CIT-I v. Reliance Energy Ltd.

441 ITR 346Supreme Court of India2022#4218 most cited

What is CIT-I v. Reliance Energy Ltd. authority for?

Deductions under Section 80IA are to be granted from Gross Total Income, not restricted to 'Profits & Gains of Business or Profession' income.

28

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2022 to 2025.

Also referred to as

CIT v. Reliance Energy Ltd · Section 80IA · Section 80IA(5) · Gross Total Income · Profits and Gains of Business or Profession · deduction from income · Supreme Court decision

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.

Dlf Cyber City Developers Ltd., Gurugram vs. DCIT, Circle-1(1), Gurugram

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

ITA 4864/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

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…

Dlf Cyber City Developers Ltd., Gurugram vs. DCIT, Circle-1(1), Gurugram

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

ITA 7407/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

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…

ACIT, Circle-1(1), Gurugram vs. Dlf Cyber City Developers Ltd., Gurugram

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

ITA 1451/DEL/2018[2012-13]Status: DisposedITAT Delhi29 Nov 2023AY 2012-13

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…

Dlf Cyber City Developers Ltd., Gurugram vs. DCIT, Circle-1, Gurugram

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

ITA 1399/DEL/2018[2012-13]Status: DisposedITAT Delhi29 Nov 2023AY 2012-13

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…

Dlf Cyber City Developers Ltd., Gurgaon vs. Addl. CIT, Gurgaon

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

ITA 3692/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Nov 2023AY 2011-12

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…

ACIT Circle-7(1), New Delhi vs. Dlf Assets Pvt. Ltd., New Delhi

Accordingly, the order of the ld. CIT (A) is confirmed and the Revenue’s appeal for AY 2013-14 is dismissed

ITA 8526/DEL/2019[2015-16]Status: DisposedITAT Delhi05 May 2022AY 2015-16

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Satyajeet Goel, CAFor Respondent: Ms. Yagya Saini Kakkar, CIT DR
Section 143(3)Section 80I

…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 80IA, held that the scope of section 80IA (5) is limited to determine the quantum of deduction under sub-section (1) of section 80IA by treating eligible business for ‘only source of income’ and same cannot be pressed into service for reading a limitation of deduction under sub- section (1) only to ‘business income’. The…

ACIT Circle-7(1), New Delhi vs. Dlf Assets Pvt. Ltd., New Delhi

Accordingly, the order of the ld. CIT (A) is confirmed and the Revenue’s appeal for AY 2013-14 is dismissed

ITA 8525/DEL/2019[2014-15]Status: DisposedITAT Delhi05 May 2022AY 2014-15

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Satyajeet Goel, CAFor Respondent: Ms. Yagya Saini Kakkar, CIT DR
Section 143(3)Section 80I

…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 80IA, held that the scope of section 80IA (5) is limited to determine the quantum of deduction under sub-section (1) of section 80IA by treating eligible business for ‘only source of income’ and same cannot be pressed into service for reading a limitation of deduction under sub- section (1) only to ‘business income’. The…

ACIT Circle-7(1), New Delhi vs. Dlf Assets Pvt. Ltd., New Delhi

Accordingly, the order of the ld. CIT (A) is confirmed and the Revenue’s appeal for AY 2013-14 is dismissed

ITA 8524/DEL/2019[2013-14]Status: DisposedITAT Delhi05 May 2022AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Satyajeet Goel, CAFor Respondent: Ms. Yagya Saini Kakkar, CIT DR
Section 143(3)Section 80I

…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 80IA, held that the scope of section 80IA (5) is limited to determine the quantum of deduction under sub-section (1) of section 80IA by treating eligible business for ‘only source of income’ and same cannot be pressed into service for reading a limitation of deduction under sub- section (1) only to ‘business income’. The…