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Jubilant Securities Pvt. Ltd. Versus Deputy Commissioner of Income-Tax

2018 (1) TMI 609 - DELHI HIGH COURT

Addition u/s 14A - Held that:- What is not in dispute in the present case is that after the CIT(A) granted limited relief and reduced the quantum of the disallowance, the assessee was satisfied. It did not prefer either an appeal or a cross-objection within the time stipulated in this regard. This, in the opinion of the Court, meant that the issue of applicability of Section 14A attained finality. The appellant / assessee, in the light of CIT v. Holcim India (P) Ltd. (2014 (9) TMI 434 - DELHI HI .....

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17, ITA 1001/2017 & CM No.41761/2017, ITA 1014/2017 & CM No.41800/2017 - Dated:- 10-1-2018 - MR. S. RAVINDRA BHAT & MR. A. K. CHAWLA JJ. Present: Mr. Gaurav Jain with Mr. Aditya Vohra, Advs. for appellant. Mr. Asheesh Jain, Senior Standing Counsel, Income Tax Department. O R D E R 1. The assessee/appellant urges that the Income Tax Appellate Tribunal (ITAT) fell into error in declining to condone the delay which occurred in the filing of its cross-objection having regard to the changed posit .....

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ter of appeal to the ITAT, by the Revenue. During the pendency of those appeals, by judicial decision (in the judgment reported as CIT v. Holcim India (P) Ltd. ITA No.486 & 299/2014 decided on 05.09.2014) the cross-objections were filed. The assessee contended that the exempt income for which disallowance was ordered under Section 14A of the Act was by way of investment in subsidiary for business purposes and not for investment purposes and therefore, the disallowance was not warranted. That .....

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me Court in National Thermal Power Co. Ltd. v. CIT (1998) 229 ITR 383 (SC) and some other judgments of the High Courts. The ITAT, however, declined to grant relief and rejected the application for condonation of delay. 4. It is urged on behalf of the assessee that once a party enters the Appellate Court, the issues are at large and the appellate forum is entitled to consider the correct position in law. So viewed, the cross-objection preferred was sufficient for the ITAT to have examined the cla .....

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