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 84Supreme Court of India1978#355 most cited

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.

245

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 1999 to 2026.

Also referred to as

Cambay Electric Supply Industrial Co. Ltd. v. CIT · 113 ITR 84 · Section 80P · derived from · attributable to · scope of expressions · profits and gains · business income attribution · industrial undertaking income · income interpretation · direct nexus

Sections most often in play

Section 80P(2)(a)(i)Section 143(3)Section 80P(2)(d)Section 80P Section 250 Section 263 Section 56 Section 2(19)

Read the full judgment

Issues it is cited on

section 57(i)section 80(2)(d)section 80(p)(2)(a)section 286 section 161 section 80p(2)(a)(iii)section 80p(2)(c)section 60 section 80j interest on securities section 80p(1)section 2(19)

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

Commissioner of Income Tax vs. Willamson Financial Services

C.A. No.-003803-003808 - 2005Supreme Court12 Dec 2007

Bench: The 60 : 40 Apportionment Under Rule 8(1) Or From 40% Profits On Sales Taxable As Business Income. 3. Rule 8(1) Of The Said Rule Provides That 40% Of The Composite Income From Sale Of Tea, Grown & Manufactured, Arrived At On Making Of The Apportionment \023Shall Be Deemed To Be Income Liable To Tax\024. 4. Assessees Exported Tea In The Accounting Year. They Were Entitled To Deduction Under Section 80Hhc Of Income-Tax Act, 1961 (For Short, \0211961 Act\024) In Respect Of The Export. They Were In The Business Of Growing & Manufacturing Tea. Since They Earned Composite Income, Their Case Stood Covered By Rule 8(1) Of Income-Tax Rules, 1962 (\0231962 Rule\024 For Short). 5. For The Sake Of Convenience We State The Facts Occurring In Civil Appeal No.3803-3808 Of 2005- Commissioner Of Income Tax V. Willamson Financial Services & Ors. In The Returns, The Assessee Claimed Section 80Hhc Deduction Against The Entire Composite Income Before Application Of Rule 8(1).

For Respondent: Willamson Financial Services & Ors

Section 2(45)Section 295Section 5Section 80H

…r Chapter IV and not to allow deduction under Chapter VI-A. In this connection reliance was placed by the learned counsel on the judgment of this Court in the case of Cambay Electric Supply Industrial Company Ltd. v. Commissioner of Income Tax \026 (1978) 113 ITR 84 (SC) which had been approved by the Constitution Bench later on in the case of Distributors (Baroda) Pvt. Ltd. v. Union of India and Ors. \026 (1985) 155 ITR 120 (SC) in which it has been held that though a deduction does not appear in Chapter IV, it has a direct impact upon the computation of income under the head \023business profit\024 an…

Honda Siel Power Products Ltd vs. The Commissioner of Income Tax New Delhi

The appeal is dismissed with no orders as to costs

ITA - 995 / 2007HC Delhi25 Oct 2007

Section 260Section 80

…2007:DHC:1329-DB gains derived from an industrial undertaking”. The Supreme Court has drawn a distinction between the expressions “derived from” and “attributable to” in Cambay Electric Supply Industrial Co. Limited v. Commissioner of Income Tax [1978] 113 ITR 84 in the following manner [page 93] : “In our view, since the expression of wider import, namely 'attributable to', has been used, the Legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.” 9. In the context of Section 80-I, the Supreme Court under…

Honda Siel Power Products Ltd vs. Commissioner of Income Tax

The appeal is dismissed with no orders as to costs

ITA/995/2007HC Delhi25 Oct 2007

Section 260Section 80

Commissioner of Income Tax-V N vs. Damanjit Singh

ITA/166/2000HC Delhi12 Jan 2007

…the export business of the assessee. 9. On the distinction between the words ‘attributable to’ and ‘derived from’, the judgment of the Hon’ble Supreme Court in Cambay Electrical Supply Industrial Co. Ltd. v. CIT (1978) 113 ITR 84 is illustrative. It was held (ITR Page 93): “In our view, since the expression of wider import, namely ‘attributable to’, has been used, the Legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.” It was explained that the expression ‘derived from’ is a…

Commissioner of Income Tax vs. Sterling Foods

In the result, the appeals are allowed

C.A. No.-002390-002391 - 1996Supreme Court15 Apr 1999

For Respondent: STERLING FOODS, MANGALORE

Section 28Section 80H

…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. vs. CIT (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 Division Bench of the High Court obse…