Cambay Electric Supply Industrial Co. Ltd. v. CIT

2 SCC 644Reported decision1978#4150 most cited

What is Cambay Electric Supply Industrial Co. Ltd. v. CIT authority for?

The computation of deduction under Section 80-IA is determined by treating the eligible business as the sole source of income, but the allowance of such deduction can consider income from other sources, provided the aggregate deductions do not exceed gross total income.

29

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2025.

Also referred to as

Cambay Electric Supply Industrial Co. Ltd. v. CIT · Section 80-IA · eligible business income · gross total income · Chapter VI-A deductions · quantum of deduction · business income restriction

Also reported as

224 ITR 122

Sections most often in play

Section 1961Section 143(3)Section 148Section 143(2)Section 10(34)Section 139(5)Section 14ASection 194Q

Issues it is cited on

section 80abretention moneysection 32aminimum alternate taxsection 10(33)eligible businesssection 80ia(4)csr expendituresection 80csection 253(3)section 80iadeduction u/s 80ia

Judgments citing Cambay Electric Supply Industrial Co. Ltd. v. CIT

NATIONAL COOPERATIVE DEVELOPMENT CORPORATION vs. ASSISTANT COMMISSIONER OF INCOME TAX

C.A. No.-004612-004612 - 2014Supreme Court10 Dec 2025

Bench: HON'BLE MR. JUSTICE PAMIDIGHANTAM SRI NARASIMHA

Section 36(1)(viii)

…quirement for a direct link. Any interpretation suggesting otherwise would upset settled law. 16. The appellant’s reliance on the decision in Meghalaya Steels (supra) is misplaced because the facts in that case were fundamentally different. In 5 (1978) 2 SCC 644. 12 Meghalaya Steels (supra), this Court interpreted Section 80-IB, which allowed deductions for profits derived from "any business" of an industrial undertaking. The income in dispute there consisted of specific government subsidies given to reimburse the company for actual operational costs like transport, power, and insurance. The Cour…

BIHAR STATE ROAD DEVELOPMENT CORPN.LTD.,PATNA vs. CIT (APPEAL), DELHI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 335/PAT/2024[2018-19]Status: DisposedITAT Patna24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 334/PAT/2024[2017-18]Status: DisposedITAT Patna24 Jul 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 333/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 332/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 331/PAT/2024[2013-14]Status: DisposedITAT Patna24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 330/PAT/2024[2012-13]Status: DisposedITAT Patna24 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

…so claimed and which was bifurcated into Own Fund and RCD Fund, was disallowed by the Ld. AO relying upon the decisions of Hon'ble Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. Vs. CIT [1978] 113 ITR 84, Ashoka Leyland Vs. CIT [1997] 224 ITR 122 and M/s Pandian Chemicals Ltd. Vs. CIT [2003] 129 Taxman 539/262 ITR 278 (SC). A sum of ₹66,47,34,169/- was disallowed which was claimed as a deduction u/s 80-IA of the Act as against the total interest earned at ₹ 71,91,44,620/- and the total income was assessed at ₹74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance…

ASSTT. COMMISSIONER OF INCOME TAX, CC-1, LUCKNOW, AAYAKAR BHAWAN, ASHOK MARG, LUCKNOW vs. APCO INFRATECH PVT. LTD., VIBHUTI KHAND GOMTI NAGAR LKO

In the result, appeals vide

ITA 623/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

M/S APCO INFRATECH PVT. LTD.,LUCKNOW vs. D/ACIT-1,CENTRAL-1, LUCKNOW

In the result, appeals vide

ITA 17/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD., LUCKNOW

ITA 454/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to 'business income' only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

M/S. APCO INFRATECH PVT. LTD.,,LUCKNOW vs. ACIT-I, LUCKNOW

In the result, appeals vide I

ITA 357/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18
Section 143(1)Section 143(2)Section 143(3)Section 80I

…tricted to\n'business income' only. On the other hand, according to him,\nsubsection (5) deals with determination of the quantum of deduction\nby treating eligible business as the only source of income of the\nAssessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008)\n4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the\ndeduction, which is at a stage prior to allowing the deduction so\ncomputed. He submitted that there is no dispute that the computation\nof deduction is only from the eligible business. The claim of the\nAssessee, as accepted by the Appellate Authority, is that there is no\nre…

M/S. APCO INFRATECH PVT. LTD.,LUCKNOW vs. ACIT-1, LUCKNOW

In the result, appeals vide

ITA 356/LKW/2020[2016-17]Status: DisposedITAT Lucknow02 Apr 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1152/BANG/2023[2018-19]Status: DisposedITAT Bangalore28 Feb 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Subramanian .S, JCIT DR
Section 10ASection 10A(9)Section 250

…annot possibly refer to gross total income but referred only to "net income". Further, Distributors (Baroda) case followed the judgment of this Court in Cambay Electric Supply Industrial Co. Ltd. v. The Commissioner of Income Tax, Gujarat-II, Ahmedabad [1978] 2 SCC 644 which decision concerned itself with Section 80-E of the Income Tax Act. Section 80 E reads as follows:— "80E – Deduction in respect of profits and gains from specified industries in the case of certain companies-(1) In the case of a company to which this section applies, where the total income (as computed in accordance with the other provisions o…

