The Tax Publishers2020 TaxPub(DT) 5410 (Mad-HC)

IN THE MADRAS HIGH COURT

VINEET KOTHARI & M.S. RAMESH, JJ.

Siva Industries & Holdings Ltd. v. CIT

Tax Case (Appeal) Nos. 777 to 779 of 2017 & CMP Nos. 19684 & 19685 of 2017

24 November, 2020

Appellant in all TCAs' by: N.V. Balaji

Respondent in all TCAs' by: J. Narayanaswamy

COMMON JUDGMENT

Vineet Kothari, J.

These Tax Case Appeals have been filed by the Assessee, challenging the order passed by the Income Tax Appellate Tribunal, 'D' Bench, Chennai, dated 7-10-2016, for the assessment years 2009-10, 2008-09 and 2010-11, by raising the following substantial questions of law :--

'1. Whether, on the facts and circumstances of the case, the Tribunal was right in confirming the disallowance made by the assessing officer under section 14A of the Act, in respect of the strategic investment made by the appellant?

2. Whether, on the facts and circumstances of the case, the Tribunal was right in confirming the disallowance under section 14A of the Act when the assessing officer has not recorded satisfaction for invoking section 14A of the Act?

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