Godrej Properties Ltd. vs. The Assessing Officer

Parties Involved

Facts Summary

This appeal is filed by the Assessee, Godrej Properties Ltd., against the order of the Commissioner of Income-tax (Appeals)/NFAC, Delhi dated 20-Feb-2024 for the Assessment Year 2018-19. The Assessee has raised grounds of appeal challenging the disallowance under Section 14A of the Income-tax Act, 1961. The assessee contends that the disallowance should be restricted to the amount of exempt dividend income of Rs. 36,227/- earned during the year under consideration, in accordance with the order of the Coordinate Bench of the Tribunal in the assessee’s own case for Assessment Years 2012-13, 2014-15, and 2015-16. The learned CIT(A) rejected the contention by holding that the assessee had itself suo motu made a disallowance of Rs. 12,77,553/- and had not filed a revised return of income to restrict the disallowance to the extent of exempt income.…

Legal Issues

• 1. Whether the disallowance under Section 14A of the Income-tax Act, 1961 should be restricted to the amount of exempt dividend income of Rs. 36,227/- earned during the year under consideration.

Judgment Outcome

Decided in favour of Assessee.

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