CIT-I v. Reliance Energy Ltd.

441 ITR 346Supreme Court of India2022#4278 most cited
28

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2025.

Sections most often in play

Section 143(3)Section 1961Section 14ASection 143(2)Section 148Section 263Section 8DSection 10A

Issues it is cited on

section 80absection 80ia(1)section 80iabsection 80ia(4)(iii)convertible foreign exchangeinitial assessment yearretention moneysection 80ia(5)minimum alternate taxsection 80ia(4)section 80csection 24(a)

Judgments citing CIT-I v. Reliance Energy Ltd.

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

In the result, the appeal of the assessee in ITA

ITA 574/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

For Appellant: Advocates Percy Perdiwala and Mahima GoudFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 115JSection 143(3)Section 263Section 43(6)Section 80I

…e. There is no restriction provided under the Act, that the gross total income should only consist of business income. In support of their submission, reliance was placed on the decision of the Hon’ble Supreme Court in the case of CIT v. Reliance Energy Ltd. (441 ITR 346, dated 28.04.2021), Pune Bench of the ITAT in Alfa Laval Lund AB v. CIT (ITA No.1287/PUN/2017, order dated 02.11.2021, AY 2012–13) and Mumbai Bench of the ITAT in Hubtown Ltd. v. CIT (ITA No.696/MUM/2021, order dated 26.04.2022, AY 2015–16). Reference was also made to submissions placed at page nos.331 & 332 of the paper book, showing that all fa…

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

ITA 573/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

For Appellant: Advocates Percy Perdiwala andFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 143(3)Section 144BSection 144C(3)Section 263Section 80Section 801A

…e. There is no restriction provided under the Act, that the gross total income should only consist of business income. In support of their submission, reliance was placed on the decision of the Hon'ble Supreme Court in the case of CIT v. Reliance Energy Ltd. (441 ITR 346, dated 28.04.2021), Pune Bench of the ITAT in Alfa Laval Lund AB v. CIT (ITA No.1287/PUN/2017, order 7 ITA Nos 573 and 5754 of 2024 VIP Private Limited dated 02.11.2021, AY 2012–13) and Mumbai Bench of the ITAT in Hubtown Ltd. v. CIT (ITA No.696/MUM/2021, order dated 26.04.2022, AY 2015–16). Reference was also made to submissions placed at page n…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

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

…led to claim deduction under Section 80-IA of the Act on interest income received from banks. The appellant places reliance upon the following judgments: a) Commissioner of Income-tax-I v. Reliance Energy Ltd. reported in [2021] 127 taxmann.com 69 (SC)/[2022] 441 ITR 346 (SC), wherein the Hon'ble Apex Court has upheld that "there is no restriction on taking into account income from any other source while allowing the deduction computed under section 80-IA, subject to the aggregate of all deductions under Chapter VI-A not exceeding the 'gross total income". The Hon'ble Apex Court further held I.T.A. Nos.: 330, 331…

M/S. GENPACT INDIA,GURGAON vs. DCIT, NEW DELHI

In the result, the appeal of the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6543/DEL/2016[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 10ASection 14A

…in 225 Taxman 11 (Kar)(Mag) (ii) Hewlett Packard Global Soft Ltd reported in 403 ITR 453 (Kar)(FB) (iii) Riviers Home Furnishing reported in 237 Taxman 520 (Del) (iv) Camiceria Apparels India (2019) 103 taxman.com 238(Mad) (v) Reliance Energy Ltd reported in 441 ITR 346(SC) 4. Ld. DR of the Revenue relied on the findings of lower authorities. 5. Considered the rival submissions and material placed on record. We observed that the identical issue was decided by the ITAT against the Revenue in ITA Nos.4060 & 4251/Del/2016 for AY 2011-12 vide order dated 29.04.2024. Relevant finding of the said decision is reproduc…

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

In the result, the appeal of the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6415/DEL/2016[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 10ASection 14A

