CIT v. Ajax Products Ltd.

55 ITR 741Supreme Court of India1965#1840 most cited

What is CIT v. Ajax Products Ltd. authority for?

A taxing statute must be strictly construed: the subject is not to be taxed unless the charging provision clearly and explicitly imposes the obligation, without room for intendment or implication. There is no equity about a tax, and nothing is to be read into or implied within the language used.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

CIT v. Ajax Products Ltd. · 55 ITR 741 · strict construction taxing statutes · interpretation Income Tax Act · charging provision · no equity in tax · tax liability must be clear · subject not taxed unless clearly stated · Section 69B interpretation · Rowlatt J. principle

Sections most often in play

Section 142ASection 143(3)Section 144BASection 153ASection 153DSection 23(1)(a)Section 23(1)(c)Section 23(2)(a)

Issues it is cited on

income-tax officerunexplained investmentsection 23section 142section 139undisclosed incomeprevious yearsection 132section 142(1)section 69condonation of delaysection 143(1)

Judgments citing CIT v. Ajax Products Ltd.

ASSISTANT COMMISSIONER OF INCOME TAX vs. SHELF DRILLING RON TAPPMEYER LIMITED

The appeals are allowed

C.A. No.-010586-010589 - 2025Supreme Court08 Aug 2025

Bench: HON'BLE MRS. JUSTICE B.V. NAGARATHNA

Section 144CSection 153Section 153(1)Section 44B

…18, it was observed that in construing the words of the statute if there are two possible interpretations then effect is to be given to the one that favours the citizen and not the one that imposes a burden on him. In CIT vs. Shahzada Nand & Sons, (1966) 60 ITR 392, this Court reiterated the applicability of the aforesaid principle in context of fiscal statute. In CIT vs. Jargaon Electric Supply Co. Ltd., (1960) 40 ITR 184, this Court speaking through Hidayatullah, J. repelled the contention of the Revenue that it would be unjust to allow escapement of tax in the facts therein by observing that there…

PRAMOD KUMAR CHOUDHARY,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 206/JPR/2025[2012-13]Status: DisposedITAT Jaipur09 Jul 2025AY 2012-13
For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 143(3)Section 147Section 69

…ance in the context of taxing statutes, especially the\nIncome Tax Act, 1961 and has been repeatedly affirmed by the Hon'ble apex Court.\nA pertinent example of this is the judgment, of the Hon'ble Apex Court, in the case\nof CIT vs. Ajax Products Ltd. [1965] 55 ITR 741 (SC), wherein the Hon'ble Apex\nCourt observed as under:\n“—The rule of construction of a taxing statute has been pithily stated by Rowlatt J.\nin Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 K.B. 64, 71\nthus : "In a taxing Act one has to look merely at what is clearly said. There is no\nroom for any intendment. There is no equi…

MR. JOY BAJAJ S/O SHYAM SUNDAR BAJAJ, vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal is allowed

ITA/88/2020HC Rajasthan11 Mar 2025

Bench: AVNEESH JHINGAN,MANEESH SHARMA

Section 14Section 143(3)Section 56Section 56(2)Section 56(2)(vii)

…[2025:RJ-JP:11201-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Income Tax Appeal No. 88/2020 Mr. Joy Bajaj S/o Shyam Sundar Bajaj, Aged About 35 Years, R/o 1/567 Vidyadhar Nagar, Jaipur. ----Appellant Versus The Assistant Commissioner Of Income Tax, Ward 4(2), Jaipur. ----Respondent For Appellant(s) : Mr. Sandeep Taneja with Mr. Aditya Sharma For Respondent(s) : Mr. Sandeep Pathak with Mr. Palash Gupta HON'BLE MR. JUSTICE AVNEESH JHINGAN HON'BLE MR. JUSTICE MANEESH SHARMA Order 11/03/2025 AVNEESH JHINGAN, J:- 1. This appeal is filed against the order of Income Tax Appellate Tribunal (…

DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD vs. PRAKASH NIMMAGADDA, HYDERABAD, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

