What is CIT v. Dhanrajgirji Raja Narasingirji authority for?

The revenue cannot question the commercial expediency or wisdom of an expenditure incurred by a businessman, as the businessman is the best judge of their own business interests. The department's role is limited to verifying if the expenditure was genuinely incurred and was wholly and exclusively for business purposes.

How many judgments cite CIT v. Dhanrajgirji Raja Narasingirji?

154 judgments on BharatTax cite CIT v. Dhanrajgirji Raja Narasingirji (91 ITR 544), spanning 2009 to 2026.

Which sections of the Income Tax Act does CIT v. Dhanrajgirji Raja Narasingirji come up under?

It is most often cited in judgments turning on Section 37(1), Section 143(3), Section 1961, Section 195, Section 40A(2)(b), Section 68.

CIT v. Dhanrajgirji Raja Narasingirji (91 ITR 544)

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2480/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…ing the expense "dubious and unjustifiable." Revenue's Arguments -Proposition A: The Supreme Court's Doctrine 11. on Business Judgment Does Not Protect Unsubstantiated Expenditure The CIT(A) and assessee rely heavily on CIT v. Dhanrajgiriji Raja Narasingirji (91 ITR 544 SC), Walchand& Co. Pvt. Ltd. v. CIT (65 ITR 381 SC), and J.K. Woollen Manufacturers v. CIT (72 ITR 612 SC) for the proposition that revenue cannot prescribe business expenditure. However, these cases do not shield unsubstantiated or uncommercial expenditure. A careful reading reveals:FromWalchand (65 ITR 381 SC): "It is not open to the Department…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2479/DEL/2011[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…ing the expense "dubious and unjustifiable." Revenue's Arguments -Proposition A: The Supreme Court's Doctrine 11. on Business Judgment Does Not Protect Unsubstantiated Expenditure The CIT(A) and assessee rely heavily on CIT v. Dhanrajgiriji Raja Narasingirji (91 ITR 544 SC), Walchand& Co. Pvt. Ltd. v. CIT (65 ITR 381 SC), and J.K. Woollen Manufacturers v. CIT (72 ITR 612 SC) for the proposition that revenue cannot prescribe business expenditure. However, these cases do not shield unsubstantiated or uncommercial expenditure. A careful reading reveals:FromWalchand (65 ITR 381 SC): "It is not open to the Department…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2478/DEL/2011[2005-06]Status: DisposedITAT Delhi15 Apr 2026AY 2005-06

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…ing the expense "dubious and unjustifiable." Revenue's Arguments -Proposition A: The Supreme Court's Doctrine 11. on Business Judgment Does Not Protect Unsubstantiated Expenditure The CIT(A) and assessee rely heavily on CIT v. Dhanrajgiriji Raja Narasingirji (91 ITR 544 SC), Walchand& Co. Pvt. Ltd. v. CIT (65 ITR 381 SC), and J.K. Woollen Manufacturers v. CIT (72 ITR 612 SC) for the proposition that revenue cannot prescribe business expenditure. However, these cases do not shield unsubstantiated or uncommercial expenditure. A careful reading reveals:FromWalchand (65 ITR 381 SC): "It is not open to the Department…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7855/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Mar 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR

Section 14A

…assessee to Rediffusion have been allowed even in scrutiny assessments. Thereafter, relying upon the following decisions of the Hon'ble Supreme Court, CIT vs. Walchand and Company Private Limited 65 ITR 381 (SC) and CIT v. Dhanrajgirji Raja Narsingirji (1973) 91 ITR 544 (SC), ld. First appellate authority concluded that assessee’s claim of having incurred the 15 ITA Nos.7852 to 7855/Mum/2025 & CO Nos.06 to 09/Mum/2026 (A.Ys. 2013-14, 14-15, 16-17 & 17-18) Raillis India Ltd. expenditure for business purpose stands established. Accordingly, he deleted the disallowance. 34. Before us, strongly relying upon the o…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7854/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Mar 2026AY 2016-17

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR

Section 14A

…assessee to Rediffusion have been allowed even in scrutiny assessments. Thereafter, relying upon the following decisions of the Hon'ble Supreme Court, CIT vs. Walchand and Company Private Limited 65 ITR 381 (SC) and CIT v. Dhanrajgirji Raja Narsingirji (1973) 91 ITR 544 (SC), ld. First appellate authority concluded that assessee’s claim of having incurred the 15 ITA Nos.7852 to 7855/Mum/2025 & CO Nos.06 to 09/Mum/2026 (A.Ys. 2013-14, 14-15, 16-17 & 17-18) Raillis India Ltd. expenditure for business purpose stands established. Accordingly, he deleted the disallowance. 34. Before us, strongly relying upon the o…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7853/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR

