Azadi Bachao Andolan (2003)(177 Taxation 775) and Pradip J Mehta v. CIT

300 ITR 231Supreme Court of India2008#1778 most cited

What is Azadi Bachao Andolan (2003)(177 Taxation 775) and Pradip J Mehta v. CIT authority for?

When two views are possible regarding a provision of tax law, or if there is an ambiguity, the interpretation that favors the taxpayer must be adopted. This principle is often applied in matters concerning the denial of exemptions.

64

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2024.

Also referred to as

Pradip J Mehta v CIT · 300 ITR 231 · Supreme Court · statutory interpretation · favourable to assessee rule · ambiguity in tax provisions · two views possible · tax exemption sections 11 12 · section 13 restrictions · payments to specified persons

Issues it is cited on

section 13(2)(c)section 144(b)advancement of general public utilitysection 12a(a)section 13(2)section 11(4a)section 13(3)section 13(1)(c)section 11(1)(a)section 13(1)section 40a(2)section 11(1)

Judgments citing Azadi Bachao Andolan (2003)(177 Taxation 775) and Pradip J Mehta v. CIT

MAHESWARI MINING & ENERGY PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, appeal of the assessee is allowed

ITA 1220/HYD/2019[2016-17]Status: DisposedITAT Hyderabad01 Apr 2024AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri K. Narasimha Charyassessment Years: 2016-17 Maheswari Mining & Vs. Asst. Commissioner Of Energy Pvt. Ltd., Income-Tax, Hyderabad. Circle – 16(2), Hyderabad. Pan – Aagcm0805N (Appellant) (Respondent) Assessee By: S/Shri Y. Ratnamkar& B. Satyanarayana Murthy Revenue By: Shri Y.V.S.T. Sai Date Of Hearing: 21/04/2022 Date Of Pronouncement: /04/2022

For Appellant: S/Shri Y. Ratnamkar&For Respondent: Shri Y.V.S.T. Sai
Section 143(1)Section 143(2)Section 143(3)Section 32A

…The decisions of the Hon 'ble Supreme Court which state when in ambiguity or when two views are possible the issue has to be answered in favour of the tax payer are shown below: :- 19 -: M/s Maheswari Mining & Energy Pvt. Ltd., Hyderabad. 391 ITR 1 @9 (SC) 300 ITR 231 @242 (SC) 89 ITR 236 @240 (SC) 89 ITR 251 @257 (SC) 77 ITR 518 @530 (SC) 18 For all the above reasons it is prayed that the Hon'ble ITAT be pleased to allow the appeal and direct the allowance U/s.32AD be allowed, for the Asst.Year 2016-17 of the Income Tax Act. 4.1 In addition to the above, the ld. AR of the assessee filed additional submission…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST,, JALANDHAR

ITA 344/ASR/2010[2007-08]Status: DisposedITAT Amritsar07 Dec 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 421/ASR/2009[2006-07]Status: DisposedITAT Amritsar07 Dec 2023AY 2006-07

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE DCIT, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 39/ASR/2007[2003-04]Status: DisposedITAT Amritsar07 Dec 2023AY 2003-04

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

DCIT, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 328/ASR/2007[2004-05]Status: DisposedITAT Amritsar07 Dec 2023AY 2004-05

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 177/ASR/2006[2001-02]Status: DisposedITAT Amritsar07 Dec 2023AY 2001-02

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 272/ASR/2004[1997-98]Status: DisposedITAT Amritsar07 Dec 2023AY 1997-98

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

ITA 261/ASR/2004[1999-2000]Status: DisposedITAT Amritsar07 Dec 2023AY 1999-2000

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ADDL. COMMISSIONER OF INCOME TAX, JALANDHAR

ITA 129/ASR/2002[1998-99]Status: DisposedITAT Amritsar07 Dec 2023AY 1998-99

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

ITA 186/ASR/2001[1994-95]Status: DisposedITAT Amritsar07 Dec 2023AY 1994-95

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

ITA 185/ASR/2001[1994-95]Status: DisposedITAT Amritsar07 Dec 2023AY 1994-95

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

ITA 184/ASR/2001[1993-94]Status: DisposedITAT Amritsar07 Dec 2023AY 1993-94

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…(All) 13. In case of two possible views, a view favourable to the assessee is to be preferred. The aforesaid proposition is supported by the following legal precedents : Manish Maheshwari Vs CIT [2007] 289 ITR 341 (SC); and a. Pradip J. Mehta Vs CIT [2008] 300 ITR 231 (SC) b. In view of the aforesaid, it is respectfully submitted that in the present case, there is no allegation that the payment made to specified persons were unreasonable or excessive, therefore, it is respectfully submitted, that it cannot result in complete denial of exemption under sections 11/12 of the Act.” 4. Per contra, the ld. DR reli…

