Which sections of the Income Tax Act does 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT come up under?

It is most often cited in judgments turning on Section 37(1), Section 201(1A), Section 143(3), Section 14A, Section 250, Section 43B.

201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT

Q: How many judgments cite 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT?

44 judgments on BharatTax cite 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT (205 ITR 163), spanning 2015 to 2026.

205 ITR 163Supreme Court of India1994#2657 most cited

What is 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT authority for?

The Supreme Court holds that indirect taxes paid in the course of business are admissible as business expenditure under Section 37(1). Additionally, compensatory interest incurred on delayed payment of such indirect taxes is also allowable as a business expenditure.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Malwa Vanaspati and Chemical Co. v. CIT · Malwa Vanaspati · Section 37(1) · business expenditure · indirect tax · compensatory interest · allowable deduction · interest on tax liability · disallowance 201(1A) · income tax expenditure

Sections most often in play

Section 37(1)Section 201(1A)Section 143(3)Section 14A Section 250 Section 43B Section 69C Section 115-BBE(2)

Issues it is cited on

section 215 interest under section 201(1a)section 221 section 2(28a)section 40(a)(ii)section 201(1a)explanation to section 37 eligible business prohibited by law section 201 section 11(2)section 220

Judgments citing 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT

SHETH REALTORS,MUMBAI vs. ACIT-CC-7(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 5947/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Arun Khodpiashri Sandeep Singh Karhailsheth Realtors Vasant Oasis, Site Office, Upper Basement, Cts No.345A 1 To 3, 345A 5 To 6, Makwana Road, Marol, Andheri (East), ............... Appellant Mumbai – 400059 Pan: Aavfa3975F

For Appellant: Dr. K ShivramFor Respondent: Shri Vivek Perampurna, CIT-DR

Section 133(6)Section 139(1)Section 2(24)(x)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI ARUN KHODPIA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER Sheth Realtors Vasant Oasis, Site Office, Upper Basement, CTS No.345A 1 to 3, 345A 5 to 6, Makwana Road, Marol, Andheri (East), ............... Appellant Mumbai – 400059 PAN: AAVFA3975F v/s Assistant Commissioner of Income Tax, Central Circle - 7(1), ……………… Respondent 653, Aayakar Bhavan, 6th Floor, M.K. Road, Mumbai – 400020 Assessee by : Dr. K Shivram Shri Rahul Hakkani Revenue by : Shri Vivek Perampurna, CIT-DR Date of Hearing – 14/01/2026 Date of Order - 19/01/202…

DCIT-C-6(2), MUMBAI vs. SAMIRA HABITATS INDIA LIMITED, MUMBAI

In the result, the cross-objection by the assessee for the assessment year 2012-13 is dismissed

ITA 5714/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 May 2025AY 2012-13

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailita No.5714/Mum/2024 Assessment Year : 2011-12 Assessment Year : 2012-13 Assessment Year : 2009-10

For Appellant: Shri Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 132(4)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.5714/MUM/2024 Assessment Year : 2011-12 Assessment Year : 2012-13 Assessment Year : 2009-10 DCIT- Central Circle-6(2), Room No.450, Kautilya Bhawan, BKC, Maharashtra – 400051 ……………. Appellant v/s Samira Habitats India Limited G-8, Shrikant Chambers, Sion Tromboy Road, Chembur, ……………. Respondent Maharashtra - 400071 PAN: AABCS1677F CO No.12/MUM/2025 CO No.13/MUM/2025 (Arising out of ITA No.5709/Mum/2024) (Arising out of ITA No.5714/Mum/2024) Assessm…

SPB PROJECTS AND CONSULTANCY LTD.,CHENNAI vs. ITO CORP. WARD 6(1), CHENNAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 3303/CHNY/2024[2022-23]Status: DisposedITAT Chennai14 Mar 2025AY 2022-23

Bench: Shri George George K & Shri Jagadish

For Appellant: Shri N.R.Suresh, F.C.AFor Respondent: Ms. Anitha, Addl.CIT

Section 143(1)Section 201Section 250Section 36(1)(va)Section 37Section 37(1)Section 43B

…ls Co. (supra) also relied on the decisions of the Apex Court in the cases of Prakash Cotton Mills (P.) Ltd. v. CIT[1993] 201 ITR 684/67 Taxman 546; Malwa Vanaspati & Chemical Co. v. CII[1997] 225 ITR 383 and CIT v. Ahmedabad Cotton Mfg. Co. Ltd. v. CIT[1994] 205 ITR 163. In all those cases, the Court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further, liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases i…

UPAKAR INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. ACIT, CENT CIR-2(4), HYDERABAD

In the result, the appeal of the revenue is dismissed

ITA 379/HYD/2023[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Madan Mohan Meena

Section 132Section 139Section 143(2)Section 153CSection 201Section 36(1)(iii)