Section 14A

…assessee to Rediffusion have been allowed even in scrutiny assessments. Thereafter, relying upon the following decisions of the Hon'ble Supreme Court, CIT vs. Walchand and Company Private Limited 65 ITR 381 (SC) and CIT v. Dhanrajgirji Raja Narsingirji (1973) 91 ITR 544 (SC), ld. First appellate authority concluded that assessee’s claim of having incurred the 15 ITA Nos.7852 to 7855/Mum/2025 & CO Nos.06 to 09/Mum/2026 (A.Ys. 2013-14, 14-15, 16-17 & 17-18) Raillis India Ltd. expenditure for business purpose stands established. Accordingly, he deleted the disallowance. 34. Before us, strongly relying upon the o…

ACIT- 8(1)(1), MUMBAI vs. RALLIS INDIA LIMITED, MUMBAI

06/Mum/2026

ITA 7852/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Mar 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Respondent: Shri Annavaran Kosuri, Sr.AR

Section 14A

…assessee to Rediffusion have been allowed even in scrutiny assessments. Thereafter, relying upon the following decisions of the Hon'ble Supreme Court, CIT vs. Walchand and Company Private Limited 65 ITR 381 (SC) and CIT v. Dhanrajgirji Raja Narsingirji (1973) 91 ITR 544 (SC), ld. First appellate authority concluded that assessee’s claim of having incurred the 15 ITA Nos.7852 to 7855/Mum/2025 & CO Nos.06 to 09/Mum/2026 (A.Ys. 2013-14, 14-15, 16-17 & 17-18) Raillis India Ltd. expenditure for business purpose stands established. Accordingly, he deleted the disallowance. 34. Before us, strongly relying upon the o…

ZETA BUILDTECH PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-7, DELHI, DELHI

In the result, appeal filed by the assessee is allowed

ITA 3449/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Suresh Kumar Gupta, CAFor Respondent: Ms. Ankush Kalra, Sr.DR

Section 142(1)Section 143(1)(a)Section 143(2)

…of view and not from the department's view. To support the above proposition of law, reliance is placed in the following decisions:  S.A. Builders 288 ITR 1 (SC)  CIT v. Walchand & Co. (P) Ltd.[1967] 65 ITR 381 (SC)  CIT Vs. Dhanrajgirji Raja Narasingirji 91 ITR 544 (SC)  J.K. Woollen Manufacturers v. CIT[1969] 72 ITR 612 (SC)  Aluminium Corpn. of India Ltd. v. CIT [1972] 86 ITR 11 (SC)  Dalmia Cement (254 ITR 377) (Del)  Voltamp Transformers Pvt. Ltd. vs. CIT 129 ITR 105 (Guj)  Shaw Wallace Distilleries Ltd. vs. ACIT: 85 TTJ 236 (Del.);  DCIT vs ICICI Web Trade Ltd.: ITA No. 6559/M/2006 (Mum.). 14. Wit…

DCIT, CIRCLE-1 & TPS, HUBBALLI vs. HUBLI SCAN CENTRE PVT. LTD., DHARWAD

In the result the grounds raised by the learned assessing officer are allowed as indicated above

ITA 554/BANG/2025[2018]Status: DisposedITAT Bangalore15 Dec 2025

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2018-19 M/S. Hubli Scan Centre Pvt. The Deputy Commissioner Ltd., Of Income Tax, 6-13 Lgf, Eureka Junction, Circle-1 & Tps, Travelers Bungalow Road Vs. Hubballi Dharwad - 580029 Pan: Aaach9520M Appellant Respondent

For Appellant: Shri Chytanya V Mudrabettu, Advocate

Section 143(3)Section 37(1)

…does not carry enough weight and it does not prove the assessee’s contention otherwise. 10. The Appellant assessee along with its submissions hasrelied upon the Judgment of the theHon’ble Supreme Court in case of CIT V/s Dhanrajgiriji Raja NarsingGiriji (1973)91 ITR 544 that, the department cannot dictate the circumstances in which expenditure is to be incurred. Every businessman knows his interest best. Similarly, the department cannot consider expediency factor, but must confine its examination to the reality aspect of the expenditure i. e. whether the amount claimed as a deduction was factually expended or lai…