…in 225 Taxman 11 (Kar)(Mag) (ii) Hewlett Packard Global Soft Ltd reported in 403 ITR 453 (Kar)(FB) (iii) Riviers Home Furnishing reported in 237 Taxman 520 (Del) (iv) Camiceria Apparels India (2019) 103 taxman.com 238(Mad) (v) Reliance Energy Ltd reported in 441 ITR 346(SC) 4. Ld. DR of the Revenue relied on the findings of lower authorities. 5. Considered the rival submissions and material placed on record. We observed that the identical issue was decided by the ITAT against the Revenue in ITA Nos.4060 & 4251/Del/2016 for AY 2011-12 vide order dated 29.04.2024. Relevant finding of the said decision is reproduc…

ACIT-2(1)(1), MUMBAI vs. GEECEE VENTURES LIMITED, MUMBAI

The appeal is allowed for statistical purposes

ITA 4119/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

…r the amount determined as per Section 80IA(5) of the Act. Reliance in this regard was placed by the Learned Authorised Representative for the Assessee on the judgement of Supreme Court in the case of Commissioner of Income Tax Vs. Reliance Energy Ltd. [2022] 441 ITR 346 (SC). It was submitted that the Hon’ble Supreme Court had, after taking into consideration the judgment relied upon by the Learned Departmental Representative, held that there was no ITA 3975&4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year 2018-2019 provision in claiming deduction under Section 80IA of the Act from heads of income other tha…

GEECEE VENTURES LIMITED ,MUMBAI vs. DCIT, CIRCLE 2(1)(1), MUMBAI

The appeal is allowed for statistical purposes

ITA 3975/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

…r the amount determined as per Section 80IA(5) of the Act. Reliance in this regard was placed by the Learned Authorised Representative for the Assessee on the judgement of Supreme Court in the case of Commissioner of Income Tax Vs. Reliance Energy Ltd. [2022] 441 ITR 346 (SC). It was submitted that the Hon’ble Supreme Court had, after taking into consideration the judgment relied upon by the Learned Departmental Representative, held that there was no ITA 3975&4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year 2018-2019 provision in claiming deduction under Section 80IA of the Act from heads of income other tha…

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

…ed on the assessment order. However, the learned Authorized Representative for the assessee submitted that the issue is covered in assessee’s favour by order of Hon'ble Supreme Court in the case of Commissioner of Income Tax vs. Reliance Energy Limited [2022] 441 ITR 346 (SC). In this case, Hon'ble Supreme Court held as under: “7. The contention on behalf of the Revenue before us is that the Assessing Officer was right in holding that the deduction under Section 80-IA of the Act should be restricted to ‘business income’ only. Mr. Arijit Prasad, learned Senior Counsel appearing on behalf of the Revenue, submitted…

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

…ed on the assessment order. However, the learned Authorized Representative for the assessee submitted that the issue is covered in assessee’s favour by order of Hon'ble Supreme Court in the case of Commissioner of Income Tax vs. Reliance Energy Limited [2022] 441 ITR 346 (SC). In this case, Hon'ble Supreme Court held as under: “7. The contention on behalf of the Revenue before us is that the Assessing Officer was right in holding that the deduction under Section 80-IA of the Act should be restricted to ‘business income’ only. Mr. Arijit Prasad, learned Senior Counsel appearing on behalf of the Revenue, submitted…

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

…ed on the assessment order. However, the learned Authorized Representative for the assessee submitted that the issue is covered in assessee's favour by order of Hon'ble Supreme Court in the case of Commissioner of Income Tax vs. Reliance Energy Limited [2022] 441 ITR 346 (SC). In this case, Hon'ble Supreme Court held as under: "7. The contention on behalf of the Revenue before us is that the Assessing Officer was right in holding that the deduction under Section 80-IA of the Act should be restricted to 'business income' only. Mr. Arijit Prasad, learned Senior Counsel appearing on behalf of the Revenue, submitted…