…kshmi Sugar Mills Co. also relied on the decision of the apex court in the cases of Prakash Cotton Mills Pvt. Ltd. V. CIT [1993] 201 ITR 684; Malwa Vansapati and Chemical Co. v. CIT [1997] 225 ITR 383 and CIT vs. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. 3. The ratio of those cases is not applicable here. Income-tax is not allowable as business expenditure. The amount of tax deducted is not an item of expenditure. 4. We therefore, follow…

UPAKAR INFRA PROJECTS PRIVATE LIMITED,HYDERABAD vs. ACIT, CENT CIR-2(4), HYDERABAD

In the result, the appeal of the revenue is dismissed

ITA 378/HYD/2023[2012-13]Status: DisposedITAT Hyderabad07 Jan 2025AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Madan Mohan Meena

Section 132Section 139Section 143(2)Section 153CSection 201Section 36(1)(iii)

EASTERN CARGO CARRIERS (INDIA) PRIVATE LIMITED,MUMBAI, MAHARASHTRA, INDIA vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT

In the result, the appeal of the In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 4610/MUM/2023[2021-2022]Status: DisposedITAT Mumbai20 Dec 2024AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 M/S Eastern Cargo Carriers (India) The Assessment Unit, Income Tax Pvt. Ltd., Department, Vs. Unit No. 26, Adarsh Ind. Estates, Aaykar Bhavan, M.K. Road, Sahar Road, Andheri East, Mumbai-400020. Mumbai-400099. Pan No. Aaace 1520 E Appellant Respondent

For Appellant: Mr. Niraj Sheth a/wFor Respondent: Mr. Hemanshu Joshi, Sr. DR

Section 40A(2)(a)

…T [1993] 201 ITR [1993] 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT Malwa Vanaspati and Chemical Co. v. CIT [1997] 225 [1997] 225 ITR 383 and CIT v. Ahmedabad Cotton 383 and CIT v. Ahmedabad Cotton Manufacturing Co. Ltd. Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an 205 ITR 163. In all these cases, the court was concerned with an 205 ITR 163. In all these cases, the court was concerned with an M/s Eastern Cargo Carriers (India) Pvt. Ltd. M/s Eastern Cargo Carriers (India) Pvt. Ltd. 14 indirect tax payable by the assessee in the course of its business indir…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6 4 MUMBAI, MUMBAI vs. INDIABULLS HOUSING FINANCE LIMITED, NEW DELHI

In the result the revenue’s appeal is dismissed

ITA 1536/MUM/2024[2021-22]Status: DisposedITAT Mumbai09 Oct 2024AY 2021-22

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 143(2)Section 14ASection 14A(1)Section 250Section 37

…tion to section 37(1) of the Act are not detected. 16. In the instant case, learned CIT(A) has deleted the aforesaid disallowance made by learned assessing officer on the strength of Hon’ble Supreme Court Judgement in CIT V Ahmedabad Cotton Mfg Co. Ltd (1993) 205 ITR 163 (SC) and referred the relevant part of the order as under: “...what needs to be done by an assessing authority law I.T. Act, 1961 in examining the claim of an assessee that the payment made by such assessee was a deductible expenditure under section 37 of the I.T. Act although called penalty is, to see whether the law or scheme under which the am…

ACIT 14 (1)(2), MUMBAI, MUMBAI vs. SHRIRAM CHITS MAHARASTRA LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 66/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jun 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

For Appellant: Mr. Raghav MenonFor Respondent: Mr. Ashok Kumar Ambastha, Sr. DR

Section 37(1)

…. Ltd. V. CIT [1993] 201 ITR 684; Malwa Vansapati and Chemical V. CIT [1993] 201 ITR 684; Malwa Vansapati and Chemical Co. v. CIT [1997] 225 ITR 383 and CIT vs. Ahmedabad Co. v. CIT [1997] 225 ITR 383 and CIT vs. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and payable by the assessee in the course of its business and admissible as business expenditure. 3. The ratio of those cases is…

M/S POTHYS,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(3), CHENNAI

The appeal is allowed

ITA 1360/CHNY/2023[2020-21]Status: DisposedITAT Chennai15 May 2024AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No. 1360/Chny/2023 (िनधा"रणवष" / Assessment Year: 2020-21) M/S. Pothys, Vs. The Deputy Commissioner Of No.15, Dr.Nageswara Rao Road, Income Tax, T. Nagar, Central Circle 1(3), Chennai – 600 017. Chennai. [Pan: Aaffp 2437B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjun Raj, Advocate For Shri Y. Sridhar, Ca ""यथ" क" ओर से /Respondent By : Shri Ar.V. Srinivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 09.05.2024 घोषणा क" तारीख /Date Of Pronouncement : 15.05.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri AR.V. Srinivasan, Addl. CIT

