Calcutta Co. Ltd. v. CIT

ITA 476/PUN/2016[2011-12]Status: DisposedITAT Pune15 Oct 2018AY 2011-12

…made on scientific basis. The ld. AR vehemently supported the findings of DRP and further substantiate its submissions by placing reliance on the following decisions: i. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii. Calcutta Co. Ltd. Vs. CIT, 37 ITR 1 (SC); iii. Bharat Earth Movers Vs. CIT, 245 ITR 428 (SC). 4. On the other hand Shri Rajeev Kumar representing the Department submitted that from the details furnished by the assessee relating to corporate cost allocation as head wise expenses and allocation policy the Assessing Officer observed that the cost allocation does not relate itself to any…

Eaton Fluid Power Ltd., Pune vs. Deputy Commissioner of Income-Tax

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vishal KalraFor Respondent: Shri Rajeev Kumar

ITA 506/PUN/2015[2010-11]Status: DisposedITAT Pune15 Oct 2018AY 2010-11

…made on scientific basis. The ld. AR vehemently supported the findings of DRP and further substantiate its submissions by placing reliance on the following decisions: i. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii. Calcutta Co. Ltd. Vs. CIT, 37 ITR 1 (SC); iii. Bharat Earth Movers Vs. CIT, 245 ITR 428 (SC). 4. On the other hand Shri Rajeev Kumar representing the Department submitted that from the details furnished by the assessee relating to corporate cost allocation as head wise expenses and allocation policy the Assessing Officer observed that the cost allocation does not relate itself to any…

Eaton Fluid Power Ltd., Pune vs. Deputy Commissioner of Income-Tax

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vishal KalraFor Respondent: Shri Rajeev Kumar

ITA 493/PUN/2015[2010-11]Status: DisposedITAT Pune15 Oct 2018AY 2010-11

…made on scientific basis. The ld. AR vehemently supported the findings of DRP and further substantiate its submissions by placing reliance on the following decisions: i. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii. Calcutta Co. Ltd. Vs. CIT, 37 ITR 1 (SC); iii. Bharat Earth Movers Vs. CIT, 245 ITR 428 (SC). 4. On the other hand Shri Rajeev Kumar representing the Department submitted that from the details furnished by the assessee relating to corporate cost allocation as head wise expenses and allocation policy the Assessing Officer observed that the cost allocation does not relate itself to any…

Deputy Commissioner of Income-Tax vs. Eaton Fluid Power Ltd., Pune

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vishal KalraFor Respondent: Shri Rajeev Kumar

ITA 2057/DEL/2017[2010-11]Status: DisposedITAT Delhi08 Oct 2018AY 2010-11

…made on scientific basis. The ld. AR vehemently supported the findings of DRP and further substantiate its submissions by placing reliance on the following decisions: i. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii. Calcutta Co. Ltd. Vs. CIT, 37 ITR 1 (SC); iii. Bharat Earth Movers Vs. CIT, 245 ITR 428 (SC). 4. On the other hand Shri Rajeev Kumar representing the Department submitted that from the details furnished by the assessee relating to corporate cost allocation as head wise expenses and allocation policy the Assessing Officer observed that the cost allocation does not relate itself to any…

Pyramid Realtors Pvt. Ltd., New Delhi vs. ACIT, New Delhi

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Shri Pradeep Singh Gautam

ITA 2056/DEL/2017[2010-11]Status: DisposedITAT Delhi08 Oct 2018AY 2010-11

…regarding offering of income from sanctioned FSI. Whenever FSI is sanctioned, assessee- company offered the income for taxation and claimed proportionate development expenses. He has submitted that the Hon’ble Supreme Court in the case of Calcutta Co. Ltd. 37 ITR 1 it was held that “the expression profit or gains in Income Tax Act has to be understood in its commercial sense and there can be no computation of such profits and gains until the expenditure which is necessary for the purpose of earning the receipt is deducted therefrom”. Learned Counsel for the Assessee further submitted that when the assessee…

