DCIT, Circle 27(1), New Delhi vs. Uniparts India Ltd.

Parties Involved

Facts Summary

This appeal is filed by the Revenue against the order of the Commissioner of Income-tax (Appeals)-9, New Delhi dated 04.06.2018 for Assessment Year 2014-15. The Revenue is aggrieved by the deletion of additions made by the Assessing Officer on account of investments in subsidiaries and deemed dividend received from a wholly owned subsidiary. The assessee has not declared any exempt income during the year, and the issue of deemed dividend was contested based on the nature of transactions between the assessee and its subsidiary.…

Legal Issues

• 1. Deletion of addition made by the Assessing Officer on account of investment in subsidiaries under section 14A of the Income-tax Act, 1961.
• 2. Deletion of addition made by the Assessing Officer on account of deemed dividend received from a wholly owned subsidiary under section 2(22)(e) of the Income-tax Act, 1961.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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