What is Chainrup Sampatram v. CIT authority for?

Income accrues and becomes taxable only when there is a reasonable certainty of its realization. A mere possibility or expectation of income, particularly when subject to ongoing disputes, is not enough for it to be considered accrued.

How many judgments cite Chainrup Sampatram v. CIT?

196 judgments on BharatTax cite Chainrup Sampatram v. CIT (24 ITR 481), spanning 2005 to 2026.

Which sections of the Income Tax Act does Chainrup Sampatram v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 271(1)(c), Section 154, Section 69, Section 143(1).

Chainrup Sampatram v. CIT (24 ITR 481)

ITO, Ward-9(1), Kolkata vs. M/S Acytelene Trexim (P) Ltd., Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 1429/KOL/2012[2009-10]Status: DisposedITAT Kolkata03 Aug 2016AY 2009-10

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2009-10

Section 143(1)Section 143(2)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “C” KOLKATA Before Shri N.V.Vasudevan, Judicial Member and Shri Waseem Ahmed, Accountant Member Assessment Year :2009-10 ITO, Ward-9(1), V/s. M/s Acytelene Trexim (P) Ltd., 14, N.S. Road (4th P-7, Choringhee Square, Aayakar Floor), Clive Row, Bhawan, 5th Floor, Kolkata-700 001 Room-14, Kolkata- [PAN No.AACCA 4045 J] 700 069 अपीलाथ" /Appellant .. ""यथ"/Respondent Shri Debasish Banerjee, JCIT-SR-DR अपीलाथ" क" ओर से/By Appellant ""यथ" क" ओर से/By Respondent Shri S.M.Surana, Advocate सुनवाई क" तार"ख/Date of Hearing 20-07-2016 घोषणा क" तार"ख/Date of Pronouncement…

Vijaya Bank, Bangalore vs. Addl..C.I.T., Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 331/BANG/2014[2009-10]Status: DisposedITAT Bangalore22 Jul 2016AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raojoint Commissioner Of Income-Tax, Ltu, Bangalore. … Appellant Vs. M/S. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, Mg Road, Bangalre-560001. … Respondent Pa No.Aaacv 4791 J & M/S. Vijaya Bank, Ho, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner Of Income-Tax, Ltu, Bangalore. … Respondent Revenue By : Shri P.Chandrashekar, Cit(Dr) Assessee By : Shri S.Ananthan, Ca & Smt.Lalitha Ramaswamy, Ca Date Of Hearing : 07/06/2016 Date Of Pronouncement : 22/07/2016 O R D E R Per Inturi Rama Rao, Am : These Are Cross Appeals Filed By The Assessee-Bank As Well As The Revenue Directed Against The Order Of The Cit(A), Ltu, Bangalore, Dated 28/11/2013 For The Assessment Year 2009-10. Ita Nos.318 & 331/Bang/2014 Page 2 Of 25 2. Briefly, Facts Of The Case Are That The Assessee Is A Nationalized Bank Engaged In The Business Of Banking. It Filed Return Of Income For The Assessment Year 2009-10 On 29/9/2009 Declaring A Total Income Of Rs.540,24,85,305/-. Against The Said Return Of Income, Assessment Was Completed By The Addl. Cit (Ltu), Bangalore, U/S 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As 'The Act' For Short] Vide Order Dated 30/08/2011 At A Total Income Of Rs.1205,99,81,409/-. While Doing So, The Ao Made The Following Disallowances:

For Appellant: Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CAFor Respondent: Shri P.Chandrashekar, CIT(DR)

Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER Joint Commissioner of Income-tax, LTU, Bangalore. … Appellant Vs. M/s. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, MG Road, Bangalre-560001. … Respondent PA No.AAACV 4791 J AND M/s. Vijaya Bank, HO, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner of Income-tax, LTU, Bangalore. … Respondent Revenue by : Shri P.Chandrashekar, CIT(DR) Assessee by : Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CA Date of hearing : 07/06/20…

