The Pr. Commissioner of Income-tax-5 v. Liquid Investment and Trading Co. Pvt. Ltd
[Citation -2019-LL-0215-65]
Citation | 2019-LL-0215-65 |
---|---|
Appellant Name | The Pr. Commissioner of Income-tax-5 |
Respondent Name | Liquid Investment and Trading Co. Pvt. Ltd. |
Court | HIGH COURT OF DELHI AT NEW DELHI |
Relevant Act | Income-tax |
Date of Order | 15/02/2019 |
Judgment | View Judgment |
Keyword Tags | tax exempt income • question of law • recording of satisfaction • computation of disallowance |
Bot Summary: | CORAM: HON BLE MR. JUSTICE S. RAVINDRA BHAT HON BLE MR. JUSTICE PRATEEK JALAN ORDER 15.02.2019 In this appeal the assessee had for A.Y. 2007-08 offered 85,48,009/- as disallowance under Section 14A. The AO rejected this but without recording reasons for satisfaction; and disallowed 2,95,03,813/-. The CITA gave partial relief and restricted the disallowance to 1,21,64,443/-. The ITAT in the assessee s appeal followed the principle enunciated by this Court in Joint Investments Pvt. Ltd. vs. CIT, Reported in 372 ITR 694, that the disallowance cannot exceed the tax exempt income and reduced the disallowance what was so offered by the assessee. The Court is of the opinion that since the ITAT has followed this Court s decision, no question of law arises. |