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TMI Blog2018 (8) TMI 1314X X X X Extracts X X X X X X X X Extracts X X X X ..... ded against the revenue. X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT (A) be reversed and that of the Assessing Officer be restored. 4. The appellant craves leave to add, to alter, to amend or delete any of the grounds that may be urged at the time of hearing of appeal. 2. During the course of hearing, the learned Counsel for the assessee has contended that the assessee did not earn any exempted income, therefore, provisions of Section 14A cannot be invoked ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee, the provisions of section 14A cannot be invoked. The relevant observations of the judgment of the Hon'ble Delhi High Court are extracted hereunder:- "15. Turning to the central question that arises for consideration, the court finds that the complete answer is provided by the decision of this court in CIT v. Holcim India (P) Ltd. (decision dated 5th September 2014, in I. T. A. No. 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in [2015] 4 ITR-OL 246 (P&H)-- which in turn referred to two earlier decisions of the same court in CIT v. Hero Cycles Ltd. [2010] 323 ITR 518 (P&H) and CIT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204 (P&H). The second was of the Gujarat High Court in CIT v. Corrtech Energy (P.) Ltd. [2014] 223 Taxmann 130 (Guj) ; [2015] 372 ITR 97 (Guj) and the third of the Allahabad High Court in CIT v ..... X X X X Extracts X X X X X X X X Extracts X X X X
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