TATA TELESERVICES LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 25(1), DELHI

In the result, the appeal of the assessee is allowed

ITA 2549/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.2549/Del./2024, A.Y. 2017-18 Tata Teleservices Limited Assistant Commissioner Of Jeevan Bharati Tower-1, Income Tax, Circle-25(1), 10Th Floor, Vs. C. R. Building, I. P. Estate, 24, Connaught Circus New Delhi New Delhi Pan: Aaact2438A (Appellant) (Respondent) Appellant By Sh. Salil Kapoor, Advocate Ms. Ananya Kapoor, Advocate & Sh. Shivam Yadav, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 30/07/2025 Date Of Pronouncement 27/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 29.03.2024 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 142(1)Section 143(3)Section 35DSection 37(1)

…(132 ITR 377) (Guj) Eastern Investments Ltd. vs. CIT 1951 (20 ITR 1) (SC) S. A. Builders Ltd. vs. CIT (A) 2007 (288) ITR 1 (SC) Sri Venkata Satyanarayana Rice Mill Contractors Co. vs. CIT. [1997] 223 ITR 101 (SC) CIT vs. Dhanrajgirji Raja Narasingirji [1973] 91 ITR 544 (SC). Further the assessee has submitted that, "The assessee further submits that wherever the legislature intends to allow expenditure on deferred 2 Tata Teleservices Limited basis, it clearly provides so in the statue. Intention of the statue is to allow deductibility of expenditure on revenue/capital basis. That, however, wherever expenditur…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S. SHRISH ENTERPRISES PRIVATE LIMITED, DELHI

ITA 5315/DEL/2024[2018-19]Status: DisposedITAT Delhi21 Aug 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandradcit, Room No. 225E, Cr Vs. M/S Shrish Enterprise Building, 2Nd Floor, Private Limited, Hall No. Ip Estate, 3 & 4, M-27/2, Badli New Delhi - 110002 Industrial Estate, Badli, Delhi – 110042 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs0684N Appellant .. Respondent

For Appellant: Sh. Nitin Gulati, Adv. &For Respondent: Sh. Manish Gupta, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 68

…P a g e | 1 DCIT Vs. M/s Shrish Enterprise Pvt. Ltd. (AY: 2018-19) THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER & SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER DCIT, Room No. 225E, CR Vs. M/s Shrish Enterprise Building, 2nd Floor, Private Limited, Hall No. IP Estate, 3 & 4, M-27/2, Badli New Delhi - 110002 Industrial Estate, Badli, Delhi – 110042 "थायीलेखासं./जीआइआरसं./PAN/GIR No: AAFCS0684N Appellant .. Respondent Appellant by : Sh. Nitin Gulati, Adv. & Sh. Shyam Jain, Adv. Respondent by : Sh. Manish Gupta, Sr. DR Date of Hearing 04.08.2025 Date of Pronouncement 21.…

DCIT, CENTRAL CIRCLE-4, NEW DELHI vs. G N INTERNATIONAL P.LTD, NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 2851/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumarg. N. International Pvt. Ltd, Vs. Acit, 3721/1, First Floor, Netaji Circle-10(2), Subhash Marg, Daryaganj, New Delhi New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Dcit, Vs. G. N. International Pvt. Ltd, Central Circle-4, 3721/1, First Floor, Netaji New Delhi Subhash Marg, Daryaganj, New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Assessee By : Shri Salil Agarwal, Sr. Adv Shri Shailesh Gupta, Ca Shri Dadhur Agarwal, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Ms. Neeju Gupta, Sr. Dr Date Of Hearing 25/07/2025 Date Of Pronouncement 30/07/2025

For Appellant: Shri Salil Agarwal, Sr. AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 115BSection 144Section 68

…enue cannot dictate terms as to how the businessman should conduct its affairs. The businessman knows his interest best. Reliance in this regard is placed on the decision of Hon’ble Supreme Court in the case of CIT vs Dhanrajgirji Raja Narsingirji reported in 91 ITR 544(SC). Further, we find that the onus is on the revenue to prove that the opening cash balance stood utilized for some other purposes by the assessee and that the same was not available as a cash source with the assessee as on the date of making the deposit. Reliance in this regard has been placed rightly by the decision of Hon’ble Jurisdictional Hi…

