PCIT v. Oriental Insurance Co. Ltd. (2020) 273 Taxman 527 (Delhi)(HC)

S. 4A : Disallowance of expenditure-Exempt income-Insurance Company-Provision not applicable-Ground not raised before the Tribunal cannot be argued before the High Court. [S. 44, 260 A]

Tribunal dismissed an appeal filed by revenue holding that applicability of section 14A was excluded in relation to computation of income of assessee, an insurance company.  Revenue filed an appeal claiming Tribunal should have remanded said matter to Assessing Officer for computation of income of assessee in terms of first schedule. Dismissing the appeal the Court held that   since revenue confined its challenge only in respect of applicability of section 14A and its claim was not even a ground urged before Tribunal, there was no fault in order of Tribunal. (AY. 2011-12)