JCIT, Bangalore vs. M/S Vijaya Bank, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 318/BANG/2014[2009-10]Status: DisposedITAT Bangalore22 Jul 2016AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raojoint Commissioner Of Income-Tax, Ltu, Bangalore. … Appellant Vs. M/S. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, Mg Road, Bangalre-560001. … Respondent Pa No.Aaacv 4791 J & M/S. Vijaya Bank, Ho, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner Of Income-Tax, Ltu, Bangalore. … Respondent Revenue By : Shri P.Chandrashekar, Cit(Dr) Assessee By : Shri S.Ananthan, Ca & Smt.Lalitha Ramaswamy, Ca Date Of Hearing : 07/06/2016 Date Of Pronouncement : 22/07/2016 O R D E R Per Inturi Rama Rao, Am : These Are Cross Appeals Filed By The Assessee-Bank As Well As The Revenue Directed Against The Order Of The Cit(A), Ltu, Bangalore, Dated 28/11/2013 For The Assessment Year 2009-10. Ita Nos.318 & 331/Bang/2014 Page 2 Of 25 2. Briefly, Facts Of The Case Are That The Assessee Is A Nationalized Bank Engaged In The Business Of Banking. It Filed Return Of Income For The Assessment Year 2009-10 On 29/9/2009 Declaring A Total Income Of Rs.540,24,85,305/-. Against The Said Return Of Income, Assessment Was Completed By The Addl. Cit (Ltu), Bangalore, U/S 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As 'The Act' For Short] Vide Order Dated 30/08/2011 At A Total Income Of Rs.1205,99,81,409/-. While Doing So, The Ao Made The Following Disallowances:

For Appellant: Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CAFor Respondent: Shri P.Chandrashekar, CIT(DR)

Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER Joint Commissioner of Income-tax, LTU, Bangalore. … Appellant Vs. M/s. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, MG Road, Bangalre-560001. … Respondent PA No.AAACV 4791 J AND M/s. Vijaya Bank, HO, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner of Income-tax, LTU, Bangalore. … Respondent Revenue by : Shri P.Chandrashekar, CIT(DR) Assessee by : Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CA Date of hearing : 07/06/20…

M/S D.K.Basak Jewellers Pvt. Ltd., Kolkata vs. DCIT. Cir. 12, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 51/KOL/2013[2009-10]Status: DisposedITAT Kolkata20 Jul 2016AY 2009-10

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

For Appellant: S/Shri S. L. Kochar & Anil Kochar, AdvocatesFor Respondent: Shri Rajat Kumar Kureel, JCIT, Sr. DR

Section 133ASection 143(3)

…ary findings by the Assessing Officer, there is no merit in not adopting the method of valuation of stock being consistently followed by the assessee. Further we find support from the ratio laid down by the Hon'ble Supreme Court in Chainrup Sampat Ram Vs. CIT 24 ITR 481 (SC) (supra) wherein it has been held that the value of stock cannot be appreciated higher than the cost because the closing stock is not the source of profit for the assessee. It has also been held by the Hon’ble Supreme Court that the closing stock is to be valued either at cost or market value, whichever is low. In the facts and circumstances o…

D.C.I.T Cir - 12, Kolkata. vs. M/S D.K..Basak Jewellers Pvt Ltd., Kolkata

In the result, the appeal of the assessee in ITA No

ITA 379/KOL/2013[2009-10]Status: DisposedITAT Kolkata20 Jul 2016AY 2009-10

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

For Appellant: S/Shri S. L. Kochar & Anil Kochar, AdvocatesFor Respondent: Shri Rajat Kumar Kureel, JCIT, Sr. DR

Section 133ASection 143(3)

