2018 (2) TMI 1158

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.... 1. These two Appeals under Section 260-A of the Income Tax Act, 1961 (the Act), challenge the common order dated 17th December 2014 passed by the Income Tax Appellate Tribunal (the Tribunal) for the Assessment Year 2008-09, 2009-10 & 2010-11. These two Appeals by the Revenue challenge the common impugned order dated 17th December 2014 in respect of Assessment Year 2008-09 & 2009-10. 2 The Revenu....

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....in distinguishing between the investments in subsidiary company for controlling stake and non-controlling stake to decide the applicability of Section 14A of the Act?" 3 We find that the impugned order of the Tribunal has recorded a finding of fact that in the subject Assessment Year no income in the form of dividend or otherwise was claimed as exempt income by the Respondent - Assessee. The imp....