Section 143(3)Section 200Section 206Section 206CSection 234ESection 37Section 91

…ons connected with the assessee, i.e., from whom tax has been deducted at source without any delay and accurately with increasing or overloading the burden of the department.” 10. In the case of CIT v. Ahmedabad Cotton Mfg. Co. Ltd. [1993] 71 Taxman 56/[1994] 205 ITR 163 (SC), the Hon’ble Supreme Court ruled that when an assessing authority examines claim for a deductible expenditure under section 37, which is nature of penalty, it should oversee that whether any law or act required such payment to be made as a way of punishment for violation of any law . If it is not found that penalty is paid for any violation…

M/S.G.S. ATWAL & CO.(ENGG)(P)LTD,KOLKATA vs. DCIT, CIR-11(1), KOLKATA

In the result, both the appeals of the assessee are dismissed

ITA 1009/KOL/2023[2018-19]Status: DisposedITAT Kolkata29 Apr 2024AY 2018-19

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

For Appellant: Shri Soumitra Choudhury, Advocate & ShriFor Respondent: Shri B. K. Singh, JCIT, Sr. DR

Section 139(1)Section 143(1)Section 143(3)Section 201Section 36(1)(va)

…akshmi Sugar Mills Co. also relied on the decision of the Apex Court in the cases of Prakash Cotton Mills Pvt. Ltd. v. CIT [1993] 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT [1997]/225 ITR 383 and CIT v. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases is…

M/S.G.S. ATWAL & CO.(ENGG) (P)LTD.,KOLKATA vs. DCIT, CIR-11(1), KOLKATA

In the result, both the appeals of the assessee are dismissed

ITA 1008/KOL/2023[2017-18]Status: DisposedITAT Kolkata29 Apr 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

For Appellant: Shri Soumitra Choudhury, Advocate & ShriFor Respondent: Shri B. K. Singh, JCIT, Sr. DR

Section 139(1)Section 143(1)Section 143(3)Section 201Section 36(1)(va)

EXPAT ENGINEERING INDIA LIMITED,BENGALURU vs. ACIT, CIRCLE-2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 34/BANG/2023[2014-15]Status: DisposedITAT Bangalore09 Nov 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

For Appellant: Shri Ravi Shankar, A.RFor Respondent: Shri Parithivel, D.R

Section 143Section 250

…lakshmi Sugar Mills Co. also relied on the decision of the apex court in the cases of Prakash Cotton Mills Pvt Ltd. v. CIT [1993] 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT [1997] 225 ITR 383 and CIT v. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases is…

FLEMINGO DUTYFREE SHOP PVT LTD,MUMBAI vs. DCIT, CEN-CIR-8(4), MUMBAI

In the result, the appeal of the assessee is dismissed

ITA 2218/MUM/2023[2016-2017]Status: DisposedITAT Mumbai16 Oct 2023AY 2016-2017

Bench: Shri Aby T Varkey & Shri Amarjit Singhflemingo Dutyfree Shop Vs. Dcit, Central Circle-8(4) Private Limited, 6Th Floor, Aayakar D-73/1 Ttc D-73/1 Ttc Bhavan, M.K. Road, Industrial Area, New Marine Lines, Midc Turbhe, Churchgate, Navi Mumbai – 400705 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacf7909E Appellant .. Respondent [ Appellant By : J.P. Baragra Respondent By : Ujjawal Kumar Chavan Date Of Hearing 26.09.2023 Date Of Pronouncement 16.10.2023

For Appellant: J.P. BaragraFor Respondent: Ujjawal Kumar Chavan

Section 143(2)Section 201Section 37(1)

…lakshmi Sugar Mills Co. also relied on the decision of the apex court in the cases of Prakash Cotton Mills Pvt Ltd. v. CIT [1993] 201 ITR 684 ; Malwa Vanaspati and Chemical Co. v. CIT [19971 225 ITR 383 and CITv. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases is…

THE ACIT, CIRCLE-2,, JAMNAGAR vs. SAURASHTRA CEMENT LTD.,, PORBANDAR

In the result, appeal filed by the Revenue is dismissed and appeal filed by the Assessee is partly allowed

ITA 476/RJT/2014[2010-11]Status: DisposedITAT Rajkot05 Jul 2023AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

Section 14ASection 40Section 40A(9)

…covery of value of the minerals” used in the show cause notice, the recovery is in direct proportion of the quantum of the Basalt. The Ld. AR relied upon the decision of Hon’ble Apex Court in the case of CIT vs. Ahmedabad Cotton Manufacturing Company Limited, 205 ITR 163 17. We have heard both the parties and perused all the relevant material available on record. It is pertinent to note that the dispute centres around treating the recovery of differential royalty on Basalt by the Government of Gujarat as in the nature of Penalty. But the assessee’s contention is that the same is not penalty but it is value of mi…