…ary findings by the Assessing Officer, there is no merit in not adopting the method of valuation of stock being consistently followed by the assessee. Further we find support from the ratio laid down by the Hon'ble Supreme Court in Chainrup Sampat Ram Vs. CIT 24 ITR 481 (SC) (supra) wherein it has been held that the value of stock cannot be appreciated higher than the cost because the closing stock is not the source of profit for the assessee. It has also been held by the Hon’ble Supreme Court that the closing stock is to be valued either at cost or market value, whichever is low. In the facts and circumstances o…

A.C.I.T Cir - 43, Kolkata vs. M/S Jewell India Jewellers, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2085/KOL/2013[2009-10]Status: DisposedITAT Kolkata01 Jun 2016AY 2009-10

Bench: Shri N. V. Vasudevan, Jm & Shri M. Balaganesh, Am]

For Appellant: Shri Alok Kr. Nag, JCIT, Sr. DRFor Respondent: Shri S. M. Surana, Advocate &

Section 143(3)

…ary findings by the Assessing Officer, there is no merit in not adopting the method of valuation of stock being consistently followed by the assessee. Further we find support from the ratio laid down by the Hon'ble Supreme Court in Chainrup Sampat Ram Vs. CIT 24 ITR 481 (SC) (supra) wherein it has been held that the value of stock cannot be appreciated higher than the cost because the closing stock is not the source of profit for the assessee. It has also been held by the Hon’ble Supreme Court that the closing stock is to be valued either at cost or market value, whichever is low. In the facts and circumstances o…

DCIT, New Delhi vs. M/S National Fertilizers Ltd., New Delhi

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee are allowed for all the Assessment Years

ITA 3947/DEL/2013[2006-07]Status: DisposedITAT Delhi31 May 2016AY 2006-07

Bench: Shri N. K. Saini & Smt. Beena A. Pillai

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Sunil Chander Sharma, CIT DR

Section 145Section 37(1)

…d. A.R. submitted that these reports were filed before the Ld. A.O. as well as Ld. CIT(A). He relied upon 19 I.T.A.Nos.3947,3048,3949/Del/2013 I.T.A.Nos.3517-3520/Del/2013 the decision of Hon'ble Supreme Court in the case of Chainroop Sampatram Vs CIT (1953) 24 ITR 481 (S.C.) and Hon'ble Bombay High Court in the case of CIT Vs Indian Rare Earths Ltd. (2015) 375 ITR 276, CIT Vs Corporation Bank Ltd. (1988) 174 ITR 616 (Kar.), Bharat Heavy Electricals Ltd. Vs DCIT (2005) (7) TMI-299-ITAT- Del. 6. On the contrary, Ld. D.R. submitted that the assessee has changed the method of valuation and has not reflected the tru…

M/S National Fertilizer Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals filed by the Revenue are dismissed and the appeals filed by the assessee are allowed for all the Assessment Years

ITA 3520/DEL/2013[2006-07]Status: DisposedITAT Delhi31 May 2016AY 2006-07

Bench: Shri N. K. Saini & Smt. Beena A. Pillai

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Sunil Chander Sharma, CIT DR

Section 145Section 37(1)

…d. A.R. submitted that these reports were filed before the Ld. A.O. as well as Ld. CIT(A). He relied upon 19 I.T.A.Nos.3947,3048,3949/Del/2013 I.T.A.Nos.3517-3520/Del/2013 the decision of Hon'ble Supreme Court in the case of Chainroop Sampatram Vs CIT (1953) 24 ITR 481 (S.C.) and Hon'ble Bombay High Court in the case of CIT Vs Indian Rare Earths Ltd. (2015) 375 ITR 276, CIT Vs Corporation Bank Ltd. (1988) 174 ITR 616 (Kar.), Bharat Heavy Electricals Ltd. Vs DCIT (2005) (7) TMI-299-ITAT- Del. 6. On the contrary, Ld. D.R. submitted that the assessee has changed the method of valuation and has not reflected the tru…

M/S. Ntpc-Sail Power Co. Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result the appeals filed by the assessee for assessment years 2008-09 and 2009-10 stands allowed