ITA 974/HYD/2017[2008-09]Status: DisposedITAT Hyderabad16 Dec 2024AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.974/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2008-09) Dy.Cit Vs. Shri Prakash Nimmagadda Circle 1(1) Hyderabad Hyderabad Pan:Acbpn4246R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Dr. Meghnath Chowhan, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/11/2024 घोषणा की तारीख/Pronouncement: 16/12/2024 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Revenue Is Directed Against The Order, Dated 20/03/2017 Of The Learned Cit (A)-9, Hyderabad, Relating To A.Y.2008-09. 2. The Revenue Has Raised The Following Grounds:

For Appellant: Shri K.C. Devdas, CAFor Respondent: : Dr. Meghnath Chowhan, CIT(DR)
Section 17(2)(c)Section 28

…ook at what is clearly said. There is no element of intendment. There is presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly on the language used." The Supreme Court in the case of CIT Vs. Ajax Products Ltd., (55 ITR 741) refers to this judgment. After examination of the matrix of issues it is noted that so long as there is no ambiguity in the statutory language, resort to any interpretative process to unfold the legislative intent becomes impermissible. The supposed intention of the legislature cannot then be appealed to whittle down the statutory language which…

DEPUTY COMMISSIONER OF INCOME TAX -23(1), MUMBAI vs. LAXMI FINANCE AND LEASING COMPANIES CO-OP. SOCIETY LTD, MUMBAI

In the result, appeals of the Revenue and Cross

ITA 4233/MUM/2023[2015-16]Status: DisposedITAT Mumbai29 Aug 2024AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 23(1)(a)

…used therein rather M/s. Laxmi Finance and Leasing Company Co-operative Society Ltd., than from any notions which may be entertained by the court as to that is just or expedient. The expressed intention must guide the court. CIT v. Shahzada Nand & Sons [1966] 60 ITR 392 (SC). The Legislature does not waste its words. Ordinary, a grammatical meaning is to be assigned to the words used while interpreting a provision to honour the rule. The Legislature chooses appropriate words to express what it intends and, therefore, must be attributed with such intention as is conveyed by the words employed so long as this does…

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

ITA 303/BANG/2022[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18
For Appellant: \nShri Chaitanya, Sr. Advocate a/wFor Respondent: \nMs. Neera Malhotra, CIT-DR
Section 143(2)Section 143(3)Section 92C

…as not deliberately incorporated.\nThe applicability of the aforementioned principle in the context of taxing statutes, has been repeatedly affirmed by Hon'ble Supreme Court. We refer to the decision in the case of CIT v. Ajax Products Ltd. reported in (1965) 55 ITR 741, wherein, Hon'ble Supreme Court, citing the observations of Rowlatt J. in Cape Brandy Syndicate v. IRC reported in (1921) 1 KB 64, observed as under:\n\"The rule of construction of a taxing statute has been pithily stated by Rowlatt J. in Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 К.В. 64, 71 thus :\n\"In a taxing Act one has t…

RAM DHAN YADAV,CHOMU JAIPUR vs. INCOME TAX OFFICER, ITO 7(3), JAIPUR

In the result, both the appeals of the assessee are allowed

ITA 369/JPR/2023[2008-09]Status: DisposedITAT Jaipur20 Feb 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…of Section 69B duly enumerated above para . 3.2.2. It is trite to say that the charging provision must clearly impose tax obligation. The subject is not to be taxed unless the charging provision clearly imposes the obligation - CIT vs Ajax Products Ltd (1965) 55 ITR 741 (SC). The facts of the case clearly delineate that the appellant’s does not fall within the ambit of the provision of Sec 69B of the Act. It is prayed that any assessee can only be visited with the tax liability as per the provision of the Act, if the case of the assessee does not fall within the ambit of the particular provision of the Act, no ta…

