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“dominant purpose test”

DisallowancesSection 14ASection 14A48 judgments

DCIT 2(3)(1), MUMBAI vs. TATA STEEL LTD, MUMBAI

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

ITA 3555/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09
For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

taxmann.com 154 (SC), though this judgement was delivered in the context of disallowance u/s.14A r.w.r. 8D. He referred to “dominant purpose test” which was analysed by the Hon'ble Court while dealing with the provisions of section 14A to decide as to what interpretation is to be given

TATA STEEL LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

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

ITA 3294/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09
For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

taxmann.com 154 (SC), though this judgement was delivered in the context of disallowance u/s.14A r.w.r. 8D. He referred to “dominant purpose test” which was analysed by the Hon'ble Court while dealing with the provisions of section 14A to decide as to what interpretation is to be given

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
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1696/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

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
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

M/S. COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 1406/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

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

Para 33] ■ Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting section 14A or we have to go by the theory of apportionment. The dominant

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115J

Para 33]\n■ Having clarified the aforesaid position, the first and foremost issue that\nfalls for consideration is as to whether the dominant purpose test, which is\npressed into service by the assessees would apply while interpreting section\n14A or we have to go by the theory of apportionment

NIRAKAR TRUST,VADODARA vs. THE CIT(EXEMPTION), AHMEDABAD

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

ITA 1083/AHD/2025[NA]Status: DisposedITAT Ahmedabad09 Oct 2025

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : - Nirakar Trust Cit(Exemption) 11, Anandsagar Apartment Vejalpur Anand Sagar Society Ahmedabad. Jetalpur Road Vadodara 390 007 Pan : Aabtn 8200 G (Applicant) (Responent) : Shri Viranch Modi, Ca Assessee By : Shri Alpesh Parmar, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Alpesh Parmar, CIT-DR
Section 80GSection 80G(5)Section 80G(5)(iii)

rite or ritual, cannot be branded as religious expenditure. 5.5 The consistent principle flowing from judicial interpretation of “charitable purpose” is that the dominant purpose test must be applied. If the primary and predominant object of an institution is charitable, then an incidental association with a religious or spiritual activity ... relief to persons engaged in such a cultural-spiritual practice, and not to promote or propagate any religion. On application of the dominant purpose test, the expenditure, when seen in the larger perspective of the assessee’s declared objects and overall activities, clearly assumes the character of charitable relief

DIDU INVESTMENTS PRIVATE LIMITED,KOLKATA vs. D.C.I.T.,CIRCLE-6(1), KOLKATA

The appeal of the assessee is partly allowed

ITA 2585/KOL/2024[2014-15]Status: DisposedITAT Kolkata13 Aug 2025AY 2014-15

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250

income or not. 34. Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have

BHARAT DIAMOND BOURSE,MUMBAI vs. DCIT (E)- 1(1), MUMBAI

In the result, appeal is allowed

ITA 2219/MUM/2024[2009-2010]Status: DisposedITAT Mumbai12 Mar 2025AY 2009-2010
Section 2(15)Section 45(1)Section 6

charity.\n\n14. All subsequent judgments have noticed and followed the judgment of the Constitutional Bench in Surat Ark Silk (supra) and the dominant purpose test evolved therein and applied them to the facts before them. Applying this dominant purpose test to the objects of the respondent-assessee it appears

ACIT-1(1), INDORE vs. FLEXITUFF VENTURES INTERNATIONAL LIMITED, DHAR

Appeal is dismissed

ITA 195/IND/2024[2013-14]Status: DisposedITAT Indore30 Jan 2025AY 2013-14

Bench: Us Assailing The Order Of First-

Section 10ASection 143(3)Section 14A

produced below: “34) Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have to go by the theory

KIRI INDUSTRIES LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, appeal of the assessee is partly allowed

ITA 1513/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2018-19

Bench: Dr.Brr Kumarshri Tr Senthil Kumar

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsinh B Parmar, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 14ASection 234ASection 270ASection 36(1)(iii)Section 36(1)(va)Section 40

reproduced as under- "34) Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have

ACIT 14(I)(2), MUMBAI, MUMBAI vs. GODREJ PROPERTIES LIMITED, MUMBAI

ITA 3880/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Sept 2024AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyal1. Ita No. 3880/Mum/2024 (A.Y.2017-18)

For Appellant: Shri P. Suresh, Ld. DRFor Respondent: Shri Jeet Kamdar, Ld. AR
Section 14ASection 250

relation to’ the income, i.e., the dividend income and, therefore, section 14A would not be attracted. The Apex Court held (supra) that the dominant purpose test for which the investment into shares is made by an assessee may not be relevant while interpreting section 14A of the Act. The fact

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 469/PUN/2022[2013-14]Status: DisposedITAT Pune18 Sept 2024AY 2013-14

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

case of Maxopp Investment Limited Vs CIT [2018] 91 taxmann.com 154 (SC), wherein the Hon'ble Supreme Court has held that the 'dominant purpose test' for the investments from which exempt income is earned, is not relevant for the purposes of section ... observed as under: 34. Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 468/PUN/2022[2012-13]Status: DisposedITAT Pune18 Sept 2024AY 2012-13

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

case of Maxopp Investment Limited Vs CIT [2018] 91 taxmann.com 154 (SC), wherein the Hon'ble Supreme Court has held that the 'dominant purpose test' for the investments from which exempt income is earned, is not relevant for the purposes of section ... observed as under: 34. Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 467/PUN/2022[2011-12]Status: DisposedITAT Pune18 Sept 2024AY 2011-12

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

case of Maxopp Investment Limited Vs CIT [2018] 91 taxmann.com 154 (SC), wherein the Hon'ble Supreme Court has held that the 'dominant purpose test' for the investments from which exempt income is earned, is not relevant for the purposes of section ... observed as under: 34. Having clarified the aforesaid position, the first and foremost issue that falls for consideration is as to whether the dominant purpose test, which is pressed into service by the assessees would apply while interpreting Section 14A of the Act or we have

DCIT-CC-III, LUDHIANA vs. M/S LAXMI ENERGY & FOODS LTD.,, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

ITA 33/CHANDI/2021[2011-12]Status: DisposedITAT Chandigarh10 Jul 2024AY 2011-12

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 33/Chd/2021 "नधा"रण वष" / Assessment Year: 2011-12 The Dcit, Vs. M/S Laxmi Energy & Foods बनाम Ltd., Central Circle-Iii, Sco 18-19, Sector 9-D, Ludhiana Ludhiana "थायी लेखा सं./Pan No: Aaacl3147J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 10.07.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.:

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 14A

when the shares are held by the assessee not to earn exempt income but to retain controlling stake in the group companies, the dominant purpose test cannot be said to be relevant for the purpose of sectionl4A and disallowance u/s 14A can be made. Therefore, there is no merit

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

In the result, the appeal filed by the assessee is dismissed

ITA 164/CHNY/2024[2013-14]Status: DisposedITAT Chennai10 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri M.V. Swaroop, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 11Section 12ASection 13(8)Section 143(3)Section 2(15)

objection of the Ld.DR that the main purpose of the public charitable activity undertaken by assessee has to be looked into as a dominant purpose test and that collection of money for micro financing in the form of interest on the loans advanced to the self help group members will

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