CIT v. Doom Dooma India Ltd.

310 ITR 392Supreme Court of India2009#3956 most cited

What is CIT v. Doom Dooma India Ltd. authority for?

The 'written down value' (WDV) under Section 43(6)(b) is determined by depreciation that has been 'actually allowed', meaning it has been taken into account or granted and given effect to by the Income-tax Officer in computing taxable income.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v Doom Dooma India Ltd · section 43(6)(b) · written down value · WDV · depreciation actually allowed · actual cost · taxable income · Income-tax Officer

Also reported as

178 Taxmann 261

Sections most often in play

Section 1961Section 143(3)Section 32Section 43(6)(b)Section 10(1)Section 14ASection 28Section 29

Issues it is cited on

section 32(2)section 72asafe harbour rulessection 43(6)preliminary expensessafe harboursection 43dsection 43aactual payment basissection 10(5)section 72written down value

Judgments citing CIT v. Doom Dooma India Ltd.

STEELFAB BUILDING SYSTEMS,MUMBAI vs. DCIT. CENTRAL CIRCLE 1 (2), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

ITA 3196/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17 Steelfab Building Systems Deputy Commissioner Of Income Embassy Centre, 604, Tax, Central Circle – 1(2), 6Th Floor, Jamnalal Bajaj Mumbai Vs. Road, Nariman Point, Mumbai – 400 021 (Pan : Aaxfs5995B) (Appellant) (Respondent)

For Appellant: Shri Fenil Bhatt, AdvocateFor Respondent: Shri Aditya M. Rai, Sr. DR
Section 143(1)Section 143(3)Section 271(1)(c)Section 32

…omputation of capital gain u/s.50, WDV as at 31.03.2003 at Rs.33,02,106/- is to be reduced from sale consideration of Rs.1,45,00,000/-. 7.4. For this, we find force from the decision of Hon'ble Supreme Court in the case of CIT vs. Doom Dooma India Ltd. [2009] 310 ITR 392 (SC). Hon'ble Court analysed the words “depreciation actually allowed” as occurring in section 43(6)(b) to arrive at “written down value” as defined u/s. 43(6). Hon'ble Court, came to conclusion in para-9 that meaning of the words “actually allowed” in section 43(6)(b) is to be “limited to depreciation actually taken into account or granted and g…

LATE PRAVINCHANDRA DWARKADAS DALAL (LEGAL HEIR HITEN PRAVINCHANDRA DALAL),MUMBAI vs. DY COMMISSIONER OF INCOME TAX IT CIRCLE 42(3)(1) ERSTWHILE CIRCLE 33(2), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 5367/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Feb 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Nitesh Joshi, AdvocateFor Respondent: Shri Krishna Kumar – Sr. DR
Section 143(3)Section 32Section 50

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2017-18 Late Pravinchandra Dwarkadas Deputy Commissioner of Dalal Income Tax, Circle – 42(3)(1) (Legal Heir Hiten Pravinchandra Erstwhile Circle 33(2), Dalal) Mumbai Plot No.33, ABCD, Government Vs. Industrial Estate, Kandivali West, Mumbai – 400 067 (Appellant) (Respondent) Present for: Assessee : Shri Nitesh Joshi, Advocate Revenue : Shri Krishna Kumar – Sr. DR Date of Hearing : 26.11.2024 Date of Pronouncement : 21.02.2025 O R D E R PER GIRISH AGRAWAL…

PRASIDH FINCAP LTD. ,NEW DELHI vs. DCIT CIRCLE-20(1), NEW DELHI

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

ITA 1534/DEL/2022[2014-15]Status: DisposedITAT Delhi22 Oct 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

For Appellant: Shri I. P. Bansal, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 143(3)Section 32

…WDV as on 01.04.2011 as per the provisions of the Act. The issue in dispute is no longer res integra in view of the decision of the ITA Nos. 7965 & 7966/Del/2018 Prasidh Fincap Ltd Hon'ble Supreme Court in the case of CIT Vs. Doom Dooma India Ltd reported in 310 ITR 392 (SC) wherein, the Apex court held as under:- “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this Court on the meaning of the words "actually allowed" in section 43(6)(b) in the case of Madeva Upendra Sinai v Union of India (1975) 98 ITR 209 (SC), which reads as under: "T…

PRASIDH FINCAP LTD,NEW DELHI vs. ITO, WARD-20(1), NEW DELHI

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

ITA 7966/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Oct 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

For Appellant: Shri I. P. Bansal, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 143(3)Section 32

…WDV as on 01.04.2011 as per the provisions of the Act. The issue in dispute is no longer res integra in view of the decision of the ITA Nos. 7965 & 7966/Del/2018 Prasidh Fincap Ltd Hon'ble Supreme Court in the case of CIT Vs. Doom Dooma India Ltd reported in 310 ITR 392 (SC) wherein, the Apex court held as under:- “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this Court on the meaning of the words "actually allowed" in section 43(6)(b) in the case of Madeva Upendra Sinai v Union of India (1975) 98 ITR 209 (SC), which reads as under: "T…