G N INTERNATIONAL P.LTD,NEW DELHI vs. ACIT, CIRCLE-10(2), NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 2676/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumarg. N. International Pvt. Ltd, Vs. Acit, 3721/1, First Floor, Netaji Circle-10(2), Subhash Marg, Daryaganj, New Delhi New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Dcit, Vs. G. N. International Pvt. Ltd, Central Circle-4, 3721/1, First Floor, Netaji New Delhi Subhash Marg, Daryaganj, New Delhi (Appellant) (Respondent) Pan:Aabcg4491K Assessee By : Shri Salil Agarwal, Sr. Adv Shri Shailesh Gupta, Ca Shri Dadhur Agarwal, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Ms. Neeju Gupta, Sr. Dr Date Of Hearing 25/07/2025 Date Of Pronouncement 30/07/2025

For Appellant: Shri Salil Agarwal, Sr. AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 115BSection 144Section 68

…enue cannot dictate terms as to how the businessman should conduct its affairs. The businessman knows his interest best. Reliance in this regard is placed on the decision of Hon’ble Supreme Court in the case of CIT vs Dhanrajgirji Raja Narsingirji reported in 91 ITR 544(SC). Further, we find that the onus is on the revenue to prove that the opening cash balance stood utilized for some other purposes by the assessee and that the same was not available as a cash source with the assessee as on the date of making the deposit. Reliance in this regard has been placed rightly by the decision of Hon’ble Jurisdictional Hi…

AMIT KUMAR SEN,HOOGHLY vs. ACIT, CIRCLE 23(1), , HOOGHLY

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 388/KOL/2025[2017-18]Status: DisposedITAT Kolkata25 Jun 2025AY 2017-18

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.388/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2017-2018) Amit Kumar Sen, Vs Acit, Circle-23(1), Hooghly Sahapur, Tarakeswar, Hooghly (Wb)-712410 Pan No. :Aavfs 6967 R (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri P.K.Ray, Shri S.N.Patra & Shri Trideep Nayak, Ars रधजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Addl/Cit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 25/06/2025 घोषणा की तारीख/Date Of Pronouncement : 25/06/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Assessee Against The Order Dated 27.12.2024 Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Passed In Din & Order No.Itba/Nfac/S/250/2024- 25/1071619653(1) For The Assessment Year 2017-2018. 2. Shri P.K.Ray, Shri S.N.Patra & Shri Trideep Nayak, Ld. Ars Appeared On Behalf Of The Assessee. Shri Abhijit Adhikary, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. At The Time Of Hearing, Ld. Ar Was Specifically Asked To Point Out How The Assessee Has Responded To The Chart Issued By The Assessing Officer, Which Is Recorded In Page 3 Of The Assessment Order. Other Than Referring To Various Replies That Have Been Filed By The Assessee, Which Were Uploaded From The Portal, No Specific Reply To The Said Para Was Pointed Out. Admittedly, The Assessee Has Not Been Able To Dislodge The Said Chart.

For Appellant: Shri P.K.Ray, Shri S.N.Patra and Shri Trideep Nayak, ArsFor Respondent: Shri Abhijit Adhikary, Addl/CIT-Sr.DR

Section 142(1)Section 143(2)

…because the Ld. Assessing Officer believes it is excessive or unnecessary, unless clear evidence is provided to the contrary. The Ld. Assessing Officer. in this case, has failed to provide any such clear evidence. • CIT v. Dhanrajgiri Raja Narasingirji (1973) 91 ITR 544 (SC): This judgment affirms that expenses necessary for business, even if 17 incidental or ancillary, should be allowed under Section 37(1) of the Income Tax Act, 1961. Tea & Tiffin expenses, being integral to the smooth running of business operations, fall squarely within this principle. • CIT v. Sales Magnesite (P) Ltd. (1995) 214 ITR I (SC): Th…

TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

…greement or the surrounding circumstances, the nature or character of the trade or venture, the purpose for which the expenses are incurred and the object which is sought to be achieved for incurring those expenses. iii. In ClTv Dhanajgirji Raja Narasingirji (91 ITR 544), the Supreme Court has held as follows: "It is not open to the department to prescribe what expenditure an Appellant Company should incur and in what circumstances he should incur that expenditure. Every businessman knows his interest best." Thus, whether or not a particular expenditure has to be incurred, depends on the perception of the busines…

