AO on Kirloskar Pneumatic Company Ltd. v. Commissioner of Surtax

210 ITR 485High Court1994#3209 most cited

What is AO on Kirloskar Pneumatic Company Ltd. v. Commissioner of Surtax authority for?

Convertible debentures (CCDs) continue to be classified as debt until they are converted into equity. During the pre-conversion period, interest paid on CCDs is treated as interest on debt, not as interest on equity.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2026.

Also referred to as

Kirloskar Pneumatic Company Ltd v Commissioner of Surtax · convertible debentures · debentures · debt · equity · pre-conversion period · interest on debt · interest on equity · section 36(1)(iii)

Sections most often in play

Section 194ASection 201(1A)Section 201(1)Section 201Section 194A(3)(v)Section 194A(3)(viia)(b)Section 194A(3)(i)(b)Section 139

Issues it is cited on

section 80p(i)section 194a(3)(viia)(b)section 194a(3)(viia)(a)section 194a(3)(i)(b)section 194(3)(v)section 194a(3)(i)section 194a(v)section 194(3)(viia)(b)section 5(1)(cc)section 194a(1)section 194a(3)(v)section 194a(3)

Judgments citing AO on Kirloskar Pneumatic Company Ltd. v. Commissioner of Surtax

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MAHIM BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6440/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MAROL BRANCH) ,MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6436/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH) ,MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

ITA 6433/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

ITA 6432/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6431/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MANORI BRANCH),MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

ITA 6430/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED (MULUND BRANCH),MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

ITA 6427/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED (AMBOLI BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

ITA 6422/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO-OPERTIVE BANK LIMITED (COLABA BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6420/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED ,(CHEMBUR BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

ITA 6419/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED (BYCULLA BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

ITA 6418/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED , CHEMBUR BRANCH,MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

ITA 6417/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED ,DADAR BRANCH vs. ITO (TDS)1(1)(4), MUMBAI

ITA 6416/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED( FOUR BUNGALOWS BRANCH) ,MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

ITA 6414/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZENCREDIT CO OPERATIVE BANK LIMITED,WADALA BRANCH vs. ITO (TDS)1(1)4), MUMBAI

ITA 6409/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZEN CREDIT CO-OPERATIVE BANK LTD,MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6408/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZEN CREDIT CO-OPERATIVE BANK LTD,MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6406/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (KALINA BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6400/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (VIKHROLI BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6396/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (VAKOLA BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6393/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…ecific clauses. There are a number of judicial pronouncements wherein it has been held that a specific provision overrides a general provision. For this purpose reliance was placed by the AO on Kirloskar Pneumatic Company Ltd Vs. Commissioner of Surtax (1994) 210 ITR 485 (Bom) and CIT vs. Mahanagar Telephone Nigam Ltd (2002) 254 ITR 627(Del). The Hon'ble Supreme Court in the case of South Indian Corporation (P) Ltd Vs. Secretary, Board of Revenue AIR 1964 SC 207 has held that the special provision should be given to the extent of its scope leaving the general provision to control cases where the special provision…

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