ACIT vs. K Raheja Corp Pvt. Ltd.
Case No: ITA No. 6083/MUM/2025
Court: Income Tax Appellate Tribunal, Mumbai Bench
Date: 1/22/2026
Parties Involved
appellantACIT
respondentK Raheja Corp Pvt. Ltd.
Facts Summary
The assessee, K Raheja Corp Pvt. Ltd., is a domestic company engaged in construction activities and running a hotel. It filed its return of income declaring total income at Rs.1,94,15,430/- and book profit of Rs.56,91,386/-. The assessee had suo-motu disallowed Rs.1,45,32,176/- and Rs.740/- u/s 14A of the Income-tax Act, 1961 while computing the normal income. The return was selected for scrutiny, and the Assessing Officer computed disallowance u/s 14A r.w.r. 8D at Rs.4,17,30,725/- and made an a…
Decision in favour of
Revenue
Legal Issues
- 1. Whether the Ld. CIT(A) was right in law and facts by deleting the disallowance u/s 14A of the IT Act, relying on the premise that there was no exempt income received by the assessee during the year under consideration, without appreciating the direction contained in the Circular No.5 of 2014 dated 11.02.2014 of CBDT?
- 2. Whether the Ld. CIT(A) was right in law and facts by deleting the disallowance u/s 14A of the Income Tax Act, 1961 thereby overlooking the computational procedure laid down in Rule 8D of the IT Rules, 1962 which has to be necessarily followed whenever a disallowance u/s 14A was to be made?
1 more legal issue analysed in this judgement.
Precedents Relied Upon
12 precedents cited in this judgement.