ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

disallowance of Rs. 1,76,16,528/- and Rs. 2,89,99,437/- respectively claimed by the assessee under section 36 (i) (viii) of the Act. The Ld. AO discussed this issue in para 5 page 30

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

disallowance of Rs. 1,76,16,528/- and Rs. 2,89,99,437/- respectively claimed by the assessee under section 36 (i) (viii) of the Act. The Ld. AO discussed this issue in para 5 page 30

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

disallowance of Rs. 1,76,16,528/- and Rs. 2,89,99,437/- respectively claimed by the assessee under section 36 (i) (viii) of the Act. The Ld. AO discussed this issue in para 5 page 30

M/S. PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

disallowance of Rs. 1,76,16,528/- and Rs. 2,89,99,437/- respectively claimed by the assessee under section 36 (i) (viii) of the Act. The Ld. AO discussed this issue in para 5 page 30

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE ENTERPRISES LTD.,, NEW DELHI

In the result, revenue’s appeal is dismissed and cross-objection

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia:Assessment Year: 2014-15 Deputy Commissioner Of Vs. M/S. Religare Enterprises Income-Tax, Circle-21(1), Ltd., 2Nd Floor, Rajlok New Delhi Building, 24-Nehru Place, New Delhi-110019 Pan :Aaacv5888N (Appellant) (Respondent)

30 ITA No. 7552 & CO. 27/Del./2018 attributable to the earning of the exempt income. Of course, the assessing officer made further disallowance of Rs.28,63,13,621. 13. The primary and main contention of assessee before us is, disallowance of expenditure under Section

LINKEDIN TECHNOLOGY INFORMATION PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, DELHI -4 , DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

section 40(a)(i) is no longer discriminatory. In view of the hon’ble Delhi High Court in the Herbalife (supra) as above however, the application of disallowance @100% u/s 40(a)(i) is held as discriminatory in so far as quantum of disallowance is concerned. The quantum of disallowance for resident is restricted to 30

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

RELIGARE FINVEST LTD.,NEW DELHI vs. ACIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

ACIT (OSD), CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD.,, NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

30. The Ld. Departmental Representative submitted that the CIT(A) has erred in deleting the disallowance for A.Y 2012-13, A.Y 2013-14 and A.Y 2015-16 32 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT further submitted that the CIT(A) rightly upheld the disallowance of interest on compulsory convertible debentures subscribed by its holding Company

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

M/S EICHER GOODEARTH LTD

The appeals stand disposed of as above

disallowance can be made under section 14A of the said Act. Scope of sub-sections (2) and (3) of Section 14A 29. Sub-section (2) of Section 14 A of the said Act provides the manner in which the Assessing Officer is to determine the amount of expenditure incurred in relation to income which does not form part

M/S EICHER GOODEARTH LTD

The appeals stand disposed of as above

disallowance can be made under section 14A of the said Act. Scope of sub-sections (2) and (3) of Section 14A 29. Sub-section (2) of Section 14 A of the said Act provides the manner in which the Assessing Officer is to determine the amount of expenditure incurred in relation to income which does not form part