The Pr Commissioner of Income Tax v. M/S Coffee Day Enterprises Ltd.
Case brief
What is this about?
Karnataka High Court, ITA No.45 of 2025, decided 18.11.2025, coram B M Shyam Prasad and T.M.Nadaf, JJ. (judgment per B M Shyam Prasad, J.). Revenue appeal under Section 260-A, Income Tax Act 1961, against ITAT Bengaluru order dated 23.07.2024 in ITA No.783/Bang/2024 for AY 2017-18 concerning disallowance under Section 14A r.w. Rule 8D of the Income Tax Rules made by DCIT Central Circle-1(3), Bengaluru, against M/s Coffee Day Enterprises Ltd. Substantial questions on Circular No.5/2014 dated 11.02.2014 and on deletion of the addition answered in favour of the assessee for parity with the Court's earlier dismissal of the Revenue's appeal ITA No.2/2020 (AY 2013-14) in the assessee's own case. Keywords: Section 14A; Rule 8D; disallowance; exempt income; Circular No.5/2014; parity; ITA No.2/2020; appeal dismissed.
What did the court decide?
The Revenue's appeal is dismissed and both substantial questions of law are answered in favour of the Assessee, leaving intact the Tribunal's order deleting the Section 14A r.w. Rule 8D disallowance.