Calcutta Co. Ltd. v. CIT

37 ITR 1Supreme Court of India1959#224 most cited

What is Calcutta Co. Ltd. v. CIT authority for?

When following the mercantile system of accounting, provisions for liabilities made on a scientific and rational basis are allowable as deductions, even if their actual quantification and discharge are deferred to a future date.

341

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2000 to 2026.

Also referred to as

Calcutta Co. Ltd. v. CIT · mercantile system of accounting · Section 37 · allowable deductions · provision for liabilities · unascertained liabilities · deferred payment

Sections most often in play

Section 37(1)Section 143(3)Section 14ASection 115JBSection 147Section 148Section 36(1)(vii)Section 36(1)(viia)
Read the full judgment

Issues it is cited on

mercantile system of accountingsection 37section 37(1)section 36(1)section 36section 40salaryprevious yearindiacompanytransferbusiness

Judgments citing Calcutta Co. Ltd. v. CIT

Sh. Vijay Kumar Aggarwal, Prop., Jalandhar vs. Income Tax Officer, Jalandhar

In the result, the appeals of the assessee are dismissed

ITA 38/ASR/2017[2013-14]Status: DisposedITAT Amritsar18 Mar 2019AY 2013-14

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 38/Asr./2017 : Asstt. Year : 2013-14 Ita No. 77/Asr./2017 : Asstt. Year : 2012-13

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Ms. Shivani Bansal, DR
Section 43B

…/2018 Vijay Kumar Aggarwal maintained on mercantile basis, is not consistent with the law laid down bv Hon'bie Supreme Court in series of cases cited above i.e. Bharat Earth Movers vs CIT, Metail Box Co of India Ltd vs Workmen, Calcutta Co Ltd vs. CIT (1959) 37 ITR 1 and Taparia Tools Ltd. Vs Joint CIT. Therefore, this decision of Hon'ble Delhi High Court, even while holding that the deduction was not allowable u/s.43B(d), being per incuriam, when it did not consider the law laid down by Hon'ble Apex Court supra, cannot be relied upon, for its initial view that the interest had not accrued in this year even unde…

Sri V.N.K.Memon, Bellary District vs. Principal Commissioner of Income Tax, Gulbarga

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

ITA 157/BANG/2017[2012-13]Status: DisposedITAT Bangalore15 Mar 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumarassessment Year : 2012-13 Shri V.N.K. Memon, The Assistant Khb Colony, Commissioner Of Sandur, Vs. Income Tax, Bellary District. Circle – 1, Pan: Agxpm5124G Bellary. Appellant Respondent

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 263

…enditure corresponding to the amount of sales proceeds which was retained by the CEC, the entire sales including retained amount of 20% has to be credited to the P&L account. Keshav Mills Ltd. Vs CIT (1953) 23 ITR 230,239 (SC) Calcutta Co Ltd. Vs CIT (1959) 37 ITR 1,3 (SC) CIT Vs Swadeshi Cotton & Flour Mills Pvt. Ltd. (1964) ITR 134,137 (SC) In view of the above discussion, the objection filed by the assessee on this account, is not acceptable.” 4. Thereafter, he submitted that this is the case of the assessee that as per the directions of Hon’ble Supreme Court, a monitoring committee called Central Empowere…

ITO, New Delhi vs. M/S. Paragon Xt, New Delhi

In the result appeal of the revenue is dismissed

ITA 363/DEL/2015[2010-11]Status: DisposedITAT Delhi14 Mar 2019AY 2010-11

Bench: Shri Amit Shukla & Shri L.P. Sahuasstt. Year: 2010-11

For Appellant: NoneFor Respondent: Shri Surender Pal, Sr. DR
Section 194C

…in a sense which no commercial man would misunderstand". This principle has been approved by the Privy Council in Pondicherry Railway Co. Ltd. v. CIT 5 ITC 363, and by the Supreme Court in Badridas Daga v. CIT (1958) 34 ITR 10, Calcutta Co. Ltd. v. CIT (1959) 37 ITR 1 (SC) and CIT v. BaiShirinbai (K) Kooka (1962) 46 ITR 86. The profits mentioned herein are the real profits and they must be ascertained on ordinary principles of commercial practice and commercial accounting. Therefore, the assessee's method of accounting becomes relevant for determining the income from the conduct of any business or exercise of any…

