ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13. 5. With respect to allocation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13. 5. With respect to allocation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. THE ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13. 5. With respect to allocation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13.5. With respect to allocation made

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13.5. With respect to allocation made

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13.5. With respect to allocation made

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13.5. With respect to allocation made

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A on the interest component relating to the investments in shares which yielded dividend income have been made out of owned funds and therefore, no part of such interest expenditure is allocable on this account. Our observations and findings on this aspect are not repeated here as already dealt elaborately in the above paragraphs. 13.5. With respect to allocation made

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14A of the Act read with Rule 8D(2)(iii) of Income Tax Rules, 1962 as per method vide formula laid down under Rule 8D(2)(iii) of Income Tax Rules, 1962 to cover administrative and other indirect expenses, which disallowance also we uphold. It is noteworthy that Rule 8D of Income Tax Rules, 1962 is held

PAHILAJRAI JAIKISHAN,MUMBAI vs. DCIT 19(3), MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14A of the Act read with Rule 8D(2)(iii) of Income Tax Rules, 1962 as per method vide formula laid down under Rule 8D(2)(iii) of Income Tax Rules, 1962 to cover administrative and other indirect expenses, which disallowance also we uphold. It is noteworthy that Rule 8D of Income Tax Rules, 1962 is held

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n13. 5. With respect to allocation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RANGE-1(1)(2), MUMBAI

14A on the interest\ncomponent relating to the investments in shares which yielded dividend\nincome have been made out of owned funds and therefore, no part of\nsuch interest expenditure is allocable on this account. Our observations\nand findings on this aspect are not repeated here as already dealt\nelaborately in the above paragraphs.\n\n13. 5. With respect

DCIT CIR 1(1), MUMBAI vs. M/S HOUSING DEVELOPEMENT FINANCE CORPORATION LTD, MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\n| Sr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LIMITED (MERGED ENTITY HOUSING DEVELOPMENT FINANCE CORPORATION LIMITED), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below:\n\nSr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect

DCIT - 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORARTION LTD., MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect

DCIT 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

Accordingly, ground so raised for Assessment \nYear 2004-05 is dismissed as infructuous

2. At the outset we note that aforesaid issue is covered by the order \nof Co-ordinate Bench of ITAT Mumbai in assessee's own case for \n Assessment Years 2000-01 and 2001-02 in ITA Nos.337 and \n724/Mum/2005, dated 05.07.2024 (undersigned Accountant Member \nbeing its author) wherein claim of the assessee has been allowed after \nconsidering the judicial