Saga Developers Pvt. Ltd., New Delhi vs. ACIT, New Delhi

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Shri Pradeep Singh Gautam

ITA 2054/DEL/2017[2010-11]Status: DisposedITAT Delhi08 Oct 2018AY 2010-11

…regarding offering of income from sanctioned FSI. Whenever FSI is sanctioned, assessee- company offered the income for taxation and claimed proportionate development expenses. He has submitted that the Hon’ble Supreme Court in the case of Calcutta Co. Ltd. 37 ITR 1 it was held that “the expression profit or gains in Income Tax Act has to be understood in its commercial sense and there can be no computation of such profits and gains until the expenditure which is necessary for the purpose of earning the receipt is deducted therefrom”. Learned Counsel for the Assessee further submitted that when the assessee…

Saamag Construction Ltd., New Delhi vs. ACIT, New Delhi

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Shri Pradeep Singh Gautam

ITA 2053/DEL/2017[2010-11]Status: DisposedITAT Delhi08 Oct 2018AY 2010-11

…regarding offering of income from sanctioned FSI. Whenever FSI is sanctioned, assessee- company offered the income for taxation and claimed proportionate development expenses. He has submitted that the Hon’ble Supreme Court in the case of Calcutta Co. Ltd. 37 ITR 1 it was held that “the expression profit or gains in Income Tax Act has to be understood in its commercial sense and there can be no computation of such profits and gains until the expenditure which is necessary for the purpose of earning the receipt is deducted therefrom”. Learned Counsel for the Assessee further submitted that when the assessee…

Saamag Developers Pvt. Ltd., New Delhi vs. ACIT, New Delhi

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Shri Pradeep Singh Gautam

ITA 4474/MUM/2017[2011-12]Status: DisposedITAT Mumbai07 Sept 2018AY 2011-12

…regarding offering of income from sanctioned FSI. Whenever FSI is sanctioned, assessee- company offered the income for taxation and claimed proportionate development expenses. He has submitted that the Hon’ble Supreme Court in the case of Calcutta Co. Ltd. 37 ITR 1 it was held that “the expression profit or gains in Income Tax Act has to be understood in its commercial sense and there can be no computation of such profits and gains until the expenditure which is necessary for the purpose of earning the receipt is deducted therefrom”. Learned Counsel for the Assessee further submitted that when the assessee…

Maharashtra Industrial Development Corporation, Mumbai vs. Deputy Commissioner Income Tax (Exemptions)-2(1), Mumbai

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri G.S.Pannu, Am & Shri Ravish Sood, Jm Maharashtra Industrial Deputy Commissioner Of Income Development Corporation Tax (Exemption)-2(1), बिधम/ Udyog Sarathi, Mahakali Piramal Chambers, Lalbaug, Vs. Caves Road, Andheri (East), Mumbai-400 012 Mumbai-400 093 स्थामी रेखा सं./ जीआइआय सं./ Pan No. Aaacm3560C (अऩीराथी /Appellant) (प्रत्मथी / Respondent) :

For Appellant: Shri V. Sridharan &For Respondent: Shri Purushottam Tripuri, CIT D.R

Section 143(3)Section 2Section 60Section 61Section 62

…P a g e | 1 ITA No. 4474/Mum/2017 A.Y 2011-12 Maharashtra Industrial Development Corporation Vs. Deputy Commissioner of Income Tax (Exemption) -2(1) IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI G.S.PANNU, AM AND SHRI RAVISH SOOD, JM Maharashtra Industrial Deputy Commissioner of Income Development Corporation Tax (Exemption)-2(1), बिधम/ Udyog Sarathi, Mahakali Piramal Chambers, Lalbaug, Vs. Caves Road, Andheri (East), Mumbai-400 012 Mumbai-400 093 स्थामी रेखा सं./ जीआइआय सं./ PAN No. AAACM3560C (अऩीराथी /Appellant) (प्रत्मथी / Respondent) : अऩीराथी की ओय से / Appellant by : Shri V. Sridhar…

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 4370/MUM/2015[2007-08]Status: DisposedITAT Mumbai29 Aug 2018AY 2007-08

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…are computed, a sense in which no commercial man would misunderstand, had been regarded as a principle of general application, and there is a catena of cases of this court which affirms that principle. Reference may be made to Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC), CIT v. Bai Shirinbai K. Kooka [1962] 46 ITR 86 (SC), Poona Electric Supply Co. Ltd. v. CIT [1965] 57 ITR 521 (SC), CIT v. Birla Gwalior (P.) Ltd. [1973] 89 ITR 266 (SC) and Bafna Textiles v. ITO [1975] 98 ITR 1 (Kar). What is the profit or gains which can be said to accrue or arise to the assessee when lie makes over his personal asset to the…

