DCIT CC 7(2).MUMBAI, MUMBAI vs. MAN INDUSTRIES (INDIA) LIMITED, MUMBAI

In the result, the appeal of the Revenue is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-2021

Section 14A of the Income Tax Act, 1961 would not apply to the facts of 14A of the Income Tax Act, 1961 would not apply to the facts of 14A of the Income Tax Act, 1961 would not apply to the facts of this case as no exempt income was received or receivable during this case as no exempt income

DCIT (LTU) 2, MUMBAI vs. ASIAN PAINTS LTD, MUMBAI

3) of the Act did not agree with the submissions of the assessee and\nrestricted the weighted deduction on R&D expenditure under section 35(2AB)\nof the Act on the basis of the certificate issued by the DSIR in Form No.3CL.\n33. The learned CIT(A), vide impugned order, following the decision of the\ncoordinate bench of the Tribunal

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

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

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

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

14A of the Act. Accordingly, Ground No.6 raised by the \nRevenue is dismissed. \n150. Thus, the present appeal preferred by the Revenue for the \n Assessment Year 2015-2016 is dismissed. \nITA No.2619/Mum/2024 [Assessee’s Appeal] \n151. We would next take up appeal preferred by the Assessee for the \n Assessment Year 2015-2016 which is directed against the Order

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

section, Assessing Officer has no power to bifurcate on \npro-rata basis and deduct a part of it from the gross dividend income. \nThere is no scope for any estimation of expenditure and hence no scope \n54 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs 2002-03 to 2020-21 \nfor allocation of notional expenditure. The deductions contemplated are \nthe

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

3,01,95,155 | 9,35,97,716\nLess: Utilised during the year | 7,24,53,947 | 2,68,76,000 \nLess: Used for issue of Bonus Shares | 1,43,77,167 | 1,94,71,877 \n | | 50,00,00,000 \nSHELTER ASSISTANCE RESERVE | 10,64,44,875 | 9,57,14,379 \nOpening Balance

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

Section \n36(1)(viii) speaks only of special reserve created under that section \nwithout making any distinction between reserve created before the \namendment introduced by the Finance Act, 1997, in the said section \neffective from 01.04.1998 and reserve created post amendment. By \nreferring to section 41(4A) according to which, withdrawal from the \nspecial reserve created and maintained

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

Section 57(iii) and find that ld.\nUnder the said section, Assessing Officer has no power to bifurcate on\npro-rata basis and deduct a part of it from the gross dividend income.\nThere is no scope for any estimation of expenditure and hence no scope\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and Ors.\nAYs

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFAC , DELHI

Section 57(iii) and find that ld. \nUnder the said section, Assessing Officer has no power to bifurcate on \npro-rata basis and deduct a part of it from the gross dividend income. \nThere is no scope for any estimation of expenditure and hence no scope\n52 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs

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

Section 57(iii) and find that ld. \nUnder the said section, Assessing Officer has no power to bifurcate on \npro-rata basis and deduct a part of it from the gross dividend income. \nThere is no scope for any estimation of expenditure and hence no scope \n53 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs

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. ADDL CIT RG 1(1), MUMBAI

Section\n36(1)(viii) speaks only of special reserve created under that section\nwithout making any distinction between reserve created before the\namendment introduced by the Finance Act, 1997, in the said section\neffective from 01.04.1998 and reserve created post amendment. By\nreferring to section 41(4A) according to which, withdrawal from the\nspecial reserve created and maintained

HDFC BANK LIMITED( AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT- 2(3)(1), MUMBAI

Section 57(iii) and find that ld.\nUnder the said section, Assessing Officer has no power to bifurcate on\npro-rata basis and deduct a part of it from the gross dividend income.\nThere is no scope for any estimation of expenditure and hence no scope\n\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and Ors.\nAYs

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