TMI Blog2023 (3) TMI 483X X X X Extracts X X X X X X X X Extracts X X X X ..... around the time when Corona Virus was raging in the city we are inclined to take a benevolent view. According the delay is condoned. Disallowance u/s 14A read with Rule 8D - appellant made investment in subsidiary/associated companies for strategic purposes - HELD THAT:- As a matter of fact, in the decision rendered in M/S MMTC LTD [ 2022 (12) TMI 651 - DELHI HIGH COURT] the Court even deal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2023[Application filed on behalf of the appellant seeking condonation of delay of 180 days in re-filing the appeal] 2. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal. 2.1 There is a delay of 180 days. 3. The reason given is that certain information was required from the Income Tax Department to remove the defects. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Commissioner of Income Tax Appeals [in short, CIT(A) ] to the effect that the appellant made investment in subsidiary/associated companies for strategic purposes. 7.1 The CIT(A) has also found that the respondent/assessee has not earned any dividend income which was exempted under the Act. 7.2 The Tribunal has affirmed these findings of fact and thus sustained the order of the CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fore us a judgment dated 20.07.2022, rendered by a coordinate bench of this Court in ITA No.204/2022, titled Principal Commissioner of Income Tax (Central)-2 v. M/s Era Infrastructure (India) Ltd., which has ruled on the amendment which was brought about in Section 14A of the Act via Finance Act 2022. 8.1. The coordinate bench has ruled that the amendment will not operate retrospectively. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t/revenue has filed a Special Leave Petition vis-a-vis the judgment in PCIT v. IL FS Energy Development Company Ltd. 13.1 In case, appellant/revenue were to succeed, it would then have liberty to approach the court to re-open the appeal. 14. Appeal is accordingly closed. 14.1 Registry is directed to dispatch a copy of the judgement rendered today to respondent/assessee via all modes ..... X X X X Extracts X X X X X X X X Extracts X X X X
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