Rasna Pvt. Ltd., Ahmedabad vs. The Dy. CIT., Circle-3(1)(2), Ahmedabad

In the result, appeal ITA 2334/Ahd/2015 filed by assessee is partly allowed

ITA 2334/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad30 Jan 2019AY 2010-11
For Appellant: Shri P.F. Jain, A.RFor Respondent: Shri Lalit P. Jain, Sr. D.R
Section 143(3)Section 36Section 41(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “C” BENCH Before: Shri Rajpal Yadav, Judicial Member And Shri Amarjit Singh, Accountant Member Sl. ITA/CO A.Y. Appellant Respondent No. 1 2334/Ahd/2015 2010-11 Rasna Pvt. Ltd. DCIT, Ahmedabad Circle-3(1)(2), Ahmedabad 2 2397/Ahd/2015 2010-11 ACIT, Circle-5, Rasna Pvt. Ltd. Ahmedabad Ahmedabad 3 3666/Ahd/2015 2011-12 DCIT, Rasna Pvt. Ltd. Circle-3(1)(2), Ahmedabad Ahmedabad 4 CO No. 2011-12 Rasna Pvt. Ltd. DCIT, 04/Ahd/2016 Ahmedabad Circle-3(1)(2), (In ITA No. Ahmedabad 3666/Ahd/2015) 5 3667/Ahd/2015 2012-13 DCIT, Rasna Pvt. Ltd. Circle-3(1)(2), Ahmedabad Ahmedabad…

The ITO, Ward-1(3), Ahmedabad vs. M/S. Chamunda Pharma Machinery Pvt. Ltd., Ahmedabad

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

ITA 2169/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad30 Jan 2019AY 2011-12

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.1945/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2011-2012

…provisions created are allowable expenses and only payment is to be made on the future date does not disentitle the assessee from the deduction. The relevant extract of the case (supra) is as under: “6. So is the view taken in Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1, wherein this Court has held that the liability on the assessee having been imported, the liability would be an accrued liability and would not convert into a conditional one merely because the liability was to be discharged at a future date. There may be some difficulty in the estimation thereof but that would not convert the accrued liability into…

Chamunda Pharma Machinery Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(3), Ahmedabad

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

ITA 1945/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad30 Jan 2019AY 2011-12

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.1945/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2011-2012

…provisions created are allowable expenses and only payment is to be made on the future date does not disentitle the assessee from the deduction. The relevant extract of the case (supra) is as under: “6. So is the view taken in Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1, wherein this Court has held that the liability on the assessee having been imported, the liability would be an accrued liability and would not convert into a conditional one merely because the liability was to be discharged at a future date. There may be some difficulty in the estimation thereof but that would not convert the accrued liability into…

DCIT, New Delhi vs. M/S. Sistema Shyam Teleservices Ltd., New Delhi

In the result Appeal of the ld AO is dismissed

ITA 732/DEL/2016[2010-11]Status: DisposedITAT Delhi25 Jan 2019AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishidcit, Vs. Sistema Shyam Circle-23(2), Teleservices Ltd, New Delhi A-60, Naraina Industrial Area-I, New Delhi Pan: Aaccs1709H (Appellant) (Respondent)

For Appellant: Shri Alok Vasant, CAFor Respondent: Shri Surender Pal, Sr. DR
Section 143(3)Section 144C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER DCIT, Vs. Sistema Shyam Circle-23(2), Teleservices ltd, New Delhi A-60, Naraina Industrial Area-I, New Delhi PAN: AACCS1709H (Appellant) (Respondent) Revenue by : Shri Surender Pal, Sr. DR Assessee by: Shri Alok Vasant, CA Date of Hearing 11/12/2018 Date of pronouncement 25/01/2019 O R D E R PER PRASHANT MAHARISHI, A. M. 1. This appeal is filed by The Deputy Commissioner of Income tax [ The ld AO ] Circle 23(2), New Delhi against order of the ld Commissioner of Income…

