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Pr. Commissioner Of Income Tax ... vs M/S Era Infrastructure (India) Ltd. on 20 July, 2022

(D.2) Whether the aforesaid explanation to section 14A of the Act is retrospective or prospective has been considered by various Hon'ble High Courts in the cases reported as Pr. CIT vs. Era Infrastructure (India) Ltd. [2022] 141 taxmann.com 289 (Delhi), Williamson Financial Services Ltd. vs. CIT [2024] 166 taxmann.com 607 (Gauhati) and Pr. CIT vs. Avantha Realty Ltd. [2024] 164 taxmann.com 376 (Calcutta). In these decisions, Hon'ble High Courts have held that the amendment to section 14A of the Income Tax Act, whereby the aforesaid explanation was inserted, is prospective in nature, and not retrospective. Respectfully following the aforesaid decisions of Hon'ble High Courts, it is held that explanation to section 14A of the Act, inserted by amendment brought about by Finance Act, 2022, with effect from 01/04/2022, is prospective in nature and has no application to the assessment year 2016-17 to which this appeal pertains. Accordingly, it is held that the assessee is not hit by the aforesaid explanation to section 14A of the Act in so far as assessment year 2016-17 is concerned. Further, in respectful consideration of precedents mentioned in foregoing paragraphs (D.1.1) and (D.1.1.1) of this order; it is held that no disallowance is attracted u/s 14A of IT Act in assessment year 2016-17. In view of I.T.A. No.227/Lkw/2020, 229/Lkw/20, 31 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 the foregoing, we decline to interfere with the order of learned CIT(A) on this issue.
Delhi High Court Cites 20 - Cited by 21 - Manmohan - Full Document

Cheminvest Limited vs Commissioner Of Income Tax-Vi on 2 September, 2015

I.T.A. No.227/Lkw/2020, 229/Lkw/20, 19 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 20 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 21 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 22 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 23 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 24 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 25 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 26 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 27 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 I.T.A. No.227/Lkw/2020, 229/Lkw/20, 28 587/Lkw/19, 485/Lkw/19, 588/Lkw/19 (D.1.1) There is no dispute on the fact that the assessee's exempt income, not included in taxable income of the assessee, during the year was nil. It was held by Hon'ble Delhi High Court in the case of Cheminvest Ltd. vs. CIT [2015] 61 taxmann.com 118 (Delhi) that disallowance u/s 14A of the Act is not attracted when exempt income during the year is nil. In this case, Hon'ble Delhi High Court held as under:
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