158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd.

222 ITR 183Supreme Court of India#23711 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2026 to 2026.

Sections most often in play

Section 115JBSection 14ASection 37(1)Section 92CA(3)Section 250Section 143(3)Section 80G

Issues it is cited on

section 14a(1)strategic investmentprohibited by lawright to receivesection 10(34)section 14a(2)interest on securitiessection 41(1)section 92ca(3)mercantile system of accountingsection 80p(2)(a)profits and gains of business or profession

Judgments citing 158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd.

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…fore the Ld. CIT(A), the assessee relied upon the following case laws in support of the claim that only real income could be taxed. i) State Bank of Travancore v. CIT [1986] 158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd. [1996] 88 Taxman 536/222 ITR 183 (SC) ii) Rajkot District Gopalak Co-op. Milk Producers' Union Ltd. v. CIT [1993] 204 UR 590 (Guj.) "Keeping in view of the ruling of the above case, it is submitted before your goodself for appreciation that, for the interest to be treated as 'income' of the assessee, the assessee must have a title over such receipt and where the receipt has been…

M/S Coal India Ltd., Kolkata vs. DCIT, Cir-5(1), Kolkata

ITA 1407/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 1Section 115JSection 250

…fore the Ld. CIT(A), the assessee relied upon the following case laws in support of the claim that only real income could be taxed. i) State Bank of Travancore v. CIT [1986] 158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd. [1996] 88 Taxman 536/222 ITR 183 (SC) ii) Rajkot District Gopalak Co-op. Milk Producers' Union Ltd. v. CIT [1993] 204 UR 590 (Guj.) "Keeping in view of the ruling of the above case, it is submitted before your goodself for appreciation that, for the interest to be treated as 'income' of the assessee, the assessee must have a title over such receipt and where the receipt has been…

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…fore the Ld. CIT(A), the assessee relied upon the following case laws in support of the claim that only real income could be taxed. i) State Bank of Travancore v. CIT [1986] 158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd. [1996] 88 Taxman 536/222 ITR 183 (SC) ii) Rajkot District Gopalak Co-op. Milk Producers' Union Ltd. v. CIT [1993] 204 UR 590 (Guj.) "Keeping in view of the ruling of the above case, it is submitted before your goodself for appreciation that, for the interest to be treated as 'income' of the assessee, the assessee must have a title over such receipt and where the receipt has been…

158 ITR 102 (SC) & CIT v. Shiv Prakash Janak Raj & Co. (P.) Ltd. (222 ITR 183) — Cited in 3 Judgments | BharatTax