RAM DHAN YADAV,CHOMU JAIPUR vs. ITO, WD 7(3), JAIPUR

In the result, both the appeals of the assessee are allowed

ITA 366/JPR/2023[2007-2008]Status: DisposedITAT Jaipur20 Feb 2024AY 2007-2008

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

…of Section 69B duly enumerated above para . 3.2.2. It is trite to say that the charging provision must clearly impose tax obligation. The subject is not to be taxed unless the charging provision clearly imposes the obligation - CIT vs Ajax Products Ltd (1965) 55 ITR 741 (SC). The facts of the case clearly delineate that the appellant’s does not fall within the ambit of the provision of Sec 69B of the Act. It is prayed that any assessee can only be visited with the tax liability as per the provision of the Act, if the case of the assessee does not fall within the ambit of the particular provision of the Act, no ta…

DCIT, CENTRAL CIRCLE AJMER vs. VIJAY GRANIMARMO PRIVATE LIMITED, NAYA GHAR GULAB BARI AJMER

In the result of the cross objection of the assessee in CO No

ITA 648/JPR/2023[2020-21]Status: DisposedITAT Jaipur17 Jan 2024AY 2020-21

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. Alka Gautam (CIT) (V.H)
Section 143(3)

…ax Act. It is settled law that the general provision, only, controls cases where the special provision does not apply as the special provision is given effect to the extent of its scope. Hon’ble Supreme Court in the case of CIT v. Shahzada Nand & Sons [1966] 60 ITR 392 (SC) observed as under: “Another rule of construction which is relevant to the present enquiry is expressed in the maxim, generalia specialibus non derogant, which means that when there is a conflict between a general and a special provision, the latter shall prevail. The said principle has been stated in Craies on Statute Law, 5th Edn., at P. 205…

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

ITA 5305/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

…THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN Before Shri Saktijit Dey, Vice President and Shri M. Balaganesh, Accountant Member ITA No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. DCIT, 14th Floor, Tower-C, Building Circle-2, No. 1, DLF City, Phase-II, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J ITA No. 5305/Del/2018 (A.Y.: 2015-16) DCIT, Vs. Schlumberger Asia Services Ltd, 14th Floor, Tower-C, Building No. Circle-2, International Taxation, 1, DLF City, Phase-II, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J Assessee by : Shr…

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

ITA 5223/DEL/2018[2015-16]Status: DisposedITAT Dehradun15 Sept 2023AY 2015-16

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

…THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN Before Shri Saktijit Dey, Vice President and Shri M. Balaganesh, Accountant Member ITA No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. DCIT, 14th Floor, Tower-C, Building Circle-2, No. 1, DLF City, Phase-II, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J ITA No. 5305/Del/2018 (A.Y.: 2015-16) DCIT, Vs. Schlumberger Asia Services Ltd, 14th Floor, Tower-C, Building No. Circle-2, International Taxation, 1, DLF City, Phase-II, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J Assessee by : Shr…

DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

…THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN Before Shri Saktijit Dey, Vice President and Shri M. Balaganesh, Accountant Member ITA No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. DCIT, 14th Floor, Tower-C, Building Circle-2, No. 1, DLF City, Phase-II, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J ITA No. 5305/Del/2018 (A.Y.: 2015-16) DCIT, Vs. Schlumberger Asia Services Ltd, 14th Floor, Tower-C, Building No. Circle-2, International Taxation, 1, DLF City, Phase-II, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J Assessee by : Shr…

SCHLUMBERGER ASIA SERVICES LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed

ITA 6126/DEL/2017[2013-14]Status: DisposedITAT Dehradun15 Sept 2023AY 2013-14

Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J

For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)

…THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN Before Shri Saktijit Dey, Vice President and Shri M. Balaganesh, Accountant Member ITA No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. DCIT, 14th Floor, Tower-C, Building Circle-2, No. 1, DLF City, Phase-II, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J ITA No. 5305/Del/2018 (A.Y.: 2015-16) DCIT, Vs. Schlumberger Asia Services Ltd, 14th Floor, Tower-C, Building No. Circle-2, International Taxation, 1, DLF City, Phase-II, Gurgaon Dehradun (Appellant) (Respondent) PAN: AADCS1107J Assessee by : Shr…

