2019 (4) TMI 1578

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....i, DR ORDER PER SMT. P. MADHAVI DEVI, J.M. This is assessee's appeal for the A.Y 2013-14 against the order of the CIT (A)-4, Hyderabad, dated 8.3.2018. The assessee has raised the following grounds of appeal: " 1. On the facts and in the circumstances of the case, the order of Commissioner of Income Tax (Appeals)-4, Hyderabad, dismissing the appeal of the Appellant is erroneous, illegal and u....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he investment in downstream subsidiary companies is out of business expediency and therefore the provisions of section 14A of the Act could not have been invoked. For these and other grounds that may be urged at the time of hearing it is prayed that the appeal may be allowed". 2. However, at the time of hearing, the learned Counsel for the assessee submitted that the disallowance made by the as....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t was held that even where the dominant purpose for making investment in shares is to gain control of the company, the provisions of section 14A r.w.r 8D are applicable. 4. Having regard to the rival contentions and the material on record, we find that the assessee has raised a specific ground that the investments were made to gain control of the subsidiary companies and therefore, it is its busi....