3 In Steel Containers Ltd. v. CIT

112 ITR 995High Court1978#14698 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2015 to 2026.

Sections most often in play

Section 142(2A)Section 143(3)Section 147 of the Income Tax Act Section 148 of the Income Tax Act Section 153C of the Income Tax Act Section 153D of the Income Tax Act Section 1961 Section 250 of the Income Tax Act

Judgments citing 3 In Steel Containers Ltd. v. CIT

DCIT Central Circle 1 Delhi, Delhi vs. Sahara India Financial Corporation Ltd, Lucknow

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11

Section 142Section 250Section 269SSection 271D

…ified, it would be open to the departmental authorities and the Tribunal, and indeed they would be under a duty, to grant that relief. The right of the assessee to relief is not restricted to the plea raised by him." 3.3 In Steel Containers Ltd. v. CIT (1978) 112 ITR 995 (Cal), the A.O. disallowed a portion of the remuneration paid to Balmer Lawrie and Co. Ltd. as excessive in terms of section 40(c)(i) of the Act. The ITAT found that section 40(c)(i) of the Act could not apply to the allowance or remuneration paid to Balmer Lawrie and Co. Ltd., it being a corporate entity. The disallowance could not be made under…

Assistant Commissioner of Income Tax, Central Circle-25 New Delhi, Delhi vs. Faridabad Presswell Pvt Ltd, Delhi

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

…ified, it would be open to the departmental authorities and the Tribunal, and indeed they would be under a duty, to grant that relief. The right of the assessee to relief is not restricted to the plea raised by him." 5.3 In Steel Containers Ltd. v. CIT (1978) 112 ITR 995 (Cal), the A.O. disallowed a portion of the remuneration paid to Balmer Lawrie and Co. Ltd. as excessive in terms of section 40(c)(i) of the Act. The ITAT found 16 that section 40(c)(i) of the Act could not apply to the allowance or remuneration paid to Balmer Lawrie and Co. Ltd., it being a corporate entity. The disallowance could not be mad…

Shri Om Prakash Patidar (HUF), Indore vs. The ITO 2(4), Indore

In the result, appeal of the assessee is partly allowed

ITA 220/IND/2017[2013-14]Status: DisposedITAT Indore03 Jan 2019AY 2013-14

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2013-14

Section 131(1)Section 143(3)

…that misquoting of a section is not fatal to the case of the Revenue. For this proposition, he relied on the following case law: 9 [ITA No.220/Ind/2017] [Shri Om Prakash Patidar (HUF), Indore] ITR 529 (Bom.) (ii) Steel containers Lt.d v. Commissioner (1978) 112 ITR 995 (Cal.) and (iii) D.M. Neterwalla v. Commissioner (1980) 122 ITR 880 (Bom.) The above decisions point out to one thing that the Tribunal has power to allow the Revenue to raise a ground for the first time before it. It is also held therein that the Tribunal can uphold disallowance under another section. In the light of the above decisions we hold…

Ram Lal, New Delhi vs. ITO, Ward-33(4), New Delhi

In the result appeal filed by assessee against the penalty proceedings stands allowed

ITA 2231/DEL/2018[2011-12]Status: DisposedITAT Delhi31 Oct 2018AY 2011-12

Bench: Smt. Beena A Pillai & Shri Maharishi Prashantay: 2011-12 Sh. Ram Lal Ito, Ward 33(4) C/O M/S Rra New Delhi Vs. Taxindia D-28, South Extension Part I New Delhi 110 049 Pan: Accpl5384L & Ay: 2011-12 Sh. Ram Lal Ito, Ward 24(4) C/O M/S Rra New Delhi Vs. Taxindia D-28, South Extension Part I New Delhi 110 049 Pan: Accpl5384L

For Appellant: Sh. Ashwani Taneja, Sh. Somil AgarwalFor Respondent: Sh. Surender Pal, Sr. D.R

Section 143(3)Section 24Section 271(1)Section 69Section 80C

…h stands unfulfilled even as on date. Placing reliance upon the decision of Hon’ble Allahabad High Court in the case of Sneh Lata vs CIT reported in 61 ITR 139 and decision of Hon’ble Calcutta High Court in the case of Steel Containers Ltd vs. CIT reported in 112 ITR 995 Ld.Sr.DR submitted that the addition deserves to be confirmed as assessee has not discharged its onus of explaining the cash deposits as per law. 10. We have perused submissions advanced by both sides in the light of records placed before us. 10.1. The facts of the case are rather glaring and one-sided. The appellant accepts and admits that cash…

Sh. Ram Lal, New Delhi vs. ITO, New Delhi

In the result appeal filed by assessee against the penalty proceedings stands allowed

ITA 1692/DEL/2016[2011-12]Status: DisposedITAT Delhi31 Oct 2018AY 2011-12

For Appellant: Sh. Ashwani Taneja, Sh. Somil AgarwalFor Respondent: Sh. Surender Pal, Sr. D.R

Section 143(3)Section 24Section 271(1)Section 69Section 80C

C.K. Ramakrishna, Bangalore vs. ITO, Bangalore

In the result, the assessee's appeal for Assessment Year 2009-10 is dismissed

ITA 550/BANG/2014[2009-10]Status: DisposedITAT Bangalore30 Jul 2015AY 2009-10

For Appellant: Shri Raghavendra Chakravarthi, C.AFor Respondent: Shri O.P. Yadav, CIT (D.R)

Section 143(3)Section 234BSection 68Section 69

…a section is not fatal to the case of the Revenue. For this proposition, he relied on the following case law : (i) CIT vs. Gilbert and Barker Manufacture Inc. Co. U.S.A. 1977 CTR (Bom) 347 : (1978) 111 ITR 529 (Bom). (ii) Steel Containers Ltd. vs. CIT (1978) 112 ITR 995 (Cal), and (iii) D.M. Neterwalla vs. CIT (1980) 122 ITR 880 (Bom). The above decisions point out to one thing that the Tribunal has power to allow the Revenue to raise a ground for the first time before it. It is also held therein that the Tribunal can uphold 8 disallowance under another section. In the light of the above decisions we hold that…