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Raajratna Energy Holdings Private ... vs Deputy Commissioner Of Income-Tax, ... on 11 August, 2025

The facts of our case are totally different and distinguishable from the facts of the above case. We have made investments out of our own funds exclusively in our subsidiaries for strategic business purpose and not with the intension to earn dividend income. Further, as we have made the investments out of our funds that too in closely held subsidiaries on long term basis. Our submission is that, we have not incurred any expenditure either on interest or on administrative expense.

Income Tax Appellate Tribunal - Bangalore Cites 70 - Cited by 0 - Full Document

Dy. Commissioner Of Income Tax , ... vs Integrated Cleanroom Technologies ... on 17 September, 2021

The ground no. 2 relates to addition on account of section 14A of Rs. 13,45,717/- being 1% of the investments made of Rs.13,45,71,770/-. The appellant has stated that it does not have any exempt dividend income and therefore the disallowance ix]». 14A is not called for. There is a jurisdictional ITAT decision in the situation, wherein the disallowance u/s. 14A cannot be made if the appellant has not earned any exempt income. The extract of the decision in the case of DCIT Vs. Maheshwari Mega Ventures Limited, Hyderabad in ITA No. 367/Hyd/2013 dated 03.02.2017 is reproduced as below:

Income Tax Appellate Tribunal - Hyderabad Cites 13 - Cited by 4 - Full Document

Dy. Commissioner Of Income Tax , ... vs Ksk Electricity Financing India ... on 4 September, 2020

5. The ld. CIT(A) deleted the disallowance by appreciating the contention of the assessee that since there was no exempt income, provisions of section 14A would not come into operation. The ld. CIT(A) also placed reliance on the decision of this Tribunal in the case of DCIT Vs. Maheswari Mega Ventures Ltd., Hyderabad in ITA No. 367/Hyd/2013, dated 03/02/2017 in support of his decision.

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Dy. Commissioner Of Income Tax , ... vs Ilabs Hyderabad Technology Centre ... on 10 September, 2020

5. When the appeal was taken up for hearing none appeared on behalf of the respondent-assessee. therefore, We have heard the ld. DR and gone through the orders of the authorities below. In the instant case, though the assessee has made investments, the assessee did not earn any exempt income. The ld. CIT(A) deleted the disallowance by relying on the decision of this Tribunal in the case of Maheswari Mega Ventures Ltd. (supra), wherein the Tribunal has held as under:

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Dy. Commissioner Of Income Tax , ... vs Gvk Energy Limited , Hyderabad on 25 March, 2021

3. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT(A), who has deleted the disallowance by relying on the decision of the ITAT, Hyderabad in the case of DCIT Vs. Maheshwari Mega Ventures Ltd., ITA No. 367/Hyd/2013, dated 03/02/2017 observing that the assessee has not earned any dividend income during year on such investments, therefore, no disallowance is warranted in the case of the assessee.

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Assistant Commissioner Of Income Tax ... vs Madhava Holdings Private Limited , ... on 17 August, 2023

5. Assessee preferred appeal and argued that no such disallowance can be made since it has not earned any exempt income in the year under consideration. Learned CIT(A), as a matter of fact, noted that there is no exempt income earned by the assessee during the year under consideration and while following the view taken by a Co-ordinate Bench of the Tribunal in the case of DCIT vs Maheswari Mega Ventures Ltd in ITA No. 367/Hyd/2013 dated 03/02/2017, reached the conclusion that no such Page 2 of 6 ITA No. 55/Hyd/2022 disallowance could be made and directed the learned Assessing Officer to delete the same.