Section 14A Disallowance also on Strategic investments

CIT Vs Alpha G. Corp Development Ltd. (Delhi high Court)

High Court held that strategic investments have to be considered for disallowance under Section 14A but assessee is entitled to contend that the investments are legacy Investments or one-time investment and that there is in fact no expenditure incurred to earn the tax-free income.

FULL TEXT OF THE HIGH COURT ORDER / JUDGEMENT

The question of law framed by this Court in all the three appeals is as follows:

“Did the Income Tax Appellate Tribunal (ITAT) fall into error in holding that the disallowance under Section 14-A of the Income Tax Act was not warranted because the underline investment was for strategic purposes? “

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