CIT v. Chandravilas Hotel (

108 ITR 719High Court1977#12007 most cited
8

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2017 to 2025.

Sections most often in play

Section 115BBESection 131Section 133ASection 143(3)Section 147Section 148Section 37(1)Section 68

Issues it is cited on

section 115beproximate nexussection 91preponderance of probabilityviolation of natural justicecreditworthiness of the creditordisallowance of interest expenditureaddition under section 68section 148a(d)commercial expediencysection 37(1)section 37

Judgments citing CIT v. Chandravilas Hotel (

The Dy.CIT, Central Circle-1, Vadodara vs. Pawan Edifice Pvt. Ltd., Vadodara

Appeals are partly allowed for

ITA 529/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

…judicial precedents including the decisions of the Hon'ble Allahabad High Court in Sabalgarh Industries Ltd. v. CIT (46 ITR 978), the Hon'ble Gujarat High Court in CIT v. Chandravilas Hotel (164 ITR 102), and the Hon'ble Bombay High Court in Amrit Lal & Co. (108 ITR 719) and Ciba Dyes Ltd. v. CIT (25 ITR 102), the Assessing Officer concluded that the mere production of vouchers was insufficient to discharge the burden of proof under section 37(1) of the Act, particularly when the genuineness of expenditure was in doubt. It was held that the possibility of a personal or non-business element in such expenditure co…

Pawan Edifice Pvt. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

ITA 477/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

…judicial precedents including the decisions of the Hon'ble Allahabad High Court in Sabalgarh Industries Ltd. v. CIT (46 ITR 978), the Hon'ble Gujarat High Court in CIT v. Chandravilas Hotel (164 ITR 102), and the Hon'ble Bombay High Court in Amrit Lal & Co. (108 ITR 719) and Ciba Dyes Ltd. v. CIT (25 ITR 102), the Assessing Officer concluded that the mere production of vouchers was insufficient to discharge the burden of proof under section 37(1) of the Act, particularly when the genuineness of expenditure was in doubt. It was held that the possibility of a personal or non-business element in such expenditure co…

Deputy Commissioner of Income Tax, Central Circle -5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue

ITA 4878/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 May 2025AY 2020-21

Bench: Hon'Ble Shri Sandeep Gosain & Hon'Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…f expenditure. The word "exclusively" refers to the motive, objective and purpose of the expenditure and gives jurisdiction to the taxing authorities to examine these matters [Siddho Mal & Sons V/s. CIT 122 ITR 839, 844 (Del); Amritlal & Co. Pr. Ltd. V/s. CIT 108 ITR 719, 729 (Bom)]. The expression "wholly and exclusively" in section 37(1) does not mean "necessarily". Ordinarily, it is for the assessee to decide whether any expenditure should be incurred in the course of its or his business. Such expenditure even may be incurred voluntarily and without any necessity, and if it is incurred for promoting the busine…

Deputy Commissioner of Income Tax, Central Circle -5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4872/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 May 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…f expenditure. The word "exclusively" refers to the motive, objective and purpose of the expenditure and gives jurisdiction to the taxing authorities to examine these matters [Siddho Mal & Sons V/s. CIT 122 ITR 839, 844 (Del); Amritlal & Co. Pr. Ltd. V/s. CIT 108 ITR 719, 729 (Bom)]. The expression "wholly and exclusively" in section 37(1) does not mean "necessarily". Ordinarily, it is for the assessee to decide whether any expenditure should be incurred in the course of its or his business. Such expenditure even may be incurred voluntarily and without any necessity, and if it is incurred for promoting the busine…

Deputy Commissioner of Income Tax, Central Circle-5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue

ITA 4866/MUM/2023[2021-22]Status: DisposedITAT Mumbai27 May 2025AY 2021-22

Bench: Hon’Ble Shri Sandeep Gosain & Hon'Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…f expenditure. The word "exclusively" refers to the motive, objective and purpose of the expenditure and gives jurisdiction to the taxing authorities to examine these matters [Siddho Mal & Sons V/s. CIT 122 ITR 839, 844 (Del); Amritlal & Co. Pr. Ltd. V/s. CIT 108 ITR 719, 729 (Bom)]. The expression "wholly and exclusively" in section 37(1) does not mean "necessarily". Ordinarily, it is for the assessee to decide whether any expenditure should be incurred in the course of its or his business. Such expenditure even may be incurred voluntarily and without any necessity, and if it is incurred for promoting the busine…

Deputy Commissioner of Income Tax, Central Circle- 5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4865/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 May 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…f expenditure. The word "exclusively" refers to the motive, objective and purpose of the expenditure and gives jurisdiction to the taxing authorities to examine these matters [Siddho Mal & Sons V/s. CIT 122 ITR 839, 844 (Del); Amritlal & Co. Pr. Ltd. V/s. CIT 108 ITR 719, 729 (Bom)]. The expression "wholly and exclusively" in section 37(1) does not mean "necessarily". Ordinarily, it is for the assessee to decide whether any expenditure should be incurred in the course of its or his business. Such expenditure even may be incurred voluntarily and without any necessity, and if it is incurred for promoting the busine…

Shri Rampriya Developers Private Limited, Hyderabad vs. Deputy Commissioner of Incometax, Circle-3(1), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1946/HYD/2017[1999-2000]Status: DisposedITAT Hyderabad14 Aug 2024AY 1999-2000

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.1946/Hyd/2017 (िनधा"रण वष"/Assessment Year: 1999-2000) Shri Rampriya Developers Vs. Dy. C. I. T. (P) Ltd Circle 3(1) Hyderabad Hyderabad Pan:Aajcs6629P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 09/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR
Section 143(3)Section 14A

…agreement the nature or the surrounding circumstances, character of the rude or venture, the purpose for which, the expenses are incurred and the object which it sought to be achieved for incurring those expenses”. In Amritlal and Co. Pvt. Ltd. v. CIT |1977] 108 ITR 719, Bench of the Bombay High Court considered the argument of the assessee that a commission paid to the two directors and four salesmen under a resolution of the Company should be allowed as a deduction without any further scrutiny: The court held that the mere fact that the assessee-company should be allowed as a deduction without any further scru…

Arsh Iron & Steel Ltd., Burdwan vs. ACIT, Cir-3, Asansol

In the result, assessee’s appeal is partly allowed

ITA 206/KOL/2014[2009-10]Status: DisposedITAT Kolkata12 May 2017AY 2009-10

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 142(1)Section 143(3)

….45, 5.46 and 5.47 applies here squarely and the same is repeated here:- “CIT vs. Durga Prasad More (1974) 82 ITR 540 (SC) Sumati Dayala vs CIT (1995) 214 ITR 801 (SC) Sickhomal & Sons vs. CIT (1980) 122 ITR 839, 844 (Del) Amritlal & Co. P Ltd. vs. CIT (1977) 108 ITR 719 (Bom) Travancore Titanum Product Ltd. vs. CIT (1966) 60 ITR 277 CIT vs. Indian Cements Ltd. (1975) 98 ITR 69 (Mad) Swadesh Cotton Mills vs. CIT (1967) 63 ITR 57 (SC) Lachminaryan Madan Lal vs. CIT (1972) 86 ITR 739 (SC) WT Suren & Co. P. LTd. vs. CIT (1971) 80 ITR 602 (Bom) CIT vs. Central India Machiery Mfg. Co. Ltd. (1985) 45 CTR (MP) 126, 135…

CIT v. Chandravilas Hotel ( (108 ITR 719) — Cited in 8 Judgments | BharatTax