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

section 14A r.w. Rule 8D. After reducing therefrom suo-moto disallowance of Rs.36,50,000/-, the Ld. AO disallowed Rs.1

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

section 14A r.w. Rule 8D. After reducing therefrom suo-moto disallowance of Rs.36,50,000/-, the Ld. AO disallowed Rs.1

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

section 14A r.w. Rule 8D. After reducing therefrom suo-moto disallowance of Rs.36,50,000/-, the Ld. AO disallowed Rs.1

INCOME TAX vs. LIMITED

The appeal is dismissed

Section 50(2) are attracted in the present case so as to tax short-term capital gain on transfer of block of assets?” 2008:DHC:2682-DB ITA No. 895 of 2007 Page 3 of 21 3. In order to deal with the issues raised in the appeal, it would be necessary for us to record certain undisputed facts

TRIVENI TURBINE LTD,NOIDA vs. ACIT, CIRCLE 5(3)(1), NOIDA

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay[Assessment Year: 2018-19]

Section 37(1), the AO disallowed the deduction of 210,50,000 claimed under Section 35(2AA) and added the amount

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)

disallowance under section 14A of the Act cannot exceed the actual exempt dividend income. 2. Each of the aforesaid contentions are elaborated hereunder: Re (a): Amendment in section 14A - prospective and not retrospective 3. Kind attention is, at the outset, invited to the provisions of section 14A of the Act, as amended by the Finance Act, 2022, w.e.f

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

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.

section 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19,95,37,610 being 25% of support service fees and reimbursement of expenses aggregating to Rs.79,81,50

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance to administrative expenditure, and that too, is pegged at 0.5% for the value of investments, which gave rise to income that was exempt from tax, it failed to examine as to whether the provisions of Section 14A of the Act were, in the first Karampal Sahu [State of Jharkhand v. Shiv Karampal Sahu

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance to administrative expenditure, and that too, is pegged at 0.5% for the value of investments, which gave rise to income that was exempt from tax, it failed to examine as to whether the provisions of Section 14A of the Act were, in the first Karampal Sahu [State of Jharkhand v. Shiv Karampal Sahu

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance to administrative expenditure, and that too, is pegged at 0.5% for the value of investments, which gave rise to income that was exempt from tax, it failed to examine as to whether the provisions of Section 14A of the Act were, in the first Karampal Sahu [State of Jharkhand v. Shiv Karampal Sahu

NIIT TECHNOLOGIES LTD.,,NEW DELHI vs. ACIT, CIRCLE-18(2), NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify