Challapalli Sugars Ltd. v. CIT

98 ITR 167Supreme Court of India1975#514 most cited

What is Challapalli Sugars Ltd. v. CIT authority for?

Interest on borrowed capital utilized for acquiring a capital asset is capitalized until business commences. Once business is set up, this interest is deductible under section 36(1)(iii) even if the asset has not yet been put to use, accepting commercial accounting standards in the absence of contrary statutory provisions.

185

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

Challapalli Sugars Ltd. v. CIT · 98 ITR 167 · Section 36(1)(iii) · Section 32 · capitalization of interest · actual cost · borrowed capital · commencement of business · asset put to use · deductibility of interest · accounting standards · mercantile system

Also reported as

3 SCC 572

Sections most often in play

Section 37(1)Section 115JBSection 234ASection 250Section 40A(2)(b)Section 43BSection 139(1)Section 143(3)

Issues it is cited on

section 10(5)section 32(1)(iia)section 32(1)demergeradditional depreciationright to receivesection 92bsection 32section 22section 57put to usemercantile system of accounting

Judgments citing Challapalli Sugars Ltd. v. CIT

VNG AUTOMOTIVE P. LTD. vs. ASSTT. COMMISSIONER OF INCOME

The appeals are disposed of as allowed

ITA-795/2004HC Delhi10 Apr 2026
For Appellant: Mr. Satyen Sethi & Mr. Arta Trana PandaFor Respondent: Mr Abhishek Maratha, SSC, Mr Apoorv
Section 148

…ncidental to acquisition of assets and the same would go to reduce the cost of project. 15. Mr. Sethi submitted that the Supreme Court in CIT v. Bokaro Steel Ltd., (1999) 236 ITR 315 (SC), applying the ratio of Challapalli Sugar Mills Ltd. v. CIT, (1975) 98 ITR 167, held that if an assessee receives any amounts, which are inextricably linked with the process of setting-up its plant & machinery, such receipts will go to reduce the cost of its assets, for such receipts are of a capital nature and cannot be taxed as „income‟. In reaching the aforesaid conclusion, Tuticorin Alkali Chemicals & Fertilizers Lt…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI vs. LIGHTHOUSE LEARNING PRIVATE LIMITED, MUMBAI

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

ITA 5433/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 14ASection 250Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER I.T.A. No. 5433/Mum/2024 A.Y: 2020-21 ACIT, Circle – 14(1)(2) Vs Lighthouse Learning Room No. 455, 4th Floor, Private Limited Aayakar Bhavan, MK Windson, 8th floor, 801- Marg, Mumbai – 400020. 803, Off CST Road, Vidyanagari Marg, Kalina Santhcruz E, Mumbai. PAN – AACCE2954N (Appellant) (Respondent) Assessee by Shri Viraj Mehta Revenue by Shri Rajesh Kumar Yadav Date of Hearing 17.12.2025 Date of Pronouncement 30.01.2026 ORDER Per: SHRI. SANDEEP GOSAIN, J.M.: The pres…

M/S. SURAVI INFRASTRUCTURE,MUMBAI vs. INCOME TAX OFFICER WARD 23(3)(1), MUMBAI

In the result the appeal filed by the assessee stands partly allowed

ITA 3702/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai () & Ms. Padmavathy S ()

Section 143(2)Section 143(3)Section 36(1)(iii)

…iture by holding that, land purchased was not put to use. However, it is not undisputed by the authorities that the land was purchased for the purposes of business of the assessee. 8. Hon’ble Supreme Court in case of Challapalli Sugars Ltd. v. CIT reported in 98 ITR 167 and DCIT v. Core Health Care Ltd. reported in 298 ITR 194, has held that interest on borrowings used for acquisition of a capital asset is required to be capitalised up to the date of commencement of business; once business is 7 ITA No. 3702/Mum/2025; A.Y. 2018-19 M/s Suravi Infrastructure set up, such interest is deductible u/s 36(1)(iii) even if…

M/S RPJ MINERALS PVT. LTD ,MAIHAR vs. INCOME TAX OFFICER, WARD -1,SATNA, SATNA

ITA 86/JAB/2022[2017-18]Status: DisposedITAT Jabalpur19 Sept 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

…he application of the income for payment of interest or any other activity could not affect its taxability. It distinguished the principle of capitalization of interest payable as laid down by the Court in the case of Challapalli Sugars Limited vs. CIT (1975) 98 ITR 167, by pointing out that whether a particular receipt was in the nature of income and fell within the charge of section 4 of the Income Tax Act was a question of law, which had to be decided on the basis of the provisions of the Act and the interpretation of the term, “income" given in a number of decisions by 15 ITA No.154/JAB/2016 ITA No.86/JAB/202…

INCOME TAX OFFICER WARD-1 vs. M/S RPJ MINERALS PRIVATE LTD., SATNA

ITA 154/JAB/2016[2012-13]Status: DisposedITAT Jabalpur19 Sept 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

…he application of the income for payment of interest or any other activity could not affect its taxability. It distinguished the principle of capitalization of interest payable as laid down by the Court in the case of Challapalli Sugars Limited vs. CIT (1975) 98 ITR 167, by pointing out that whether a particular receipt was in the nature of income and fell within the charge of section 4 of the Income Tax Act was a question of law, which had to be decided on the basis of the provisions of the Act and the interpretation of the term, "income…

FUSION LASTEK TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

ITA 1094/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad22 May 2025AY 2018-2019

Bench: Us:

Section 143(2)Section 143(3)Section 234CSection 48

…आयर अपीलीय "यायािधकरण म", हैदराबाद ‘बी’ ब"च, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad "ी मंजूनाथ जी, माननीय लेखा सद"य एवं "ी रवीश सूद, माननीय "याियक सद"य SHRI G. MANJUNATHA, HON’BLE ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER आयकरअपीलसं./I.T.A.No.1094/Hyd/2024 (िनधा"रण वष"/ Assessment Year: 2018-19) Fusion Lastek Technologies Vs. Deputy Commissioner of Private Limited, Income tax, Sanath Nagar, Circle-8(1), Hyderabad. Hyderabad. PAN: AAACF7009D (अपीलाथ"/ Appellant) (""थ"/ Respondent) करदाता का "ितिनिध"/ : Sri Pawan Kumar Assessee Chakrapani, CA Represen…

RINA S. MEHTA,MUMBAI vs. ACIT, CC-4(1), MUMBAI

The appeal of the assessee is allowed and the appeal of the revenue\nis dismissed

ITA 704/MUM/2023[1993-94]Status: DisposedITAT Mumbai01 Apr 2025AY 1993-94
Section 234ASection 249(4)Section 250

…27 (1)\nand 27 (2).\n6. Learned Counsel for the assessee has also drawn attention to the\nAccounting Standard (AS) 9 to contend that once there be an accounting\nstandard as noted by the Supreme Court in Challapalli Sugars Ltd., V/s.C.І.Т.\n(S.C.) reported in 98 ITR 167 in the absence of any other statutory provision\nthe accountancy standard should be accepted. In the instant case in dividend\nincome is so far as revenue arising from concerned, the accounting standard\nsets out as under :-\n“13. Revenue arising from the use by others of enterprise resources yielding\ninterest, royalties and dividends should only…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(1), MUMBAI vs. SMT REENA SUDHIR MEHTA , MUMBAI

The appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 1177/MUM/2023[1993-94]Status: DisposedITAT Mumbai01 Apr 2025AY 1993-94

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vijay Mehta, ARFor Respondent: Dr. P. Daniel (Spl. Counsel for the department), Sr. DR
Section 144Section 234ASection 249(4)Section 250

…tion 27 (1) and 27 (2). 6. Learned Counsel for the assessee has also drawn attention to the Accounting Standard (AS) 9 to contend that once there be an accounting standard as noted by the Supreme Court in Challapalli Sugars Ltd., V/s.C.I.T. (S.C.) reported in 98 ITR 167 in the absence of any other statutory provision the accountancy standard should be accepted. In the instant case in dividend income is so far as revenue arising from concerned, the accounting standard sets out as under :- “13. Revenue arising from the use by others of enterprise resources yielding interest, royalties and dividends should only be r…

JCIT(OSD), CIR-3(1)(2), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE (INDIA) LTD, HARYANA

In the result, appeal of the Revenue is dismissed

ITA 1225/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri V. Nand Kumar, CIT-DR
Section 115JSection 143(3)Section 2Section 250Section 391Section 45

…le Apex Court viz. i) M/s. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii) CIT Vs. Woodward Governor Pvt. Ltd., 312 ITR 254 (SC), iii) CIT Vs. U.P. State Industrial Development Corporaiton, 225 ITR 703 (SC); iv) Challapalli Sugars Ltd Vs. CIT, (98 ITR 167) In view of the above, we see no reason to interfere with the order of the Ld. CIT(A) on this issue. This ground of appeal of the Revenue is dismissed. ITA Nos. 1184/Ahd/2018 & 1225/Ahd/2018 Assessee : Reckitt Benckiser Healthcare (I) Ltd Asst. Year : 2011-12 - 45– 12. In the result, appeal of the Revenue is dismissed. 13. To sum up, assessee’s…

RECKITT BENCKISER HEALTHCARE INDIA PVT. LTD., ( FORMERLY KNOWN AS RECKITT BENCKISER HEALTHCARE INDIA LTD.,),HARYANA vs. DCIT, CIRCLE-3(1)(2), AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 1184/AHD/2018[2011-12]Status: FixedITAT Ahmedabad18 Feb 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri V. Nand Kumar, CIT-DR
Section 115JSection 143(3)Section 2Section 250Section 391Section 45