ITA 1037/DEL/2013[2008-09]Status: DisposedITAT Delhi31 May 2016AY 2008-09

Bench: Shri N. K. Saini & Smt. Beena Pillai

For Appellant: Shri M.P.Rastogi, AdvFor Respondent: Shri Sunil Chandra Sharma, CIT DR

Section 142Section 143

…valuation of closing stock if the change is bona fide and followed regularly thereafter. The loss arising out of revaluation of closing stock was allowable." 4.19 We further find that the Hon'ble Supreme Court in the case of Chainrup Sampatram vs. CIT (1953) 24 ITR 481(SC) has held as under (short notes) : "It is a misconception to think that any profit 'arises out of the valuation of the closing stock' and the situs of its arising or accrual is where the valuation is made. Valuation of unsold stock at the close of an accounting period is a necessary part of the process of determining the trading results of tha…

M/S. Honda Siel Power Products Ltd., Gautam Budh Nagar vs. DCIT, New Delhi

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

ITA 551/DEL/2014[2009-10]Status: DisposedITAT Delhi13 Apr 2016AY 2009-10

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: S/Sh. Neeraj Jain, AdvFor Respondent: Sh. Armendra Kumar, CIT/ DR

Section 143(3)Section 144CSection 2Section 92B

…ons, wherein it has been held that the provision made by the assessee towards obsolete and slow moving items was allowable deduction: • CIT v. British Paints India Ltd.: 188 ITR 44 (SC) • CIT v. Hindustan Zinc Ltd.: 291 ITR 391(SC) • ChainrupSampatram v. CIT: 24 ITR 481 (SC) • Hotline Tele Tube and Components Limited: 175 Taxman 286 (Del. HC) • CIT v. Hughes Communication India Ltd.: 215 Taxman 136 (Del. HC) 55 ITA Nos.551/Del./2014 & 636/Del./2015 • CIT v Becton Dickinson India (P.) Ltd.: 214 Taxman 636 (Del. HC) • CIT v Bharat Commerce & Industries Ltd.: 107 Taxman 135 (Del. HC) • JetAirways India (P) Ltd. vs…

Hunter Douglas India P.Ltd, Mumbai vs. DCIT 8(2), Mumbai

In the result, the assessee’s appeals for both the A

ITA 2769/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Nov 2015AY 2009-10

Bench: Shri Jason P. Boaz, Am & Shri Ram Lal Negi, Jm आयकर अपील सं./I.T.A. Nos. 2769/Mum/2014 & 877/Mum/2015 ("नधा"रण वष" / Assessment Years: 2009-10 & 2010-11) Hunter Douglas India Private Limited Dy. Cit-8(2), C-102, Mangalya Building, Aaykar Bhavan, बनाम/ Marol Maronshi Road, Mumbai Opp. Fire Brigade, Andheri (E), Vs. Mumbai-400 059 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aaach 2712 F (अपीलाथ" /Appellant) (""यथ" / Respondent) : अपीलाथ" क" ओर से / Appellant By : Shri Reepal Tralshawala ""यथ" क" ओर से/Respondent By : Ms. Kusum Bansal

For Appellant: Shri Reepal TralshawalaFor Respondent: Ms. Kusum Bansal

Section 115JSection 143(1)Section 143(3)

…g judicial pronouncement: (i) Avaya Global Connect ltd. 122 TTJ (Mum) 300 (ii) Atlas Copco (India) Ltd. – ITA No. 448/PN/2010 dated 30.1.2012 (iii) CIT vs. Becton Dickinson India (P) Ltd. (2013) 214 Taxman 636 (Delhi HC) (iv) Chainrup Sampatram vs. CIT (1953) 24 ITR 481 (SC) 3.3 Per contra, the ld. DR strongly supported the orders of the authorities below. It was submitted that the assessee has not established that the said slow moving/obsolete stock had in fact been destroyed as claimed by the assessee in accordance with its stated policy. If stocks of such value as Rs.32.17 lacs and Rs.20.22 lacs were in fact d…

