SICPA INDIA PRIVATE LIMITED vs. Additional Joint Deputy ACIT & DCIT

Parties Involved

Facts Summary

The case involves four appeals filed by SICPA INDIA PRIVATE LIMITED and the Revenue against different orders of the Ld. CIT(Appeals)-24, New Delhi for the assessment years 2016-17, 2017-18 & 2018-19. The primary dispute is regarding the disallowance under section 14A of the Income Tax Act. The Revenue’s appeal (ITA No.386/Del/2024) for the assessment year 2017-18 was dismissed as not maintainable due to the disallowance amount being less than Rs.60 lakhs. The other three appeals by the assessee challenge the disallowance under section 14A, arguing that the Assessing Officer did not record proper satisfaction as required by Rule 8D. The assessee had previously succeeded in a similar issue in ITA No.9604/Del/2019 for the assessment year 2008-09.…

Legal Issues

• 1. Maintainability of the Revenue’s appeal (ITA No.386/Del/2024) for the assessment year 2017-18.
• 2. Disallowance under section 14A for the assessment years 2016-17, 2017-18 & 2018-19.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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