Court Dismisses Appeal on Tax Disallowance; No Exempt Income Found, No Substantial Legal Question Raised.

The court condoned a 285-day delay in re-filing the appeal by the appellant/revenue. Regarding the deletion of disallowance under Section 14A of the Income Tax Act for AY 2013-14 and AY 2014-15, the court found that the respondent/assessee had not earned any exempt income during the relevant periods. As the issue was already addressed by prior judgments of the coordinate bench, no substantial question of law was found. Consequently, the appeals were dismissed.

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Issues:
- Condonation of delay in re-filing the appeal
- Deletion of disallowance u/s 14A of the Income Tax Act, 1961

Condonation of Delay:
The applications were moved by the appellant/revenue seeking condonation of a 285-day delay in re-filing the appeal. The delay was condoned based on the reasons provided in the applications, and the applications were disposed of accordingly.

Deletion of Disallowance u/s 14A:
The appeals pertained to Assessment Year (AY) 2013-14 and AY 2014-15. The only question raised in the appeals was regarding the deletion of disallowance made u/s 14A of the Income Tax Act, 1961. In ITA 316/2023, the disallowance was quantified at Rs.12,50,66,466, while in ITA 317/2023, the deletion of disallowance was Rs.8,41,21,936. It was found that the respondent/assessee had not earned any exempt income during the period in question. The issue was already covered by judgments of the coordinate bench of the Court, and it was noted that no substantial question of law arose for consideration. Therefore, the appeals were dismissed.

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