Commissioner of Income Tax-VI vs. Tupperware India Pvt. Ltd

ITA/787/2014HC Delhi22 Dec 2014

Section 37(1)Section 4

…ad accordingly made a provision based upon the principle that closing stock has to be valued at cost price or market price, whichever is lower. The respondent-assessee has relied upon decision of the Supreme Court in Chainrup Sampat Ram versus CIT (1953) 24 ITR 481 (SC). The aforesaid principle is well recognised and accepted. However, valuation of the closing stock on the basis of market price, if lower, should have foundation and basis on how market price has been computed and not merely on ipsi dixit. The Assessing Officer has not gone into the said aspect but applied principle of matching to mak…

Commissioner of Income Tax(C)-III vs. Svp Industries Ltd

ITA/495/2013HC Delhi03 Sept 2014

Section 3

…,1944, the levy of excise duty is on the manufacture of the finished product the same is quantified and collected on the value (i.e. selling price). Before concluding, we may rely on judgment of this Court in the case of Chainrup Sampatram V. CIT [1953] 24 ITR 481 in which it has been held that "valuation of unsold stock at the close of the accounting period was a necessary part of the process of determining the trading results-of that period. It cannot be regarded as source of profits. That, the true purpose of crediting the value of unsold stock is to balance the cost of the goods entered on the ot…

Commissioner of Income Tax Del vs. Indian Sugar & Gen.Indu.Ex.Imp

ITA - 645 / 2005HC Delhi30 Jan 2012

Section 260A

…2005, 742/2005, 796/2005, 817/2005, 794/2005, 71/2011, 1166/2011 & 1168/2011. Page 15 of 23 This issue is no longer res integra and was settled by the Supreme Court in Chainrup Sampatram v. Commissioner of Income-Tax, West Bengal, (1953) 24 ITR 481 (SC) wherein it has been held as under:- “While we agree with the conclusion that no part of the profits of the firm in the accounting year can be said to have accrued or arisen at Bikaner, the reasoning by which the learned Judges arrived at that conclusion seems to us, with all respect, to proceed on a misconception. It is wrong to assume t…

Commissioner of Income Tax Del

ITA/645/2005HC Delhi30 Jan 2012

Section 260A

…2005, 742/2005, 796/2005, 817/2005, 794/2005, 71/2011, 1166/2011 & 1168/2011. Page 15 of 23 This issue is no longer res integra and was settled by the Supreme Court in Chainrup Sampatram v. Commissioner of Income-Tax, West Bengal, (1953) 24 ITR 481 (SC) wherein it has been held as under:- “While we agree with the conclusion that no part of the profits of the firm in the accounting year can be said to have accrued or arisen at Bikaner, the reasoning by which the learned Judges arrived at that conclusion seems to us, with all respect, to proceed on a misconception. It is wrong to assume t…

M/S. Sanjeev Woolen Mills vs. Commnr. of Income Tax, Mumbai

The appeal is dismissed with no order as to costs

C.A. No.-006735-006736 - 2003Supreme Court24 Nov 2005

For Respondent: Commissioner of Income-tax, Mumbai

Section 80

…utting the stock at the market value does not and cannot bring in any real profit which is necessary for taxing the income under the Act as is held in Chainrup Sampatram vs. C.I.T. [1953] 24 I.T.R. 481 (S.C.) and CIT vs. Hind Construction Ltd.. (1972) 83 ITR 211. Thirdly, it is settled principle of Income-tax Law that it is the real income, which is taxable under the Act. This proposition was enunciated in C.I.T. vs. Birla Gwalior (P.) Ltd., [1973] 89 I.T.R.266 (S.C.), which was pronounced in C.I.T., Bombay City I vs. Messrs. Shoorji Vallabhdas and Co. [1962] 46 I.T.R. 144 (S.C.). U…

Chainrup Sampatram v. CIT