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

4 being general in nature does not need any separate adjudication. 6.4 In the result, the assessee's appeal in ITA No. 466/KOL/2018 is partly allowed for statistical purposes. A.2 Now we shall take up the Revenue's appeal in ITA No. 622/KOL/2018 for adjudication. 7. Ground No. 1 relates to the deletion of disallowance of ₹ 31.58 crores

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

disallowed\nunder Rule 8D of the IT Rules and the disallowance has been made only\nunder clause (iii) of Rule 8D as per the formulae mentioned therein and\nthe same is not to be considered for the purpose of MAT and the\naddition, if any, made to the book profit on account of disallowance u/s\nPage 43\nITA

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

41 I.T.A. No.: 1854/Kol/2016 Assessment Year: 2012-13 I.T.A. No.: 1899/Kol/2017 Assessment Year: 2013-14 M/s. Tata Global Beverages Limited. 3,12,83,015/- computed as per Rule 8D(2)(iii) while arriving at book profit under section 115JB of the Art without appreciating that provisions of subsection (2) & (3) of Section 14A which prescribes for estimated disallowance

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

41 I.T.A. No.: 1854/Kol/2016 Assessment Year: 2012-13 I.T.A. No.: 1899/Kol/2017 Assessment Year: 2013-14 M/s. Tata Global Beverages Limited. 3,12,83,015/- computed as per Rule 8D(2)(iii) while arriving at book profit under section 115JB of the Art without appreciating that provisions of subsection (2) & (3) of Section 14A which prescribes for estimated disallowance

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

APEEJAY PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2013-14

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 116/Kol/2023 Assessment Year: 2013-14

section 14A of the Act confirmed by the ld. CIT(A). We notice that the impugned disallowance consists of two amounts, one is the interest disallowance under Rule 8D(2)(ii) and other is expenditure disallowance under Rule 8D(2)(iii) r.w.s. 14A of the Act. So far as the interest disallowance is concerned, the ld. Counsel for the assessee

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

4 being general in nature does not need any separate\nadjudication.\n6.4 In the result, the assessee's appeal in ITA No. 466/KOL/2018 is\npartly allowed for statistical purposes.\nA.2 Now we shall take up the Revenue's appeal in ITA No.\n622/KOL/2018 for adjudication.\n7.\nGround No. 1 relates to the deletion of disallowance of ₹ 31.58\ncrores

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

4 being general in nature does not need any separate\nadjudication.\n6.4 In the result, the assessee's appeal in ITA No. 466/KOL/2018 is\npartly allowed for statistical purposes.\nA.2 Now we shall take up the Revenue's appeal in ITA No.\n622/KOL/2018 for adjudication.\n7.\nGround No. 1 relates to the deletion of disallowance of ₹ 31.58\ncrores

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

section 115JB of the\nAct is a self-contained code and only the disallowances mentioned in\nthe explanation could have been made. Further, clause (f) of\nExplanation 1 to section 115JB of the Act refers to the amount or\namounts of expenditure relatable to any income to which section 10\napplies. The Ld. AO has not made any disallowance

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

section 115JB of the\nAct is a self-contained code and only the disallowances mentioned in\nthe explanation could have been made. Further, clause (f) of\nExplanation 1 to section 115JB of the Act refers to the amount or\namounts of expenditure relatable to any income to which section 10\napplies. The Ld. AO has not made any disallowance

SENBO ENGINEERING LIMITED,KOLKATA vs. DCIT, CIR-11, KOLKATA. , KOLKATA

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Years: 2007-08 Senbo Engineering Limited, Deputy Commissioner Of 87, Lenin Sarani, Vs Income Tax, Circle-11, Kolkata - 700013 Kolkata - 700013 (Pan: Aadcs6138B) (Appellant) (Respondent)

disallowance of Rs.55,256 u/s 40(a)(ia), there appeared a total income of Rs.6,21,42,197 while as per the Return the Total Income had been Nil. The Assessing Officer computed the tax/interest payable by the appellant at Rs 31,36,906 which was inclusive

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

4 of the appeal is allowed for statistical\npurposes.\n10. Ground No. 5 relates to the Ld. CIT(A) erring in directing the Ld.\nAO to delete the disallowance of ₹1,19,67,718/- computed u/s14A of\nthe Act read with Rule 8D(2)(ii) of the Income Tax Rules, 1962 and to\nrestrict expenses for the investments which actually

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

In the result, the appeal filed by the Revenue in ITA No

4 of the appeal is allowed for statistical\npurposes.\n10. Ground No. 5 relates to the Ld. CIT(A) erring in directing the Ld.\nAO to delete the disallowance of ₹1,19,67,718/- computed u/s14A of\nthe Act read with Rule 8D(2)(ii) of the Income Tax Rules, 1962 and to\nrestrict expenses for the investments which actually

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. DOLLAR HOLDING PVT. LTD., KOLKATA

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

disallowance of Rs. 18,67,227/- under section 14A of the Act on account of expenses incurred to earn exempt income to Rs. 86,368/- in contravention of CBDT's Circular No. 5/2014 dated 11/02/2014?” 04. Brief facts of the case are that the assessee filed the return of income on 29.09.2015, declaring total loss of ₹10,22,220/-, which

DEPUTY COMMISSOENR OF INCOME TAX, KOLKATA vs. DOLLAR HOLDING PVT. LTD., KOLKATA

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

disallowance of Rs. 18,67,227/- under section 14A of the Act on account of expenses incurred to earn exempt income to Rs. 86,368/- in contravention of CBDT's Circular No. 5/2014 dated 11/02/2014?” 04. Brief facts of the case are that the assessee filed the return of income on 29.09.2015, declaring total loss of ₹10,22,220/-, which

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

4 of the appeal is allowed for statistical\npurposes.\n10. Ground No. 5 relates to the Ld. CIT(A) erring in directing the Ld.\nAO to delete the disallowance of ₹1,19,67,718/- computed u/s14A of\nthe Act read with Rule 8D(2)(ii) of the Income Tax Rules, 1962 and to\nrestrict expenses for the investments which actually

D.C.I.T CIR - 10(1), KOLKATA vs. M/S EUREKA FORBS LTD, KOLKATA

In the result, the appeal filed by the Revenue in ITA No

4 of the appeal is allowed for statistical\npurposes.\n10. Ground No. 5 relates to the Ld. CIT(A) erring in directing the Ld.\nAO to delete the disallowance of ₹1,19,67,718/- computed u/s14A of\nthe Act read with Rule 8D(2)(ii) of the Income Tax Rules, 1962 and to\nrestrict expenses for the investments which actually