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 927/BANG/2023[2016-17]Status: DisposedITAT Bangalore08 Jan 2024AY 2016-17

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri Padam Chand Kincha, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 10ASection 30Section 80ASection 80H

…annot possibly refer to gross total income but referred only to "net income". Further, Distributors (Baroda) case followed the judgment of this Court in Cambay Electric Supply Industrial Co. Ltd. v. The Commissioner of Income Tax, Gujarat-II, Ahmedabad [1978] 2 SCC 644 which decision concerned itself with Section 80-E of the Income Tax Act. Section 80 E reads as follows:— "80E – Deduction in respect of profits and gains from specified industries in the case of certain companies-(1) In the case of a company to which this section applies, where the total income (as computed in accordance with the other provisions o…

NHDC LIMITED,BHOPAL vs. DCIT - 3(1), BHOPAL, BHOPAL

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

ITA 40/IND/2021[2015-16]Status: DisposedITAT Indore11 Dec 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

Section 143(3)Section 80I

…ost of manufacture of the Respondent's products. 14. Interpreting the similar expression contained in Section 80 IB, the Supreme Court in CIT v. Meghalaya Steel Ltd. (supra) referred to the decisions in Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 2 SCC 644; CIT v. Sterling Foods (1999) 4 SCC 98 and Pandian Chemicals Ltd. (supra) and observed as under: "18......What is to be seen for the applicability of Sections 80-IB and 80- IC is whether the profits and gains are derived from the business. So long as profits and gains emanate directly from the business itself, the fact that the immediate source of…

DCIT 3 (1) , BHOPAL vs. M/S NHDC LTD, BHOPAL

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

ITA 316/IND/2020[2015-16]Status: DisposedITAT Indore11 Dec 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

Section 143(3)Section 80I

…ost of manufacture of the Respondent's products. 14. Interpreting the similar expression contained in Section 80 IB, the Supreme Court in CIT v. Meghalaya Steel Ltd. (supra) referred to the decisions in Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 2 SCC 644; CIT v. Sterling Foods (1999) 4 SCC 98 and Pandian Chemicals Ltd. (supra) and observed as under: "18......What is to be seen for the applicability of Sections 80-IB and 80- IC is whether the profits and gains are derived from the business. So long as profits and gains emanate directly from the business itself, the fact that the immediate source of…

M/S. SARAF EXPORTS vs. COMMISSIONER OF INCOME TAX, JAIPUR - III

C.A. No.-004822-004822 - 2022Supreme Court10 Apr 2023

Bench: HON'BLE MR. JUSTICE M.R. SHAH

Section 143(2)Section 75Section 80

…had made by selling the import entitlements was not a profit and gain which it had derived from its industrial undertaking. For that purpose, it relied upon the decision of this Court in Cambay Electric Supply Industrial Co. Ltd. v. CIT [(1978) 2 SCC 644 : 1978 SCC (Tax) 119 : (1978) 113 ITR 84]. It was there held that the expression “attributable to” was wider in import than the expression “derived from”. The expression of wider import, namely, “attributable to”, was used when the legislature intended to cover receipts from sources other than the actual conduct of the business. The Divis…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE vs. M/S. BANGALORE INTERNATIONAL AIRPORT LIMITED, BANGALORE

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

ITA 374/BANG/2020[2013-14]Status: DisposedITAT Bangalore14 Jun 2022AY 2013-14

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 250Section 271(1)(c)Section 80Section 80I

…ost of manufacture of the Respondent’s products. 14. Interpreting the similar expression contained in Section 80 IB, the Supreme Court in CIT v. Meghalaya Steel Ltd. (supra) referred to the decisions in Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 2 SCC 644; CIT v. Sterling Foods (1999) 4 SCC 98 and Pandian Chemicals Ltd. (supra) and observed as under: “18. …..What is to be seen for the applicability of Sections 80-IB and 80- IC is whether the profits and gains are derived from the business. So long as profits and gains emanate directly from the business itself, the fact that the immediate source of t…

M/S. BANGALORE INTERNATIONAL AIRPORT LIMITED,BANGALORE vs. COMMISSIONER OF INCOME TAX (APPEALS)- 1, BANGALORE

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

ITA 191/BANG/2020[2013-14]Status: DisposedITAT Bangalore14 Jun 2022AY 2013-14

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 250Section 271(1)(c)Section 80Section 80I

…ost of manufacture of the Respondent’s products. 14. Interpreting the similar expression contained in Section 80 IB, the Supreme Court in CIT v. Meghalaya Steel Ltd. (supra) referred to the decisions in Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 2 SCC 644; CIT v. Sterling Foods (1999) 4 SCC 98 and Pandian Chemicals Ltd. (supra) and observed as under: “18. …..What is to be seen for the applicability of Sections 80-IB and 80- IC is whether the profits and gains are derived from the business. So long as profits and gains emanate directly from the business itself, the fact that the immediate source of t…

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. NSL RENEWABLE POWER PRIVATE LIMITED, HYDERABAD

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

ITA 166/HYD/2020[2016-17]Status: DisposedITAT Hyderabad03 Sept 2021AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Aliasgar RampurwalaFor Respondent: Shri P. Chandra Sekhar
Section 115JSection 143(3)Section 14ASection 80I

…estricted to ‘business income’ only. On the other hand, according to him, sub- section (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

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