ACIT, New Delhi vs. M/S. Housing & Urban Development Corporation Ltd., New Delhi

In the result, Assessee’s appeal vide ITA No

ITA 6151/DEL/2014[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Gagan Kumar, Adv. &For Respondent: Sh. K.J. Singh, CIT (DR)
Section 143(3)Section 14ASection 263

…ad, it goes against the assessee. Now, we come to the case of Bharat Earth Movers v. CIT (Supra). In this case, the Hon’ble Supreme Court, after considering Metal Box Co. of India Ltd. v. Their Workmen[1969] 73 ITR 53 (SC) and Calcutta Co. Ltd. v. CIT[1959] 37 ITR 1 (SC) stated, at Paragraph 4 of the Order, the well settled law in these words: “The law is settled: if a business liability has definitely arisen in the accounting year, the deduction should be allowed although the liability may have to be quantified and discharged at a future date. What should be certain is the incurring of the liability. It shoul…

M/S. Housing & Urban Development Corporation Ltd. (Hudco), New Delhi vs. DCIT, New Delhi

In the result, Assessee’s appeal vide ITA No

ITA 5705/DEL/2014[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Sh. Gagan Kumar, Adv. &For Respondent: Sh. K.J. Singh, CIT (DR)
Section 143(3)Section 14ASection 263

…ad, it goes against the assessee. Now, we come to the case of Bharat Earth Movers v. CIT (Supra). In this case, the Hon’ble Supreme Court, after considering Metal Box Co. of India Ltd. v. Their Workmen[1969] 73 ITR 53 (SC) and Calcutta Co. Ltd. v. CIT[1959] 37 ITR 1 (SC) stated, at Paragraph 4 of the Order, the well settled law in these words: “The law is settled: if a business liability has definitely arisen in the accounting year, the deduction should be allowed although the liability may have to be quantified and discharged at a future date. What should be certain is the incurring of the liability. It shoul…

Telenor (India) Communications Pvt. Ltd., New Delhi vs. ACIT, Circle- 25(1), New Delhi

In the result appeal of assessee is partly allowed for statistical purposes

ITA 7541/DEL/2017[2014-15]Status: DisposedITAT Delhi04 Dec 2018AY 2014-15

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri G.S. Agarwal, Sr. Adv. &nFor Respondent: Shri S.S. Rans, CIT(DR)

…set off, all corresponding liabilities of UW due to DoT were automatically vested with appellant due to the provisions of section 132 of the TP Act. The appellant placed reliance on the decision of Supreme Court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC) wherein it has been held that the expression to compute gain or 36 37 loss 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 receipts is deducted therefrom irrespective of whether the expenditure is actually incurred or…

Deputy Commissioner of Income Tax, Circle-1, Kakinada vs. Sar Chandra Environ Solutions Private Limited, Kakinada

In the result, appeals filed by the Revenue and the cross objections filed by the assessee are dismissed

ITA 149/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam28 Nov 2018AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Mrs. Suman Malik – Sr.DR
Section 143(1)Section 148

…n the following judicial pronouncements in support of its claim relating to non- disallowance of the provision made in respect of Drill cutting disposal expenses which are produced as under: Hon'ble Supreme court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC) has held that the liability on the assessee having been imported, the liability would be an accrued liability and would not convert into a conditional one merely because the liability was to be discharged at a future date. There may be some difficulty in the estimation thereof but that would not convert the accrued liability into a conditional…

Deputy Commissioner of Income Tax, Circle-1, Kakinada vs. Sar Chandra Environ Solutions Private Limited, Kakinada

In the result, appeals filed by the Revenue and the cross objections filed by the assessee are dismissed

ITA 148/VIZ/2018[2013-14]Status: DisposedITAT Visakhapatnam28 Nov 2018AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Mrs. Suman Malik – Sr.DR
Section 143(1)Section 148

…n the following judicial pronouncements in support of its claim relating to non- disallowance of the provision made in respect of Drill cutting disposal expenses which are produced as under: Hon'ble Supreme court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC) has held that the liability on the assessee having been imported, the liability would be an accrued liability and would not convert into a conditional one merely because the liability was to be discharged at a future date. There may be some difficulty in the estimation thereof but that would not convert the accrued liability into a conditional…