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 3237/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2018AY 2008-09

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…are computed, a sense in which no commercial man would misunderstand, had been regarded as a principle of general application, and there is a catena of cases of this court which affirms that principle. Reference may be made to Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC), CIT v. Bai Shirinbai K. Kooka [1962] 46 ITR 86 (SC), Poona Electric Supply Co. Ltd. v. CIT [1965] 57 ITR 521 (SC), CIT v. Birla Gwalior (P.) Ltd. [1973] 89 ITR 266 (SC) and Bafna Textiles v. ITO [1975] 98 ITR 1 (Kar). What is the profit or gains which can be said to accrue or arise to the assessee when lie makes over his personal asset to the…

DCIT Cen Cir 4(2), Mumbai vs. Sudhakar M. Shetty, Mumbai

ITA 2906/MUM/2015[2011-12]Status: DisposedITAT Mumbai29 Aug 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…are computed, a sense in which no commercial man would misunderstand, had been regarded as a principle of general application, and there is a catena of cases of this court which affirms that principle. Reference may be made to Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC), CIT v. Bai Shirinbai K. Kooka [1962] 46 ITR 86 (SC), Poona Electric Supply Co. Ltd. v. CIT [1965] 57 ITR 521 (SC), CIT v. Birla Gwalior (P.) Ltd. [1973] 89 ITR 266 (SC) and Bafna Textiles v. ITO [1975] 98 ITR 1 (Kar). What is the profit or gains which can be said to accrue or arise to the assessee when lie makes over his personal asset to the…

ACIT 3(1)(1), Mumbai vs. Ald Automoative P.Ltd, Mumbai

In the result, the assessee’s appeals are allowed for statistical purposes, while the Revenue’s appeals are dismissed

ITA 802/MUM/2017[2011-12]Status: DisposedITAT Mumbai09 Aug 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Year: 2011-12 Acit-3(1)(1), Vs M/S Ald Automotive Private Room No.607, 6Th Floor, Limited, Aayakar Bhavan, 13, Floor, Maker Chamber-Iv, M. K. Road, Nariman Point. Mumbai-400020 Mumbai-400021 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No.Aafca0924K

…therefore, corresponding services, are liable to be rendered over the lease term – as indicated by the corresponding expenditure, the accounting treatment is in consonance with AS-9. The assessee’s reliance on the decisions in Calcutta Co. Ltd. vs. CIT [1959] 37 ITR 1 (SC) and Madras Industrial Investment Corporation Ltd. vs. CIT [1997] 225 ITR 802 (SC), both advocating the matching principle, is apposite. The AO shall cause necessary verification as indicated above, subject to whose findings of fact we allow the assessee’s claim. We may further add that the assessee’s plea is acceptable only qua such expenditure…

ACIT - 17(2), Mumbai vs. Narendra Nandlal Chauhan, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 5270/MUM/2016[2012-13]Status: DisposedITAT Mumbai08 Aug 2018AY 2012-13

Bench: Shri Joginder Singh() & Shri G Manjunatha ()

Section 143(2)Section 37

…ns to AY 2012-13. The revenue has raised the following grounds of appeal:- "1) On the facts & in the circumstances of the case, and in law, the Ld.CIT(A) has erred in relying upon the decision OF THE Hon'ble Apex Court in the case of Calcutta Co Ltd Vs. CIT, 37 ITR 1, and directing to delete the disallowance of Rs.39,46,705/- on account of provision for development expenses, without appreciating the fact that the said decision is not applicable to the matrix of the facts and circumstances of the instant case of the assessee." 2) "On the facts & in the circumstances of the case, and in law, the Ld.CIT(A) has erre…

M/S Enexio Power Cooling Solutions India Pvt Ltd (Formerly Known As M/S Gea Cooling Tower Technologies (India) P Ltd, Chennai vs. ACIT (OSD) Corp Range 2, Chennai

In the result, the assessee’s appeal is partly allowed

ITA 509/CHNY/2018[2014-15]Status: DisposedITAT Chennai06 Aug 2018AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. No. 509/Chny/2018 "नधा"रणवष"/Assessment Year : 2014-15

For Appellant: Shri Saroj Kumar Parida, AdvocateFor Respondent: Mrs. Ruby George, CIT

