2025 (8) TMI 430

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....pellant : Shri R. Vijayaraghavan, Advocate For The Respondent : Ms. Babitha, JCIT ORDER PER JAGADISH, A.M : Aforesaid appeal filed by the assessee for Assessment Year (AY) 2017-18 arises out of the order of Learned Commissioner of Income Tax, National Faceless Appeal Centre (NFAC), Delhi [hereinafter "CIT(A)"] dated 14.03.2024 in the matter of assessment framed by the Assessing Officer....

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....Act as per Rule 8D of the Rules of Rs. 45,68,180/-. The A.O while computing the disallowance as per Rule 8D(2)(ii) of the Rules has taken the average value of investment at Rs. 61,01,07,796/- and computed 1% of average investment as disallowance u/s. 14A of the Act. The assessee has objected to adopt the investment value at Rs. 61,01,07,796/- as the investment made in the equity share and tax free....

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....es. Aggrieved, the assessee is in appeal before us. 4. The Ld. Authorized Representative (A.R) of the assessee has argued that the name of HDFC Capital Builder Fund has been changed as HDFC Capital Builder Value fund and HDFC Medium Term Opportunities fund has been changed as HDFC Corporate Bond Fund and these two funds are growth funds income of which is not exempt from tax and therefore, the ....

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....und and the assessee has not submitted any details. The Ld CIT(A) therefore, considered this fund as HDFC Mid Cap Opportunity Fund which is equity oriented fund, and income of which as long term capital gain is exempt u/s 10(38) of the Act. The Ld CIT(A), similarly in the case of HDFC Capital Builder Fund held it equity oriented fund, income of which is exempt u/s 10(38) of the Act. The Ld. AR bef....