IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 20-01-2026 CORAM THE HON'BLE DR.JUSTICE ANITA SUMANTH AND THE HON'BLE MR.JUSTICE MUMMINENI SUDHEER KUMAR TCA No.169 of 2013 M/s IDFC Limited KRM Towers, 8^th Floor, No.1, Harringon Road, Chetpet, Chennai – 600 031.

..Appellant Vs The Assistant Commissioner Of Income Tax, Company Circle II(3), Chennai.

..Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against Income Tax Appeal No.101/Mds/2012 dated 28.09.2012 on the file of the Income Tax Appellate Tribunal, Chennai “C” Bench for the assessment year

2007 – 2008.

For Appellant(s): Mr.Niraj Sheth For Respondent(s): Mr.T.Ravikumar Senior Standing Counsel

JUDGMENT

(Judgment of the Court was delivered by Dr.Anita Sumanth J.)

This Tax Case (Appeal) relating to assessment year 2007-08 has been filed at the instance of the assessee assailing order dated 28.09.2012 passed by the Income Tax Appellate Tribunal (in short ‘ITAT”/’Tribunal’).

2. The substantial questions of law that had been admitted on 19.06.2013 are as follows:

1. Whether the Income Tax Appellate Tribunal erred in holding that the deduction to which the appellant was entitled under Section 36(1)(viia)(c) of