The Deputy Commissioner of Income Tax, Circle-1, Kakinada vs. Sar Chandra Environ Solutions Private Limited, Kakinada

In the result, appeals filed by the Revenue and the cross objections filed by the assessee are dismissed

ITA 147/VIZ/2018[2010-11]Status: DisposedITAT Visakhapatnam28 Nov 2018AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Mrs. Suman Malik – Sr.DR
Section 143(1)Section 148

…n the following judicial pronouncements in support of its claim relating to non- disallowance of the provision made in respect of Drill cutting disposal expenses which are produced as under: Hon'ble Supreme court in the case of Calcutta Co. Ltd. v. CIT [1959] 37 ITR 1 (SC) has held that the liability on the assessee having been imported, the liability would be an accrued liability and would not convert into a conditional one merely because the liability was to be discharged at a future date. There may be some difficulty in the estimation thereof but that would not convert the accrued liability into a conditional…

Pr. Commissioner of Income Tax-8 vs. Sistema Shyam Teleservices Ltd

The appeals are disposed of

ITA/1069/2017HC Delhi15 Nov 2018

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

Section 260A

…iple of law laid down in E.D. Sassoon and Co. Ltd. (supra) that fee was debt due at the time of deposit. The fee was paid in advance though services were yet to be rendered. Reference was made to Calcutta Company Ltd. Vs. Commissioner of Income Tax [1959] 37 ITR 1 (SC) that when the fee was paid in advance it would be in nature of deposit or ITA Nos.70/2013, 73/2013 & 1069/2017 Page 13 of 17 an advance. Otherwise, it would lead to an anomalous situation not intended in law, as when the amount was received the expense…

Commissioner of Income Tax-III vs. Shyam Telelink Ltd

The appeals are disposed of

ITA/70/2013HC Delhi15 Nov 2018

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

Section 260A

…iple of law laid down in E.D. Sassoon and Co. Ltd. (supra) that fee was debt due at the time of deposit. The fee was paid in advance though services were yet to be rendered. Reference was made to Calcutta Company Ltd. Vs. Commissioner of Income Tax [1959] 37 ITR 1 (SC) that when the fee was paid in advance it would be in nature of deposit or ITA Nos.70/2013, 73/2013 & 1069/2017 Page 13 of 17 an advance. Otherwise, it would lead to an anomalous situation not intended in law, as when the amount was received the expense…

Commissioner of Income Tax-III vs. Shyam Telelink Ltd

The appeals are disposed of

ITA/73/2013HC Delhi15 Nov 2018

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

Section 260A

…iple of law laid down in E.D. Sassoon and Co. Ltd. (supra) that fee was debt due at the time of deposit. The fee was paid in advance though services were yet to be rendered. Reference was made to Calcutta Company Ltd. Vs. Commissioner of Income Tax [1959] 37 ITR 1 (SC) that when the fee was paid in advance it would be in nature of deposit or ITA Nos.70/2013, 73/2013 & 1069/2017 Page 13 of 17 an advance. Otherwise, it would lead to an anomalous situation not intended in law, as when the amount was received the expense…

Asst CIT 27(2), Navi Mumbai vs. Merit Magnum Construction, Mumbai

In the result, the Revenue’s appeal as well as assessee’s cross objection stands

ITA 6656/MUM/2016[2008-09]Status: DisposedITAT Mumbai25 Oct 2018AY 2008-09

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm Acit-27(2), M/S. Merit Magnum Construction Room No. 420, 4Th Floor, Samruddhi, Office Floor, Plot No. 157, 18Th Road, Tower No. 6, Vashi Rly. Station Vs. Complex, Vashi, Navi Mumbai-400 703 Nr. Ambedkar Garden, Chembur (East), Mumbai-400 703 Pan/Gir No. Aacfv 9391 F (Revenue) (Assessee) :

For Appellant: Shri Paresh Shaparia
Section 133ASection 143(3)Section 147Section 148