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1),, VISAKHAPATNAM vs. DATLA SHANTI, VISAKHAPATNAM

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

ITA 33/VIZ/2021[2017-18]Status: DisposedITAT Visakhapatnam16 Feb 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Sri ON Hari Prasada Rao
Section 129Section 142(1)Section 143(2)Section 143(3)Section 54F

…आयकर अपील"यअ"धकरण, "वशाखापटणम पीठ, "वशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM "ी दु"वू" आर एल रे"डी, "या"यक सद"य एवं "ी एस बालाकृ"णन, लेखा सद"य के सम" BEFORE SHRI DUVVURU RL REDDY, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकर अपील सं./ I.T.A. No.33/Viz/2021 ("नधा"रण वष" / Assessment Year :2017-18) Deputy Commissioner of Income Vs. Smt. Datla Shanti, Tax, Circle-3(1), Visakhapatnam. Visakhapatnam. PAN: AJFPD 6650 D (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee by : Sri I. Kama Sastry, AR ""याथ" क" ओर से / Revenue by :…

ACIT (CIR.) - 6(1)(2), MUMBAI vs. BHANDAR POWER LTD., MUMBAI

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

ITA 6061/MUM/2016[2010-11]Status: DisposedITAT Mumbai31 May 2019AY 2010-11

Bench: Shri Mahavir Singh & Shri Rajesh Kumar

For Appellant: Shri Anuj Kisnadwala, A.RFor Respondent: Shri Chaudhary Arunkumar Singh, D.R
Section 143(1)Section 143(2)Section 80I

…that where two views are possible then view in favour of the assessee has to be taken as has been held by the Hon’ble Apex court in the case of CIT Vs Vegetable Products Ltd 88 ITR 192 (SC) , Manish Maheswari Vs ACIT 289 ITR 341(SC) and Pradip J. Mehta Vs CIT 300 ITR 231 (SC). 12. The ld AR while relying heavily on the order of CIT(A) stated that ld CIT(A) passed a very reasoned and speaking order following the decisions of the Hon’ble Apex Court, various Hon’ble High Courts and coordinate benches and therefore the order of CIT(A) may be confirmed on this issue by dismissing the ground raised by the Revenue. M/s…

DCIT (IT) 3(1)(2), MUMBAI vs. LUCENT TECHNOLOGIES CRL LLC, MUMBAI

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

ITA 678/MUM/2016[2012-13]Status: DisposedITAT Mumbai13 Aug 2018AY 2012-13

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Respondent: Shri Madhur Agarwal
Section 144Section 144C(5)Section 234BSection 271

…We are aware that the Hon’ble Karnataka High Court has held that the payment for supply of software is royalty. Thus, we have two diagonally opposite views on the same issue. In such a situation the Hon'ble Supreme Court has, in the matter of Pradip J. Mehta (300 ITR 231), held that when two views were possible, then ‘invariably, the court would adopt the interpretation which is favour of the taxpayer’. The Hon’ble Court held as under: “29. It is well-settled that when two interpretations are possible, then invariably, the court would adopt the interpretation which is in favour of the taxpayer and against the Rev…

LUCENT TECHNOLOGIES GRL LLC,MUMBAI vs. JDIT (IT) RG 4, MUMBAI

In the result, these appeals by the assessee stands allowed

ITA 7704/MUM/2012[2009-10]Status: DisposedITAT Mumbai13 Aug 2018AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Samuel Darse
Section 115Section 115ASection 144C(1)Section 144C(5)Section 44D

…We are aware that the Hon’ble Karnataka High Court has held that the payment for supply of software is royalty. Thus, we have two diagonally opposite views on the same issue. In such a situation the Hon'ble Supreme Court has, in the matter of Pradip J. Mehta (300 ITR 231), held that when two views were possible, then ‘invariably, the court would adopt the interpretation which is favour of the taxpayer’. The Hon’ble Court held as under: “29. It is well-settled that when two interpretations are possible, then invariably, the court would adopt the interpretation which is in favour of the taxpayer and against the Rev…

LUCENT TECHNOLGIES GRL LLC,MUMBAI vs. DDIT (IT) 4(1), MUMBAI

In the result, the appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 1934/MUM/2014[2010-11]Status: DisposedITAT Mumbai16 Jul 2018AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri PJ PardiwalaFor Respondent: Shri Samuel Darse, DR
Section 143(3)Section 144C(1)Section 9(1)(vi)