ARUN KUMAR VERMA, BHILAI,DURG vs. INCOME TAX OFFICER 1(2), BHILAI, DURG

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 80/RPR/2023[2019-20]Status: DisposedITAT Raipur29 May 2023AY 2019-20

Bench: Shri Ravish Soodआयकर अपील सं./ Ita Nos.79 & 80/Rpr/2023 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-2020 Arun Kumar Verma Plot No.152, Telgu Para, Maroda Tank, Maroda, Bhilai (C.G.) Pan : Abkpv0530H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.). ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 139Section 142Section 143(1)Section 154Section 36(1)(va)

…ted that. "The Courts have to construe the statute according to the plain language and tenor thereof and if any untoward consequences result there from, it is for authority other than the Court to rectify or prevent the same". 1. In CIT v. Ajax Products Ltd., 55 ITR 741 (SC), it was observed that "If the words of a statute are precise and unambiguous, they must be accepted as declaring the express intentions of the Legislature". 2. In CIT v. Shahzada Nand & Sons. 60 ITR 392 (SC), it is said that "In a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equit…

ARUN KUMAR VERMA, BHILAI,DURG vs. INCOME TAX OFFICER 1(2), BHILAI, DURG

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 79/RPR/2023[2018-19]Status: DisposedITAT Raipur29 May 2023AY 2018-19

Bench: Shri Ravish Soodआयकर अपील सं./ Ita Nos.79 & 80/Rpr/2023 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-2020 Arun Kumar Verma Plot No.152, Telgu Para, Maroda Tank, Maroda, Bhilai (C.G.) Pan : Abkpv0530H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.). ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 139Section 142Section 143(1)Section 154Section 36(1)(va)

…ted that. "The Courts have to construe the statute according to the plain language and tenor thereof and if any untoward consequences result there from, it is for authority other than the Court to rectify or prevent the same". 1. In CIT v. Ajax Products Ltd., 55 ITR 741 (SC), it was observed that "If the words of a statute are precise and unambiguous, they must be accepted as declaring the express intentions of the Legislature". 2. In CIT v. Shahzada Nand & Sons. 60 ITR 392 (SC), it is said that "In a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equit…

SAGE INTERNATIONAL INC.,USA vs. ACIT, CIRCLE INT. TAXATION 3(1)(2), DELHI

In the result, the appeal of the assessee is allowed

ITA 2214/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Apr 2023AY 2018-19

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2018-19] Sage International Inc., Vs Acit, 105, Townline Road, 2 Pmb 332, Circle 3(1)(2), Vernon Hills, Foreign United International States, Usa. Taxation, Delhi. Pan-Aaycs9212R Appellant Respondent Appellant By Shri Pradeep Dinodia, Ca Respondent By Shri Bhuvnesh Kulshrestha, Cit Dr Date Of Hearing 28.02.2023 Date Of Pronouncement 10.04.2023 Order Per Kul Bharat: The Present Appeal Filed By The Assessee Is Directed Against The Order Of Assessing Officer Passed U/S 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (“The Act”) Dated 15.07.2022 For The Assessment Year (“Ay”) 2018-19 .

Section 143(3)Section 234ASection 4Section 90

…itled to relief or deduction of taxes paid in accordance with the provisions of section 90 or section 91 of tile Act. In this respect, reliance is placed the judicial pronouncements of the Hon'ble Supreme Court in the case of CIT v. Shahzada Nand & Sons[1966] 60 ITR 392 (sq, Union of India v. India Fisheries (P.) Ltd. AIR 1966 SC 35 and State of Gujarat v. Patel Ramjibhai AIR 1979 SC 1098 which have laid down that, when there is conflict between a general and special provision, the latter shall prevail or the general provisions must yield to the special provisions. It is further submitted that the deeming provisi…

DY COMMISSIONER OF INCOME TAX-23(1) , MUMBAI vs. M/S LAXMI FINANCE & LEASING COMPANIES COMMERCIAL PREMISES CO-OP SOC. LTD, MUMBAI

