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Principal Commissioner of Income Tax, Delhi Versus Bharti Enterprises (Holding) Pvt. Ltd.

2017 (11) TMI 918 - DELHI HIGH COURT

Disallowance u/s 14A - Held that:- ITAT noticed the decision of this Court in Maxopp Investment Ltd. v. Commissioner of Income Tax, (2011 (11) TMI 267 - Delhi High Court) that Rule 8D of the Income Tax Rules does not have retrospective operation. In this case, the lower authority had ruled that the provision did have retrospective operation. No question of law, therefore, arises since the ITAT merely followed the ruling of this Court in Maxopp (supra). - Treatment of interest for the sum whi .....

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documentary evidence. Given that the disinvestment itself is not doubted as is evident from the matters reported by the assessee which are part of the record, the expenses claimed are neither disproportionate nor of the kind that facially require proof as was sought by the authorities below. Consequently, no question of law arises. - As far as the capitalization of the interest in the hands of the assessee in the sum of ₹ 2,34,05,003/- is concerned, we notice that the CIT (A) had rever .....

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Supreme Court in Challapalli Sugar Ltd. v. CIT, (1974 (10) TMI 3 - SUPREME Court). - ITA 950/2017, CM APPL.40197-40199/2017 - Dated:- 8-11-2017 - S. Ravindra Bhat And Sanjeev Sachdeva, JJ. For the Appellant : Mr. Rahul Kaushik, Sr. Standing Counsel For the Respondent : None ORDER 1. The Revenue urges three questions of law with respect to AY 2006-07 with respect to the respondent s/assessee s income. The first question relates to disallowance of ₹ 47,11,206/- under Section 14A of the Incom .....

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mmissioner of Income Tax, (2012) 347 ITR 272 (Delhi) that Rule 8D of the Income Tax Rules does not have retrospective operation. In this case, the lower authority had ruled that the provision did have retrospective operation. No question of law, therefore, arises since the ITAT merely followed the ruling of this Court in Maxopp (supra). 3. As far as the second question goes, the Court is of the opinion that it is entirely factual. The assessee sold off its shares to an entity in a bid to disinve .....

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