…ious year’s warranty settlement is allowable expenditure. Same view was taken by the Hon’ble Jurisdictional High Court in the case of Kone Elevator India Pvt. Ltd. v. ACIT, 340 ITR 46. Further, the Hon’ble Supreme Court in the case of Calcutta Co. Ltd v. CIT, 37 ITR 1, held that where the assessee was following the mercantile system of accounting is entitled for deduction of the expenditure which is incidental to the business on accrual basis though it was not actually incurred during the relevant accounting year. The Hon’ble Kerala High Court in the case of CIT v. Indian Transformers Ltd, 270 ITR 259, held that…

Franklin Templeton International Services (India) P.Ltd, Mumbai vs. Asst CIT Cir 6(3)(1), Mumbai

In the result, appeal of the assessee is allowed in part in terms indicated hereinabove

ITA 1778/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Jun 2018AY 2011-12

Bench: Shri R.C.Sharma, Am & Shri Ram Lal Negi, Jm M/S. Franklin Templeton Vs. Assistant Commissioner Of International Services (India) Pvt. Income Tax, Ltd., Circle 6(3)(1), Room Tower 2, 13Th Floor No.506, Aayakar Bhavan, Indiabulls Finance Centre M.K. Road, Senapati Bapat Marg Mumbai – 400 020 Elphinstone (W) Mumbai – 400 013 Pan/Gir No.Aaacf6496L (Appellant) .. (Respondent)

Section 143(3)Section 144C

…deduction during the year only. In this connection, reliance is placed on the following judicial precedents: Bharat Earth Movers v C1T [20091 (245 ITR 42H) • Metal Box Co. of India Ltd v. their workmen [19691 (73 ITR 53) • (SC) Calcutta Co Ltd. v C1T [19591 (37 ITR 1) (SC) • 11. In view of the above discussion, we do not find any merit for disallowance of expenditure incurred under the head ‘repairs and maintenance’ amounting to Rs.36,33,865/-. We direct accordingly. 12. Learned AR has also raised an additional ground to the effect that incase of disallowance of repairs and maintenances expenditure, the deductio…

DCIT Circle 1, Tirunelveli vs. Rm Kv Fashion Garments Pvt Ltd, Tirunelveli

In the result, appeal filed by the Revenue in ITA No

ITA 761/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

ITA 760/CHNY/2018[2014--15]Status: DisposedITAT Chennai30 Apr 2018

…e the corresponding revenue receipt is recognized. In the present case, there is no corresponding revenue to the expenditure on unredeemed bonus points. These principles were enunciated by Hon’ble Supreme Court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 and in the case of CIT v. Bilahari Investment Ltd. 299 ITR 1 (SC), which are extracted below vide para 12 & 13: “12. The argument of the Revenue that as per the agreements signed by the students, they were called upon and were required to pay the entire fee upfront for the entire course at the time of admission and, therefore, the assessee had ear…

ACIT Circle 1, Tirunelveli vs. M/S Rm Kv Fbrics Private Limited, Tirunelveli

In the result, appeal filed by the Revenue in ITA No

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

ITA 759/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

…e the corresponding revenue receipt is recognized. In the present case, there is no corresponding revenue to the expenditure on unredeemed bonus points. These principles were enunciated by Hon’ble Supreme Court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 and in the case of CIT v. Bilahari Investment Ltd. 299 ITR 1 (SC), which are extracted below vide para 12 & 13: “12. The argument of the Revenue that as per the agreements signed by the students, they were called upon and were required to pay the entire fee upfront for the entire course at the time of admission and, therefore, the assessee had ear…

ACIT Circle 1, Tirunelveli vs. M/S Rm K V Silks Private Limited, Tirunelveli

In the result, appeal filed by the Revenue in ITA No

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

ITA 614/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

…e the corresponding revenue receipt is recognized. In the present case, there is no corresponding revenue to the expenditure on unredeemed bonus points. These principles were enunciated by Hon’ble Supreme Court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 and in the case of CIT v. Bilahari Investment Ltd. 299 ITR 1 (SC), which are extracted below vide para 12 & 13: “12. The argument of the Revenue that as per the agreements signed by the students, they were called upon and were required to pay the entire fee upfront for the entire course at the time of admission and, therefore, the assessee had ear…

M/S Rm Kv Fbrics Private Limited, Tirunelveli vs. ACIT Circle 1, Tirunelveli

In the result, appeal filed by the Revenue in ITA No

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.