…le Apex Court viz. i) M/s. Rotork Controls India Pvt. Ltd. Vs. CIT, 314 ITR 62 (SC); ii) CIT Vs. Woodward Governor Pvt. Ltd., 312 ITR 254 (SC), iii) CIT Vs. U.P. State Industrial Development Corporaiton, 225 ITR 703 (SC); iv) Challapalli Sugars Ltd Vs. CIT, (98 ITR 167) In view of the above, we see no reason to interfere with the order of the Ld. CIT(A) on this issue. This ground of appeal of the Revenue is dismissed. ITA Nos. 1184/Ahd/2018 & 1225/Ahd/2018 Assessee : Reckitt Benckiser Healthcare (I) Ltd Asst. Year : 2011-12 - 45– 12. In the result, appeal of the Revenue is dismissed. 13. To sum up, assessee’s…

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 461/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 455/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 454/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

DCIT, CIRCLE 6, JAIPUR, NCRB, JPR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 453/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

DCIT, CIRCLE-6 JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, TILAK NAGAR JPR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 452/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

…inextricably linked with the setting up of the capital structure of the assessee- company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. vs. CIT 1974 CTR (SC) 309 : (1975) 98 ITR 167 (SC) : TC 17R.834, this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in s. 10(5) of the Indian IT Act, 1922,…

ACIT, SPECIAL RANGE-6, NEW DELHI vs. MB POWER (MADHYA PRADESH) LTD, NEW DELHI

Appeal is allowed for statistical purposes in above terms

ITA 7967/DEL/2019[2016-17]Status: DisposedITAT Delhi05 Dec 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2016-17 Acit, Vs. Mb Power (Madhya Pradesh) Special Range-6, Ltd., New Delhi 239, Okhla Industrial Estate, Phase-Iii, New Delhi Pan :Aafcm6698A (Appellant) (Respondent) Assessee By Sh. Satyan Sethi, Adv. Sh. A.T. Panda, Adv. Department By Sh. B.S. Anand, Sr. Dr Date Of Hearing 26.11.2024 Date Of Pronouncement 05.12.2024 Order

Section 143(3)Section 56

…ee. These receipts are inextricably linked with the setting up of the capital structure of the assessee company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sigars Ltd. v. CIT (1975) 98 ITR 167, this court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the morning of that expression in section 10(5) of the Indian Income-tax Act, 1922, and w…

ASSISTANT COMMISSIONER COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. IL AND FS TAMILNADU POWER COMPANY LIMITED, CHENNAI

In the result, the appeal of the revenue is dismissed

ITA 1716/CHNY/2024[2011-12]Status: DisposedITAT Chennai04 Dec 2024AY 2011-12

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No. 1716 /Chny/2024 निर्धारण वर्ा /Assessment Years: 2011-12 Assistant Commissioner Of Income Il & Fs Tamilnadu Power Company Tax, Limited, Corporate Circle-1(1), Old No.21, New No.2, Kpr Tower, Chennai 4Th Floor, Greams Road, S.O. Nungambakkam, Chennai-600 006. [Pan: Aabcf1176A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Ashwin, C.A अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Ms.Gowthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 23.09.2024 घोषणा की तारीख /Date Of Pronouncement : 04.12.2024

For Respondent: Ms.Gowthami Manivasagam, JCIT
Section 250

…cably linked with the setting up of the capital structure of the assessee-company. They must, therefore, be viewed as capital receipts going to reduce the cost of construction. In the case of Challapalli Sugars Ltd. v. Commissioner of Income-tax, A.P. ([1975] 98 ITR 167), this Court examined the question whether interest paid before the commencement of production by a company on amounts borrowed for the acquisition and installation of plant and machinery would form a part of the actual cost of the asset to the assessee within the meaning of that expression in Section 10(5) of the Indian Income-tax Act, 1922 and I…

LUPIN LTD.,MUMBAI vs. THE DY CIT, CIRCLE-3(4), MUMBAI

In the result, the appeal of the assessee in I

ITA 77/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 Mar 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Rajan Vora, Shri PranayFor Respondent: Ms. Manju Thakur, Sr. DR
Section 10ASection 115JSection 143(3)Section 154Section 271(1)(c)Section 37(1)

…ing on the case of Challapalli Sugars Ltd.'s case, was also taken up before the Hon'ble Supreme Court in the case of Tuticorin Alkalis (supra). Dealing with the same, the Hon'ble Supreme Court held that : "The question in Challapalli Sugars Ltd.'s case [1975] 98 ITR 167 (SC) was about computation of depreciation and development rebate under the Indian Income-tax Act, 1922. In order to calculate depreciation and development rebate it was necessary to find out "the actual cost" of the plant and machinery purchased by the company. This court held that "cost" is a word of wider connotation than "price". There was a d…

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Challapalli Sugars Ltd. v. CIT (98 ITR 167) — Cited in 185 Judgments | BharatTax