DCIT, C-V, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

3,05,70,155/-. 26.4 It is also brought to our notice that on identical facts the Hon'ble ITAT vide para 31 to 34 of the order dated 15.6.2021 in ITA No. 1493/2017 & CO 4/2018 for AY 2011-12 restored the issue of suo-moto disallowance made under section 14A

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A(3), which says that disallowance needs to be calculated as per Rule 8D even if the assessee claims

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. ESSIX BIOSCIENCES LIMITED, MANIMAJRA

In the result, the appeal is dismissed and the

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowance cannot be made where there is no exempt income without appreciating the fact that applicability of section 14 A or Rule 8D does not depend on earning of income. 3. That the Ld. C1T(A) has erred in ignoring the legislative intent expressed in clarificatory explanation inserted in section 14A

ITO, WARD, PALAMPUR vs. THE KANGRA CENTRAL COOPERATIVE BANK LIMITED, KANGRA

In the result, appeal of the Department is partly allowed for statistical purposes

Bench: Us Is Filed Under Section 253 Of The Income Tax Act, As Amended From Time To Time. The Respondent Is A Cooperative Bank.

3)/2021- 22/1035999175(1). 4. The Respondent herein being aggrieved as aforesaid preferred first appeal before the Ld. CIT(A) wherein they interalia has raised following grounds: "1. Disallowance under section 14A

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

In the result, the appeal of the Revenue is dismissed

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.:

Disallowance as per provisions of Section 14A of the Act. 1. Total investments made amounting to Rs.61,32,54,169/- . 2. The Assessing Officer has made total addition of Rs.3,79,55,179/- by applying the provisions of Section 14A of the Act. 3

M/S HERO CYCLES LTD.,LUDHIANA vs. ACIT, C-V, LUDHIANA

In the result, appeal of the Department is dismissed and the\nappeal of the assessee is allowed

disallowance of expenses by invoking provisions of\nsection 14A of the Act read with Rule 8D of the Income Tax Rules, 1962\non the ground that the assessee company had made investment in\nshares/mutual funds, the income from which in the form of dividend or\nlong term capital gains is exempt from tax under section

SH RAMESH KUMAR DUDANI,MOHALI vs. DCIT, CIRCLE -6(1), MOHALI

The appeal of the assessee stands allowed

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकरअपीलसं./Ita No. 589/Chd/2019 "नधा"रणवष" / Assessment Year :2015-16 Shri Ramesh Dudani, The Dcit, बनाम C-104, Industrial Area, Circle 6(1), Live Phase Vii, Stock Complex, Mohali -160055 Sector 68, Mohali "थायी लेखा सं./Pan No: Abbpd0633J अपीलाथ"/Appellant ""यथ"/Respondent

3 589-c-2019 (A.Y. 2015-16) – Ramesh Dudani, Mohali to give any proof of any account which was maintained separately for keeping personal funds. Accordingly, the AO proceeded to make a disallowance of Rs.15,21,161/- towards finance expenses in terms of section 14A

THE SHAHABAD COOP. SUGAR MILLS,SHAHABAD vs. ACIT, CIRCLE, KURUKSHETRA

Bench: Us In Terms Of Section 253 Of The Income Tax Act, 1961. 2. The Assessee Being Aggrieved By The Order Of Ld. Cit(A) Dt. 11/03/2018 Which Is Hereinafter Referred To As The Impugned Order, Before This Tribunal In Form No. 36 Has Interalia Raised The Following Grounds Of Appeal:

3. That it is admitted fact that section 14 A of IT Act does not go behind the intention of Assessee, rather, it purely considers whether income is arizable or not. The disallowance has got to be made under Section 14A

DCIT, CIRCLE, PANCHKULA vs. M/S HARYANA VIDYUT PRASARAN NIGAM LTD., PANCHKULA

In the result, appeal is dismissed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshi

disallowance under Section 14A of the Income Tax Act, 1961 was not made out, affirmed by the Jurisdictional High Court in the matter of Avon Cycles Vs. CIT, Ludhiana, bearing ITA No. 277 of 2013? 3

ACIT, CIRCLE, PANCHKULA vs. M/S HARYANA VIDYUT PRASARAN NIGAM LTD., PANCHKULA

In the result, we upheld the

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 14A, of the Income Tax Act, 1961 read with Rule 8D of the Income Tax Rules, 1962 was not called for as the assessee has not earned any exempt income ignoring the legislative intent of the statue, further clarified vide Circular No. 5/2014 dated 11.02.2014 which provides for disallowance of expenditure even where the Assessee has not earned

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LTD, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

disallowable under section 14A. 5. Against the order of the AO the ASSESSEE went in appeal before the CIT(A). 5.1 Before the CIT(A), it was submitted that the assessee has let out part of its godowns and warehouses to third parties such as FCI, Central 3

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

disallowable under section 14A. 5. Against the order of the AO the ASSESSEE went in appeal before the CIT(A). 5.1 Before the CIT(A), it was submitted that the assessee has let out part of its godowns and warehouses to third parties such as FCI, Central 3