2021 (10) TMI 1480

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..... ORDER PER KUL BHARAT, JM : This appeal filed by the Revenue is directed against the order dated 31.03.2017 of the learned CIT(A)-2, New Delhi, relating to Assessment Year 2013-14. The Revenue has raised following grounds of appeal:- 1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (A) has erred in deleting the disallowance made u/s 14A of the....

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....rade Centre and World Trade Tower amounting to Rs. 45,577/- and disallowance made invoking the provisions of section 14A of the Act of Rs. 7,24,23,249/-. 3. Aggrieved against this, the assessee filed appeal before the Ld.CIT(A), who deleted the disallowance of depreciation and disallowance on account of provisions of section 14A of the Act. 4. Aggrieved against the impugned order o....

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....record and gone through the orders of the authorities below. Apropos to Ground No. 1, Ld. Counsel for the assessee has brought to our notice the order of Hon'ble Delhi High Court rendered in ITA No. 535 & 536/Del/2015, both titled as PCIT vs Bharat Hotels Ltd. dated 11.098.2015 wherein Hon'ble Delhi High Court has decided the issues against the Revenue by observing as under:- 2.....

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....iary companies for strategic purposes. (iii) The investment during the year was made In u subsidiary company which was situated outside India and, therefore the dividend income if any received from foreign companies was not exempt." 4. The ITAT has rightly followed the decision of this Court in CIT v Holcim India Pvt. Ltd. (2014) 272 CTR (Del) 282 and held that since no exempt di....