SAURASHTA CEMENT LTD.,,PORBANDAR vs. THE JOINT COMMISSIONER OF INCOME TAX, RANGE-2,, JAMNAGAR

In the result, appeal filed by the Revenue is dismissed and appeal filed by the Assessee is partly allowed

ITA 457/RJT/2014[2010-11]Status: DisposedITAT Rajkot05 Jul 2023AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

Section 14ASection 40Section 40A(9)

EXPAT ENGINEERING INDIA LIMITED,BENGALURU vs. ACIT, CIRCLE-2(1)(2), BENGALURU

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1139/BANG/2022[2016-17]Status: HeardITAT Bangalore30 Mar 2023AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am

For Appellant: Sri.Ravishankar S.V., AdvocateFor Respondent: Sri.Gudimella VP Pavan Kumar, JCIT-DR

Section 143(2)Section 143(3)Section 201Section 250Section 37

…ring India Limited. Co. also relied on the decision of the apex court in the cases of Prakash Cotton Mills Pvt Ltd. v. CIT [1993] 201 ITR 684; Malwa Vanaspati and Chemical Co. v. CIT [1997] 225 ITR 383 and CIT v. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases is…

M/S PREMIER IRRIGATION ADRITEC (P) LTD.,KOLKATA vs. ACIT, CIR-11(1), KOLKATA , KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 387/KOL/2021[2014-15]Status: DisposedITAT Kolkata20 Jan 2023AY 2014-15

Bench: Shri Sanjay Garg & Shri Girish Agrawal

Section 2(24)Section 250Section 3Section 36(1)Section 36(1)(va)Section 43B

…alakshmi Sugar Mills Co. also relied on the decision of the apex court in the cases of Prakash Cotton Mills Pvt Ltd. v. CIT [1993] 201 ITR 684 ; MalwaVanaspati and Chemical Co. v. CIT [19971 225 ITR 383 and CITv. Ahmedabad Cotton Manufacturing Co. Ltd. [1994] 205 ITR 163. In all these cases, the court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further liability for interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases is…

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (LTU) , BANGALORE

In the result, the appeal filed by the assessee is partly allowed

ITA 2835/BANG/2017[2013-14]Status: DisposedITAT Bangalore20 Jan 2023AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2835/Bang/2017 : Asst.Year 2013-2014 M/S.Dell International Services The Additional Commissioner India Private Limited Of Income-Tax (Ltu) V. Bangalore. Divyashree Greens, Sy.Nos.12/1, 12/2A & 13/1A,Challaghatta Village,Varthur Hobli Bengaluru – 560 071. Pan : Aaach1925Q. (Appellant) (Respondent) Appellant By : Sri.T.Suryanarayana, Advocate Respondent By : Sri.Praveen Karanth, Cit-Dr Date Of Pronouncement : 20.01.2023 Date Of Hearing : 13.01.2023 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.11.2017 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company, Engaged In The Business Of Manufacturing & Trading In Computer Systems Including Support & Maintenance Services & Leasing Of Computers. For The Assessment Year 2013-2014, The Return Of Income Was Filed On 30.11.2013 Declaring Total Income Of Rs.22,31,24,760. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Issued On 2 It(Tp)A No.2835/Bang/2017. M/S.Dell International Services India Private Limited. 11.09.2014. During The Course Of Assessment Proceedings, It Was Noticed That The International Transactions Entered By The Assessee With Its Associated Enterprises (Aes) Had Exceeded The Prescribed Limit, Hence, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The Said Transaction. The Tpo Passed Order U/S 92Ca Of The I.T.Act On 19.10.2016. In The Said Order, The Tpo Had Proposed Following Adjustments:-

For Appellant: Sri.T.Suryanarayana, AdvocateFor Respondent: Sri.Praveen Karanth, CIT-DR

Section 143(2)Section 143(3)Section 144CSection 40Section 92CSection 92C(3)

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

ITA 1982/BANG/2018[2012-13]Status: DisposedITAT Bangalore12 Jan 2023AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R

Section 143(3)

…Co. (supra) also relied on the decisions of the Apex Court in the cases of Prakash Cotton Mills (P.) Lid, v. CIT [1993] 201 ITR 684 / 67 Taxman 546; Malwa Vanaspati & Chemical Co. v. CIT[1997] 225 ITR 383 and CIT v. Ahmedabad Cotton Mfg. Co. Ltd. V. CIT[1994] 205 ITR 163. In all those cases, the Court was concerned with an indirect tax payable by the assessee in the course of its business and admissible as business expenditure. Further. liability for' interest which had been incurred by the assessee therein was regarded as compensatory in nature and allowable as business expenditure. 16. The ratio of those cases…

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

ITA 1981/BANG/2018[2010-11]Status: DisposedITAT Bangalore12 Jan 2023AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R

Section 143(3)

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