Ahmadabad and Gujarat Gas Financial\nServices Ltd. v. ACIT

307 ITR 370Reported decision#10502 most cited

What is Ahmadabad and Gujarat Gas Financial\nServices Ltd. v. ACIT authority for?

A provision towards country risk cannot be claimed as a deduction solely because it is made as per RBI regulations.

10

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2025 to 2025.

Also referred to as

Ahmadabad and Gujarat Gas Financial Services Ltd. v. ACIT · 307 ITR 370 · country risk provision · deduction · RBI regulations · New India Industries Ltd. V. ACIT

Sections most often in play

Section 5(2)Section 115ASection 143(3)Section 144C(13)Section 234BSection 234DSection 244ASection 270A

Issues it is cited on

section 9(1)(v)section 92ca(3a)section 44cuse of equipmentsection 92c(1)section 28(iv)section 9(1)(i)interest under section 234csection 5(2)transfer pricing ordersection 115asection 36(1)(viia)

Judgments citing Ahmadabad and Gujarat Gas Financial\nServices Ltd. v. ACIT

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

…issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of the revenue.” 23. The facts for the year under consideration being identical, respectfully following the decision of the…

Ahmadabad and Gujarat Gas Financial\nServices Ltd. v. ACIT (307 ITR 370) — Cited in 10 Judgments | BharatTax