ACIT Vs NDL Ventures Limited (ITAT Mumbai)
Facts/Background
The appeal was filed by the Revenue against the order dated 29.03.2025 passed by the Ld. Commissioner of Income-tax (Appeals)-48, Mumbai [Ld. CIT(A)] for Assessment Year (A.Y.) 2018-19 in ITA No. 3899/MUM/2025, involving NDL Ventures Limited. The assessee is engaged in the business of Media and Communication, trading in securities, real estate, etc.
For A.Y. 2018-19, the assessee filed its return of income on 25.10.2018. The return was processed under Section 143(1) of the Income-tax Act, 1961. Subsequently, the case was selected for scrutiny. During the assessment proceedings, the Assessing Officer (AO) observed that the assessee made investments in equity shares yielding exempt income of ₹10,88,15,186/- during the year. The assessee submitted that it had earned exempt income and had suo moto disallowed ₹5,01,67,393/- under Section 14A. The AO invoked Section 14A read with Rule 8D, computed the total disallowance at ₹10,88,15,186/-, and added the differential amount of ₹5,86,47,793/- back to the assessee’s income. Additionally, the AO made a disallowance regarding Section 80G deduction for Corporate Social Responsibility (CSR) expenditure under Section 135 of the Companies Act, 2013, holding it to be specially prohibited under Section 37(1) of the Act.
Aggrieved, the assessee appealed before the Ld. CIT(A).