…ssessee firm after the assessment year under consideration can be allowed against the income that arose and accrued during A Y 2008-09. In this regard, reference may be made to the decision of the Hon'ble Supreme Court in the case of Calcutta Co. Ltd. vs. CIT 37 ITR 1. In this case the Hon'ble Supreme Court held that the accrued liability to be discharged at future date be allowed in cases where the assessee is following mercantile system of accounting. In this case the assessee and the JDA partner has quantified the estimated expenses at Rs. 180 to Rs. 200 crores. However, the expenditure is found to be excessiv…

DCIT Corporate Circle 1 (1), Chennai vs. M/S East Coast Constructions & Industries Limited, Chennai

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 1442/CHNY/2018[2010-11]Status: DisposedITAT Chennai24 Oct 2018AY 2010-11

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 1442/Chny/2018 िनधा"रण वष"/Assessment Year:2010-11 The Deputy Commissioner Of M/S. East Coast Constructions & Income Tax, Central Circle 1(1), Vs. Industries Ltd., No. 4, Moores Road, Chennai – 34. Chennai 600 006. [Pan:Aaace1662P] (Appellant) (Respondent) अपीलाथ" की ओर से / Appellant By : Ms. Tripurasundari, Cit ""थ" की ओर से/Respondent By : Shri G. Baskar, Advocate सुनवाई की तारीख/ Date Of Hearing : 11.09.2018 घोषणा की तारीख /Date Of Pronouncement : 24.10.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) 6, Chennai Dated 30.01.2018 Relevant To The Assessment Year 2010-11. The Only Effective Ground Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Has Erred In Deleting The Disallowance Of ₹.25,24,97,133/- Towards Expenses Relatable To The Retention Money Withheld By The Contractees.

For Appellant: Ms. Tripurasundari, CITFor Respondent: Shri G. Baskar, Advocate
Section 143(3)Section 263

…e average of previous year’s warranty settlement is allowable expenditure. Same view was taken by the jurisdictional High Court in the case of Kone Elevator India Pvt. Ltd vs ACIT, 340 ITR 46. Further, the Supreme Court in the case of Calcutta Co. Ltd vs 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 Kerala High Court in the case of CIT vs Indian Transformers Ltd, 270 ITR 259, held that provisio…

M/S Shantipushpa Associates, Bilaspur(Cg) vs. I.T.O. Ward 1(1), Bilaspur(Cg)

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

ITA 102/BIL/2015[2010-11]Status: DisposedITAT Raipur22 Oct 2018AY 2010-11

Bench: Shri R.K. Panda & Ms. Suchitra Kambleassessment Year: 2010-11 Shantipushpa Associates, Vs. Ito, Ward 1(1), Opp. Bank Of Baroda, Ayakar Bhavan, Link Road, Vyapa Vihar, Bilaspur (Cg). Bilaspur (Cg). Pan : Aaffs5574B

For Appellant: Shri Sunil Kumar Agrawal, CA &For Respondent: Shri V.B. Sargar, DR
Section 143(3)Section 145(3)

…fore making ‘provision of exp’ of Rs1,14,05,462 in the books): Net Profit would be Rs.1,18,23,282 x 11.40% 13,47,854 12. Relying on various decisions including the decision of the Hon'ble Supreme Court in the case of Calcutta Company Ltd. vs. CIT reported in 37 ITR 1 and various other decisions as filed in the paper book and written synopsis he submitted that the expenditure which is incidental to the business on accrual basis, though it was not incurred during the relevant accounting year, should be allowed as a deduction. 13. The ld. DR, on the other hand, heavily relied on the order of the CIT(A). 10 14. W…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 467/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Oct 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…d upon the following decisions wherein it has been held that liability which has arisen in the relevant accounting year is an allowable deduction even though its actual quantification and discharge is deferred to a future date: a) Calcutta Discount Co. Ltd.: 37 ITR 1 (SC) b) Metal Box (P) Limited (1969): 73 ITR 53 (SC) c) United Commercial Bank v. CIT 240 ITR 355 (SC) d) Bharat Earth Movers: 245 ITR 428 (SC) e) Kelvinator of India Ltd. reported in 256 ITR 1 confirmed by SC in 320 ITR 561 f) CIT v Vinitec Corpn. (P) Ltd.: 278 ITR 337 (Delhi) g) National Mineral Development Corporation Ltd. v. JCIT : 98 ITD 278 (…