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The Commissioner Of Income Taxchennai v. M/S.shriram Retail Holdings Pvt. Ltd

High Court 15 Oct 2024 In favour of: Assessee
Forum / Bench
High Court · hc_cis_mas
Parties
The Commissioner Of Income Taxchennai v. M/S.shriram Retail Holdings Pvt. Ltd
Date of order
15 Oct 2024
Assessment year(s)
Outcome
Dismissed

Case summary

In The Commissioner Of Income Taxchennai v. M/S.shriram Retail Holdings Pvt. Ltd, the High Court (2024) dismissed the appeal. The decision went in favour of the assessee.

Issue: Whether on the facts and circumstances of the case, the Appellate Tribunal was right in holding that the Assessing Officer has wrongly made disallowance regarding direct expenditure made under Section 14A read with Rule 8D(i)" 2.

Summary auto-generated from the order below — read the full judgment for the complete reasoning.

Sections referenced in this judgment

The order — as passed by the High Court

T.C.A.No.576 of 2015 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 15.10.2024 CORAM : THE HONOURABLE MR.JUSTICE R. SURESH KUMARAND THE HONOURABLE MR.JUSTICE C. SARAVANAN T.C.A.No.576 of 2015 The Commissioner of Income TaxChennai...Appellant Vs. M/s.Shriram Retail Holdings Pvt. Ltd.4, Lady Desika RoadMylapore, Chennai – 600 004...Respondent Prayer: Appeal filed under Section 260-A of the Income Tax Act, 1961, against the order of Income Tax Appellate Tribunal, Madras “A”Bench,Chennaidated10.04.2014passedin I.T.A.No.1477/Mds/2013. For the Appellant :Mr.J.NarayanaswamySenior Standing Counsel For the Respondent:Ms.Vandhana Vyasfor Mr.R.Sivaraman JUDGMENT (Order of the Court was made by R.SURESH KUMAR, J.)The present tax case appeal was admitted on 23.07.2015 by this Court on the following substantial question of law:- https://www.mhc.tn.gov.in/judis "1. Whether on the facts and circumstances of the case, the Appellate Tribunal was right in holding that the Assessing Officer has wrongly made disallowance regarding direct expenditure made under Section 14A read with Rule 8D(i)" 2. It is submitted by the learned Senior Standing Counsel appearing for the appellant Revenue that this matter is covered under the Low Tax Effect as per the recent Circular dated 17.09.2024, in Circular No.9/2024. 3. Hence, this appeal stands dismissed, as covered under the low tax effect and the substantial question of law arising in this appeal is kept open to be decided at the later point of time. There shall be no order as to costs. (R.S.K., J.) (C.S.N, J) 15.10.2024 Neutral Citation:Yes/No drm T.C.A.No.576 of 2015 R. SURESH KUMAR, J.ANDC. SARAVANAN, J. (drm) T.C.A.No.576 of 2015 15.10.2024
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