PRASIDH FINCAP LTD,NEW DELHI vs. ITO, WARD-20(2), NEW DELHI

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

ITA 7965/DEL/2018[2012-13]Status: DisposedITAT Delhi22 Oct 2024AY 2012-13

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

For Appellant: Shri I. P. Bansal, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 143(3)Section 32

…WDV as on 01.04.2011 as per the provisions of the Act. The issue in dispute is no longer res integra in view of the decision of the ITA Nos. 7965 & 7966/Del/2018 Prasidh Fincap Ltd Hon'ble Supreme Court in the case of CIT Vs. Doom Dooma India Ltd reported in 310 ITR 392 (SC) wherein, the Apex court held as under:- “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this Court on the meaning of the words "actually allowed" in section 43(6)(b) in the case of Madeva Upendra Sinai v Union of India (1975) 98 ITR 209 (SC), which reads as under: "T…

MALABAR CEMENTS LIMITED,PALAKKAD vs. ACIT, PALAKKAD

ITA 71/COCH/2021[2017-18]Status: DisposedITAT Cochin12 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Harikrishnan Unny, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(2)Section 250

…at the “written down 5 ITA Nos.71& 255-257/Coch/2021 Malabar Cements Limited. value” of the relevant fixed asset has to be reduced by the depreciation actually allowed, which is ‘Nil’ in this case. The Hon'ble Apex Court in CIT v. Dom Dooma India Ltd. [2009] 310 ITR 392 (SC) has also decided the very issue against the department as follows: - “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this court on the meaning of the words “actually allowed: in section 43(6)(b) in the case of Madeva Upendra Sinai v. Union of India [1975] 98 ITR 209 (…

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5459/MUM/2017[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5458/MUM/2017[2011-12]Status: DisposedITAT Mumbai30 Jun 2023AY 2011-12
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5457/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2023AY 2010-11
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5327/MUM/2017[2011-12]Status: DisposedITAT Mumbai30 Jun 2023AY 2011-12
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5326/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2023AY 2010-11
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5325/MUM/2017[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 4632/MUM/2017[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

JSW STEEL LIMITED,MUMBAI vs. ACIT,CC-46, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 4287/MUM/2017[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 14A

…2) to simply conclude that depreciation 'actually allowed' also includes unabsorbed depreciation. M/s. JSW Steels Ltd. 16. The meaning of the term actually allowed is interpreted by the Hon'ble Supreme Court, in the case of CIT v. Doom Dooma India Ltd. [2009] 310 ITR 392/178 Taxman 261, wherein it has been held that, the term 'depreciation actually allowed' means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation '(2) only mean depreciation, which has been given…

M/S. CRODA INDIA COMPANY PVT. LTD,MUMBAI vs. THE PR. COMM OF INCOME TAX, MUMBAI-6

In the result, the appeal of the assessee is allowed

ITA 1439/MUM/2022[2017-18]Status: DisposedITAT Mumbai23 Dec 2022AY 2017-18
Section 143(3)Section 14ASection 263Section 32Section 32(1)Section 32(1)(ii)Section 35Section 43(6)

…of the block as on 31/03/3016 as the opening WDV as on 01/04/2016 and granted depreciation on the same in AY 2017-18 i.e the year under consideration. This action of the ld. AO is strictly in consonance with the aforesaid decision of Hon’ble Supreme Court in 310 ITR 392. Hence no error could be attributed in the order of the ld. AO in this regard. 6.3. It is not in dispute that the depreciation on goodwill was claimed by the assessee and actually allowed to the assessee only from AY 2012-13 14 M/s. Croda India Company Pvt. Ltd. onwards. Admittedly, the assessment for the AY 2012-13 was neither subjected to reo…

MALABAR CEMENTS LTD,WALAYAR vs. ACIT, CIRCLE-1, PALAKKAD, PALAKKAD

ITA 256/COCH/2021[2012-2013]Status: DisposedITAT Cochin12 Dec 2022AY 2012-2013

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Harikrishnan Unny, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(2)Section 250

…at the “written down 5 ITA Nos.71& 255-257/Coch/2021 Malabar Cements Limited. value” of the relevant fixed asset has to be reduced by the depreciation actually allowed, which is ‘Nil’ in this case. The Hon'ble Apex Court in CIT v. Dom Dooma India Ltd. [2009] 310 ITR 392 (SC) has also decided the very issue against the department as follows: - “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this court on the meaning of the words “actually allowed: in section 43(6)(b) in the case of Madeva Upendra Sinai v. Union of India [1975] 98 ITR 209 (…

MALABAR CEMENTS LTD,WALAYAR vs. ACIT, CIRCLE-1, PALAKKAD, PALAKKAD

ITA 255/COCH/2021[2011-2012]Status: DisposedITAT Cochin12 Dec 2022AY 2011-2012

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Harikrishnan Unny, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(2)Section 250

…at the “written down 5 ITA Nos.71& 255-257/Coch/2021 Malabar Cements Limited. value” of the relevant fixed asset has to be reduced by the depreciation actually allowed, which is ‘Nil’ in this case. The Hon'ble Apex Court in CIT v. Dom Dooma India Ltd. [2009] 310 ITR 392 (SC) has also decided the very issue against the department as follows: - “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this court on the meaning of the words “actually allowed: in section 43(6)(b) in the case of Madeva Upendra Sinai v. Union of India [1975] 98 ITR 209 (…

