Case Law Details
Dy. CIT Vs. Alpha G. Corp Development Ltd. (ITAT Delhi)
The intention of the appellant to invest in the subsidiary companies was never to earn dividend but the same was made to acquire land to meet the minimum requirement of Haryana Town and Country Planning Act and to overcome the restrictions put by the Haryana Urban Land Ceiling Act, 1995. The investments in the subsidiaries were for development of business and for the commercial expediency. These investments were to get the strategic advantage to gain the benefit of synergies in the different markets. Therefore, dis allowance under section 14A was not called for in relation to such strategic investments.
FULL TEXT OF THE ITAT ORDER IS AS FOLLOWS:-
1. These are the appeals filed by the revenue against the order of the learned Commissioner (Appeals)-I, New Delhi dated 21-8-2015 and Commissioner (Appeals)-42, New Delhi dated 18-8-2015 for the assessment year 2008-09, 2011-12 and 2012-13, wherein the dis allowance on account under section 14A were deleted.
2. The Revenue has raised the following grounds of appeal for assessment year 2008-09:-
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