ROYAL CANIN INDIA PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, MUMBAI

Appeal is hereby dismissed

ITA 6816/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Apr 2025AY 2021-22

Bench: Shrivikram Singh Yadav & Shri Anikesh Banerjeeroyal Canin India Pvt Ltd Vs Assistant Commissioner Of Income- 1401 & 1402, F Wing, 14Th Tax, Circle 3(1)(1), Floor, Lotus Corporate Park, Aayakar Bhavan, M.K. Road, Cts No.185/A, Graham Firth Mumbai-400 020 Compound, Western Express Highway, Goregaon (East), Mumbai-400 063 Pan: Aadcr4417J Appellant Respondent

For Appellant: ShriK.M. Gupta a/w Shri AnmolFor Respondent: Shri Pankaj Kumar (CIT DR)

Section 143(3)Section 144BSection 144CSection 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRIVIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER Royal Canin India Pvt Ltd vs Assistant Commissioner of Income- 1401 & 1402, F Wing, 14th tax, Circle 3(1)(1), Floor, Lotus Corporate Park, Aayakar Bhavan, M.K. Road, CTS No.185/A, Graham Firth Mumbai-400 020 Compound, Western Express Highway, Goregaon (East), Mumbai-400 063 PAN: AADCR4417J APPELLANT RESPONDENT Assessee by : ShriK.M. Gupta a/w Shri Anmol Chhabra Respondent by : Shri Pankaj Kumar (CIT DR) Date of hearing : 24/04/2025 Date of pronouncement : 28/…

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 366/RJT/2017[2013-14]Status: DisposedITAT Rajkot17 Mar 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)

Section 36(1)(iii)

…ng benefited from the services rendered and also it is he who knows to what extent the benefit ensures to him. Reliance in this regard may be placed on the decision of the Hon'ble Supreme Court in the case of CIT vs. Dhanrajgiri Raja Narasingirji, reported in 91 ITR 544 (SC), wherein it was held that "it is not open to the department to prescribe what expenditure an assessee should incur and in what circumstances he should incur the expenditure. 29. We find that assessee pleaded before the assessing that advances are out of interest- free funds available with the assessee and filed copy of accounts of parties and…

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 236/RJT/2016[2012-13]Status: DisposedITAT Rajkot17 Mar 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)

Section 36(1)(iii)

…ng benefited from the services rendered and also it is he who knows to what extent the benefit ensures to him. Reliance in this regard may be placed on the decision of the Hon'ble Supreme Court in the case of CIT vs. Dhanrajgiri Raja Narasingirji, reported in 91 ITR 544 (SC), wherein it was held that "it is not open to the department to prescribe what expenditure an assessee should incur and in what circumstances he should incur the expenditure. 29. We find that assessee pleaded before the assessing that advances are out of interest- free funds available with the assessee and filed copy of accounts of parties and…

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 235/RJT/2016[2011-12]Status: DisposedITAT Rajkot17 Mar 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)

Section 36(1)(iii)

…ng benefited from the services rendered and also it is he who knows to what extent the benefit ensures to him. Reliance in this regard may be placed on the decision of the Hon'ble Supreme Court in the case of CIT vs. Dhanrajgiri Raja Narasingirji, reported in 91 ITR 544 (SC), wherein it was held that "it is not open to the department to prescribe what expenditure an assessee should incur and in what circumstances he should incur the expenditure. 29. We find that assessee pleaded before the assessing that advances are out of interest- free funds available with the assessee and filed copy of accounts of parties and…

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 234/RJT/2016[2010-11]Status: DisposedITAT Rajkot17 Mar 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)

Section 36(1)(iii)

…ng benefited from the services rendered and also it is he who knows to what extent the benefit ensures to him. Reliance in this regard may be placed on the decision of the Hon'ble Supreme Court in the case of CIT vs. Dhanrajgiri Raja Narasingirji, reported in 91 ITR 544 (SC), wherein it was held that "it is not open to the department to prescribe what expenditure an assessee should incur and in what circumstances he should incur the expenditure. 29. We find that assessee pleaded before the assessing that advances are out of interest- free funds available with the assessee and filed copy of accounts of parties and…

CIT v. Dhanrajgirji Raja Narasingirji

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