…We are aware that the Hon’ble Karnataka High Court has held that the payment for supply of software is royalty. Thus, we have two diagonally opposite views on the same issue. In such a situation the Hon'ble Supreme Court has, in the matter of Pradip J. Mehta (300 ITR 231), held that when two views were possible, then ‘invariably, the court would adopt the interpretation which is favour of the taxpayer’. The Hon’ble Court held as under: “29. It is well-settled that when two interpretations are possible, then invariably, the court would adopt the interpretation which is in favour of the taxpayer and against the Re…

DDIT (IT)-2(1), MUMBAI vs. M/S. RELIANCE INFOCOMM LTD., MUMBAI

ITA 837/MUM/2007[]Status: DisposedITAT Mumbai02 Feb 2018

Bench: S/Sh. Rajendra & Ravish Sood

For Appellant: S/Shri J.D. Mistry/Deepak JainFor Respondent: S/Shri Parag Vyas- DR
Section 195Section 195(2)Section 254(1)Section 40Section 9

…आयकर अपीलीय अिधकरण, मुंबई “एल ” खंडपीठ Income-tax Appellate Tribunal “L”Bench Mumbai सव"ी राजे"", लेखा सद"य एवं रिवश सूद, "याियक सद"य Before S/Sh. Rajendra,Accountant Member & Ravish Sood, Judicial Member आयकर अपील सं./I.T.A.s/837/Mum/2007; 3431/Mum/2008; 3432/Mum/2008;3433/Mum/2008;3434/Mum/2008;3435/Mum/2008; 3436/Mum/ 2008; 3437/Mum/2008; 3440/Mum/2008; 3441/Mum/ 2008; 3442/Mum/ 2008; 3443/ Mum/ 2008;3444/Mum/2008; 4245/Mum/2008;4247/Mum/2008;4249/Mum/2008;4250/Mum/2008;4251/Mum/2008;42 52/Mum/2008;4253/Mum/2008;4261/Mum/2008;4278/Mum/2008;4279/Mum/2008; 4284/Mum/ 2008; ;4285/Mum/2008; 4286/Mum/2008;4287/M…

THE DDIT (IT)-2(1), MUMBAI vs. M/S. RELIANCE COMMUNICATIOINS LTD. ( FORMERLY KNOWN AS M/S. RELIANCE INFOCOMM LTD), NAVI MUMBAI

ITA 4877/MUM/2007[]Status: DisposedITAT Mumbai02 Feb 2018

Bench: S/Sh. Rajendra & Ravish Sood

For Appellant: S/Shri J.D. Mistry/Deepak JainFor Respondent: S/Shri Parag Vyas- DR
Section 195Section 195(2)Section 254(1)Section 40Section 9

…आयकर अपीलीय अिधकरण, मुंबई “एल ” खंडपीठ Income-tax Appellate Tribunal “L”Bench Mumbai सव"ी राजे"", लेखा सद"य एवं रिवश सूद, "याियक सद"य Before S/Sh. Rajendra,Accountant Member & Ravish Sood, Judicial Member आयकर अपील सं./I.T.A.s/837/Mum/2007; 3431/Mum/2008; 3432/Mum/2008;3433/Mum/2008;3434/Mum/2008;3435/Mum/2008; 3436/Mum/ 2008; 3437/Mum/2008; 3440/Mum/2008; 3441/Mum/ 2008; 3442/Mum/ 2008; 3443/ Mum/ 2008;3444/Mum/2008; 4245/Mum/2008;4247/Mum/2008;4249/Mum/2008;4250/Mum/2008;4251/Mum/2008;42 52/Mum/2008;4253/Mum/2008;4261/Mum/2008;4278/Mum/2008;4279/Mum/2008; 4284/Mum/ 2008; ;4285/Mum/2008; 4286/Mum/2008;4287/M…

ADDL CIT 2(3), MUMBAI vs. M/S. TATA CONSULTANCY SERVICES LTD., MUMBAI

ITA 7513/MUM/2010[2005-06]Status: DisposedITAT Mumbai23 Mar 2017AY 2005-06

Bench: Shri C.N. Prasad () & Shri Ashwani Taneja ()

Section 195Section 40Section 9(1)(vi)

…2016) Capgemini Business Services (India) Ltd [2016] 68 Taxmann.com 36 (Mumbai ITAT) (dt. February 29,2016) CIT vs. Vegetable Products (88 ITR 192)(SC) Mysore Minerals vs. CIT (239 ITR 775 (SC) UOI vs. Onkar S. Kanwar (258 ITR 761)(SC) Pradip J Mehta vs CIT (300 ITR 231)(SC) Mahindra & Mahindra vs DCIT (58 TTJ 567 (Mumbai ITAT) 10. The Ld. Senior Counsel requested for upholding the order of Ld. CIT(A) in view of the aforesaid arguments and facts and circumstances of the case. 11. We have gone through the arguments made by both the sides, orders passed by the lower authorities and also the judgements relied upon…

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