TMI Blog2018 (2) TMI 1158X X X X Extracts X X X X X X X X Extracts X X X X ..... consideration for dis-allowance. See Pr. CIT Vs. M/s. Rivian International (P.) Ltd. [2017 (12) TMI 811 - BOMBAY HIGH COURT] - Decided against revenue. - Income Tax Appeal No. 785 of 2015, Income Tax Appeal No. 789 of 2015 - - - Dated:- 5-2-2018 - M. S. Sanklecha And Riyaz I. Chagla, JJ. Mr. Suresh Kumar, for the Appellant Mr. Sanjiv Shah, for the Respondent ORDER P. C. 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cy? (b) Whether on the facts and in the circumstance of the case and in law, the Tribunal is correct in holding that Section 14A is not applicable to the case of investments in the case of subsidiary company because the purpose was not to earn dividend income but to increase controlling stake? (c) Whether on the facts and in the circumstance of the case and in law, the Tribunal is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e exempt in the subject Assessment Year. 4. The aforesaid finding by the Tribunal has been accepted by the Revenue. Therefore, it is not a subject matter of challenge before us. In fact, a similar issue had been raised by the Revenue in the case of Pr. CIT Vs. M/s. Rivian International (P.) Ltd. ITXA No. 693 of 2015 decided on 21st November 2017 where this Court following the decision of the De ..... X X X X Extracts X X X X X X X X Extracts X X X X
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