MALABAR CEMENTS LTD,WALAYAR vs. ACIT, CIRCLE-1, PALAKKAD, PALAKKAD

ITA 257/COCH/2021[2016-2017]Status: DisposedITAT Cochin12 Dec 2022AY 2016-2017

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Harikrishnan Unny, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(2)Section 250

…at the “written down 5 ITA Nos.71& 255-257/Coch/2021 Malabar Cements Limited. value” of the relevant fixed asset has to be reduced by the depreciation actually allowed, which is ‘Nil’ in this case. The Hon'ble Apex Court in CIT v. Dom Dooma India Ltd. [2009] 310 ITR 392 (SC) has also decided the very issue against the department as follows: - “8. The key word in section 43(6)(b) of the 1961 Act is "actually". We quote hereinbelow an important observation, made by this court on the meaning of the words “actually allowed: in section 43(6)(b) in the case of Madeva Upendra Sinai v. Union of India [1975] 98 ITR 209 (…

JSW STEEL LIMITED,MUMBAI vs. ADDLCIT, BANGALORE

858/M/2011

ITA 858/BANG/2011[2007-08]Status: DisposedITAT Mumbai16 Mar 2022AY 2007-08

Bench: Shri Om Prakash Kant () & Shri Amarjit Singh () Assessment Year: 2007-08 Jsw Steel Limited, The Addl. Cit, Range 11, Jindal Mansion, 5A, Vs. Bangalore. Dr. G. Deshmukh Marg, Mumbai-400026. Pan No. Aaacj 4323 N Appellant Respondent Assessment Year: 2007-08 Dc. Cc.46, M/S Jsw Steel Ltd., R.No. 659, 6Th Floor, Aayakar Vs. Jindal Mansion, 5-A, Dr. G Bhavan, M.K. Road, Deshmukh Marg, Mumbai-20. Mumbai-400026. Pan No. Aaacj 4323 N Appellant Respondent Assessment Year: 2007-08 M/S Jsw Steel Ltd., Dcit, Central Circle 46, Jsw Centre, Bandra Kurla Vs. 6Th Flr., Aayakar Bhavan, M.K. Complex, Road, Mumbai-400051. Mumbai-400020. Pan No. Aaacj 4323 N Appellant Respondent

For Appellant: Mr. Danesh Bafna &For Respondent: Mr. Achal Sharma, CIT-DR
Section 14ASection 37(1)

…into Explanation (2) to simply conclude that depreciation ‘actually allowed’ also includes unabsorbed depreciation. 16. The meaning of the term actually allowed is interpreted by the Hon’ble Supreme Court, in the case of CIT vs. Doom Dooma India Ltd. (2009) 310 ITR 392 (SC), wherein it has been held that, the term ‘depreciation actually allowed’ means depreciation of which the assessee has received effective advantage or benefit and not merely, which is notionally allowed or which is allowable. Accordingly, the words actually allowed under Explanation ‘(2) only mean depreciation, which has been given effect to,…

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. MCLEOD RUSSEL INDIA LTD.

Would be that the agricultural income itself would become liable

ITAT/378/2017HC Calcutta30 Nov 2021

Bench: : The Hon’Ble Justice T.S. Sivagnanam A N D The Hon’Ble Justice Hiranmay Bhattacharyya Date: November 30, 2021. Appearance : Mr. P. K. Bhowmik, Adv. Mr. Soumen Bhattacharjee, Adv. … For The Appellant Mr. Asim Chaudhury, Adv. …For The Respondent The Court : This Appeal By The Revenue Filed Under Section 260A Of The Income Tax Act, 1961 (The Act, In Brevity) Is Against The Order Dated 8Th October, 2015 Passed By The Income Tax Appellate Tribunal “C” Bench, Kolkata In Ita Nos. 262 & 263/Kol/2013 For The Assessment Years 2008-09 & 2009-10. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration:

Section 112Section 115WSection 260A

…OD – 9 IN THE HIGH COURT AT CALCUTTA SPECIAL JURISDICTION (INCOME TAX) ORIGINAL SIDE IA NO: GA/2/2017 (OLD NO. GA/3682/2017) IN ITAT/378/2017 PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA VS. MCLEOD RUSSEL INDIA LTD. BEFORE : THE HON’BLE JUSTICE T.S. SIVAGNANAM A N D THE HON’BLE JUSTICE HIRANMAY BHATTACHARYYA Date: November 30, 2021. Appearance : Mr. P. K. Bhowmik, Adv. Mr. Soumen Bhattacharjee, Adv. … for the appellant Mr. Asim Chaudhury, Adv. …for the respondent The Court : This appeal by the Revenue filed under Section 260A of the Income Tax Act, 1961 (the Act, in brevity) is against the order dated 8th Octo…

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CIT v. Doom Dooma India Ltd. (310 ITR 392) — Cited in 30 Judgments | BharatTax