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

…ed on the assessment order. However, the learned Authorized Representative for the assessee submitted that the issue is covered in assessee’s favour by order of Hon'ble Supreme Court in the case of Commissioner of Income Tax vs. Reliance Energy Limited [2022] 441 ITR 346 (SC). In this case, Hon'ble Supreme Court held as under: “7. The contention on behalf of the Revenue before us is that the Assessing Officer was right in holding that the deduction under Section 80-IA of the Act should be restricted to ‘business income’ only. Mr. Arijit Prasad, learned Senior Counsel appearing on behalf of the Revenue, submitted…

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

ITA 1994/PUN/2024[2020-21]Status: DisposedITAT Pune06 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80

…Rs.2,57,90,747/-, after reducing the brought-forward loss of Rs.43,706/-, the Short Term Capital Gain works out to be Rs.2,57,47,041/-. 3.1 Ld.AR relied on the decision of Hon’ble Supreme Court in Commissioner of Income Tax-I Vs. Reliance Energy Ltd., [2022] 441 ITR 346 (SC) dated 28.04.2021. 9 Submission of ld.DR : 4. Ld.Departmental Representative(ld.DR) for the Revenue submitted that Assessee had not claimed deduction on Income from Other Sources and Capital Gains under section 80IAB of the Act in the Return of Income and in the Form No.10CCB. Ld.DR for the Revenue took us through the relevant pages of the Re…

M/S. GENPACT INDIA,GURGAON vs. DCIT, NEW DELHI

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6542/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Ms. Rishpal Bedi, CIT DR
Section 10ASection 143(3)

…Taxman 11 (Kar)(Mag); (ii) Hewlett Packard Global Soft Ltd reported in 403 ITR 453 (Kar)(FB); (iii) Riviers Home Furnishing reported in 237 Taxman 520 (Del); (iv) Camiceria Appareis India (2019) 103 taxman.com 238(Mad); and (v) Reliance Energy Lid reported in 441 ITR 346(SC). 7. Per contra, Ld. DR fairly conceded that the issue under consideration are covered hence not controverted the aforesaid contention of the Ld. AR nor placed any contrary decision before us. 8. In the background of the aforesaid discussions and precedents relied upon by the Ld. AR, we do not find any infirmity in the order passed by ld. CIT(…

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6414/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Ms. Rishpal Bedi, CIT DR
Section 10ASection 143(3)

…Taxman 11 (Kar)(Mag); (ii) Hewlett Packard Global Soft Ltd reported in 403 ITR 453 (Kar)(FB); (iii) Riviers Home Furnishing reported in 237 Taxman 520 (Del); (iv) Camiceria Appareis India (2019) 103 taxman.com 238(Mad); and (v) Reliance Energy Lid reported in 441 ITR 346(SC). 7. Per contra, Ld. DR fairly conceded that the issue under consideration are covered hence not controverted the aforesaid contention of the Ld. AR nor placed any contrary decision before us. 8. In the background of the aforesaid discussions and precedents relied upon by the Ld. AR, we do not find any infirmity in the order passed by ld. CIT(…

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

In the result, the appeal of the assessee is partly allowed

ITA 4865/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Nov 2023AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

For Appellant: Shri R. S. Singhvi, CAFor Respondent: Shri. T. James Singson, CIT DR
Section 24Section 32(1)Section 801ASection 801A(4)

…2018-19, then we do not find any reason as to why the income from the same activity is not to be classified under the head 'income from house property' in these years. 16. Hon'ble Supreme Court in the case of CIT-I vs. Reliance Energy Ltd. reported in (2022) 441 ITR 346 in the context of section 801A, held that the scope of section 801A (5) is limited to determine the quantum of deduction under sub-section (1) of section 801A by treating eligible business for 'only source of income' and same cannot be pressed into service for reading a limitation of deduction under subsection (1) only to 'business income'. The r…

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