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

The expression "attributable to" is wider in scope and import than the expression "derived from" when interpreting provisions related to profits and gains from a business or industrial undertaking. The legislature's deliberate use of these distinct phrases indicates a nuanced intent regarding the directness of the nexus between income and the source.

How many judgments cite Cambay Electric Supply Industrial Co. Ltd. v. CIT?

245 judgments on BharatTax cite Cambay Electric Supply Industrial Co. Ltd. v. CIT (113 ITR 84), spanning 1999 to 2026.

Which sections of the Income Tax Act does Cambay Electric Supply Industrial Co. Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 80P(2)(a)(i), Section 143(3), Section 80P(2)(d), Section 80P, Section 250, Section 263.

Cambay Electric Supply Industrial Co. Ltd. v. CIT (113 ITR 84)

M/S. Repco Home Finance Ltd., Chennai vs. ACIT, Chennai

In the result, the appeal of assessee in ITA No

ITA 2732/CHNY/2016[2009-10]Status: DisposedITAT Chennai20 Sept 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari]

For Appellant: Mr.M.Viswanathan, C.A ""For Respondent: Dr.S.Sundaresan

Section 143(3)Section 147Section 148Section 36

…sidered as profit out of eligible business of the assessee and not eligible for deduction u/s.36(i)(viii) of the Act. For this purpose, he placed reliance in the judgement of Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd Vs. CIT in 113 ITR 84(SC) and in the case of CIT Vs. Sterling foods in 237 ITR 579(SC) and judgement of jurisdictional High Court in the case of CIT Vs. Menon Impex P Ltd., in 259 ITR 403 (Mad.). Further, ld. Assessing Officer was of the opinion that there was no direct nexus between the interest income and interest paid by the assessee for which the assessee also n…

Shri. Channabasappa, Ceo, Bellary vs. Commissioner of Income Tax, Kalaburagi

In the result, the appeal of the assessee is allowed

ITA 869/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 May 2017AY 2012-13

Bench: Shri Vijay Pal Rao

For Appellant: Shri S.N. Arvinda, AdvoacateFor Respondent: Shri M.K. Biju, JCIT (DR) (ITAT)-3, Bengaluru

Section 80PSection 80P(2)(a)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:— 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…

Shri. B Madhvesh Rao, Ceo, Bellary vs. Commissioner of Income Tax, Kalaburagi

In the result, the appeal of the assessee is allowed

ITA 868/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 May 2017AY 2012-13

Bench: Shri Vijay Pal Rao

For Appellant: Shri S.N. Arvinda, AdvoacateFor Respondent: Shri M.K. Biju, JCIT (DR) (ITAT)-3, Bengaluru

Section 80PSection 80P(2)(a)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:— 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…

Shri. Basavaraj, Ceo, Bellary vs. Commissioner of Income Tax, Kalaburagi

In the result, the appeal of the assessee is allowed

ITA 867/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 May 2017AY 2012-13

Bench: Shri Vijay Pal Rao

For Appellant: Shri S.N. Arvinda, AdvoacateFor Respondent: Shri M.K. Biju, JCIT (DR) (ITAT)-3, Bengaluru

Section 80PSection 80P(2)(a)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:— 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…

Shri. S. M Revana Siddaiah, Ceo, Bellary vs. Commissioner of Income Tax, Kalaburagi

In the result, the appeal of the assessee is allowed

ITA 866/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 May 2017AY 2012-13

Bench: Shri Vijay Pal Rao

For Appellant: Shri S.N. Arvinda, AdvoacateFor Respondent: Shri M.K. Biju, JCIT (DR) (ITAT)-3, Bengaluru

Section 80PSection 80P(2)(a)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:— 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…