In the result, appeal filed by the revenue is dismissed

ITA 1689/MUM/2022[2017-2018]Status: DisposedITAT Mumbai20 Sept 2022AY 2017-2018

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – 23(1) V. M/S. Laxmi Finance & Leasing Companies Commercial Premises Room No. 113, 1St Floor Co-Op. Soc., Limited Matru Mandir, Tardev Road C-25, G-Block, Mumbai – 400 007 Laxmi Towers, Near Icici Bank Bandra Kurla Complex Bandra (E), Mumbai -400051 Pan: Aabal0964G (Appellant) (Respondent) Assessee Represented By : Shri Madhur Agrawal Department Represented By : Shri Manoj Sinha

Section 23(1)(a)

…atute must be collected from the plain and unambiguous expression used therein rather than from any notions which may be entertained by the court as to that is just or expedient. The expressed intention must guide the court. CIT v. Shahzada Nand & Sons [1966] 60 ITR 392 (SC). The Legislature does not waste its words. Ordinary, a grammatical meaning is to be assigned to the words used while interpreting a provision to honour the rule. The Legislature chooses appropriate words to express what it intends and, therefore, must be attributed with such intention as is conveyed by the words employed so long as this does…

M/S. ODISHA POWER GENERATION CORPORATION LIMITED,BHUBANESWAR vs. DCIT,CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

ITA 131/CTK/2019[2014-15]Status: DisposedITAT Cuttack12 Sept 2022AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No Ita No.114/Ctk/2014: Assessment Year Assessment Year : 2010-11

For Appellant: S/Shri Dilip Kr. Mohanty/Pradyumna Kumar Sahu

…ly at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied." was approved by Hon'ble Supreme Court in CIT vs. Ajax Products Ltd. [1965] 55 ITR 741 (SC) and CIT vs. Shahzada Nand & Sons 11966] 60 ITR 392 (SC). In view of the foregoing, the contention of the Assessee; that if this claim is not allowed in this year, it will cause hardship to the Assessee because the aforesaid claim of Rs. 1,60,00,000/- towards ad-hoc provision on account of pay revision has not been claimed by the assessee in t…

M/S. ODISHA POWER GENERATION CORPORATION LIMITED,BHUBANESWAR vs. DCIT,CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

ITA 130/CTK/2019[2013-14]Status: DisposedITAT Cuttack12 Sept 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No Ita No.114/Ctk/2014: Assessment Year Assessment Year : 2010-11

For Appellant: S/Shri Dilip Kr. Mohanty/Pradyumna Kumar Sahu

…ly at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied." was approved by Hon'ble Supreme Court in CIT vs. Ajax Products Ltd. [1965] 55 ITR 741 (SC) and CIT vs. Shahzada Nand & Sons 11966] 60 ITR 392 (SC). In view of the foregoing, the contention of the Assessee; that if this claim is not allowed in this year, it will cause hardship to the Assessee because the aforesaid claim of Rs. 1,60,00,000/- towards ad-hoc provision on account of pay revision has not been claimed by the assessee in t…

M/S. ODISHA POWER GENERATION CORPORATION LTD.,BHUBANESWAR vs. ACIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

ITA 64/CTK/2017[2009-10]Status: DisposedITAT Cuttack12 Sept 2022AY 2009-10

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No Ita No.114/Ctk/2014: Assessment Year Assessment Year : 2010-11

For Appellant: S/Shri Dilip Kr. Mohanty/Pradyumna Kumar Sahu

…ly at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied." was approved by Hon'ble Supreme Court in CIT vs. Ajax Products Ltd. [1965] 55 ITR 741 (SC) and CIT vs. Shahzada Nand & Sons 11966] 60 ITR 392 (SC). In view of the foregoing, the contention of the Assessee; that if this claim is not allowed in this year, it will cause hardship to the Assessee because the aforesaid claim of Rs. 1,60,00,000/- towards ad-hoc provision on account of pay revision has not been claimed by the assessee in t…

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