secondly secondly, 14A disallowance was not attracted , 14A disallowance was not attracted on the strategic investment, thirdly, judicial decisions were in favour the strategic investment, judicial decisions were in favour of the assessee. But according to t of the assessee

DCIT(CC)-7(3), Mumbai, Aayakar Bhavan, Near Churchgate vs. Macrotech Developers Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 487/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Mar 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Anikesh Banerjeeassessment Year 2017-18 Dcit (Cc)-7(3, Mumbai Macrotech Developers Limited Aayakar Bhavan, 412, Floor-4, 17G Vardhaman Mumbai-400020. Vs. Chamber, Cawasji Patel Road, Horniman Circle, Fort Mumbai-400001, Maharashtra Pan: Aaacl 1490 J (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth Revenue By : Shri Hemanshu Joshi, Sr. Dr Date Of Hearing : 06.12.2024 Date Of Pronouncement : 03.03.2025

For Appellant: Shri Niraj ShethFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 115BSection 143(2)Section 36(1)(iii)

Developers Limited A.Y. 2017-18 12.4 From the above facts, the contention of appellant that investment made in CCD’s of SNCML is a strategic investment to acquire controlling interest in its subsidiary, appears to be correct. I have also gone through the Financial statements of SNCML for the year ... development and construction activities. The capital borrowed by the appellant has been invested in Compulsory convertible Debentures of Shreenivas Cotton Mills Ltd as a strategic investments in subsidiary wherein the construction projects were in progress. The appellant is able to substantiate the commercial expediency as the main object