Court Dismisses Appeals on Disallowance Deletion; No Substantial Law Question Arises for 2014-2017 Tax Years. The court condoned the delays in filing and re-filing appeals by the appellant/revenue, with delays of 11 days, 2 days, and 118 days, respectively, after ...
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Court Dismisses Appeals on Disallowance Deletion; No Substantial Law Question Arises for 2014-2017 Tax Years.
The court condoned the delays in filing and re-filing appeals by the appellant/revenue, with delays of 11 days, 2 days, and 118 days, respectively, after considering the reasons provided. Regarding the sustenance of deletion of disallowance under Section 14A of the Income Tax Act, 1961, the court dismissed the appeals for the Assessment Years 2014-15, 2015-16, 2017-18, and 2016-17. It concluded that no substantial question of law arose concerning the Tribunal's decision to uphold the deletion of disallowance, even though no tax-exempt income was earned during the relevant period.
Issues involved: Condonation of delay in filing appeals, condonation of delay in re-filing appeals, sustenance of deletion of disallowance under Section 14A of the Income Tax Act, 1961.
Condonation of delay in filing appeals: The appellant/revenue sought condonation of delay in filing appeals ITAs 409/2023 & 411/2023 (11 days delay) and ITAs 410/2023 & 412/2023 (2 days delay). The delay was condoned based on reasons provided by the appellant/revenue, and the applications were disposed of accordingly.
Condonation of delay in re-filing appeals: Another application was filed seeking condonation of delay in re-filing the appeals, with a delay of 118 days. The delay was condoned based on reasons presented by the appellant/revenue, and the applications were disposed of accordingly.
Sustenance of deletion of disallowance under Section 14A: The appeals concerned Assessment Years 2014-15, 2015-16, 2017-18, and 2016-17. The appellant/revenue aimed to challenge the Tribunal's order dated 02.08.2022. The issue for consideration was whether the Tribunal was correct in upholding the deletion of disallowance under Section 14A of the Income Tax Act, 1961, despite no tax-exempt income being earned during the relevant period. The court referred to previous judgments and concluded that no substantial question of law arose for consideration. Therefore, the appeals were dismissed.
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