M/s Mahabhadra Constructions Ltd. Vs DCIT
Parties Involved
Facts Summary
The assessee, M/s Mahabhadra Constructions Ltd., appealed against the order of the Commissioner of Income Tax (Appeals)/National Faceless Assessment Centre, Delhi, dated 21.08.2023, which upheld the disallowance of Rs. 2,21,36,173 under section 14A read with Rule 8D of the Income Tax Rules, 1962. The assessee had derived exempt income in the form of dividends amounting to Rs. 1,15,20,605 and had disallowed a sum of Rs. 50,87,743, which was enhanced to Rs. 2,21,36,173 by the Assessing Officer. The assessee argued that only dividend-yielding investments should be considered for computing the disallowance.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the disallowance under section 14A read with Rule 8D should consider only dividend-yielding investments.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
4 precedents cited in this judgement.
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