How many judgments cite CIT v. Excel Industries Ltd.?

894 judgments on BharatTax cite CIT v. Excel Industries Ltd. (358 ITR 295), spanning 2013 to 2026.

Which sections of the Income Tax Act does CIT v. Excel Industries Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 37(1), Section 147, Section 14A, Section 132, Section 153A.

CIT v. Excel Industries Ltd.

358 ITR 295Supreme Court of India2013#52 most cited

What is CIT v. Excel Industries Ltd. authority for?

When an income or expenditure is revenue neutral across different assessment years, where any benefit derived is offset by a corresponding liability or reversal, no additional tax liability arises, particularly concerning income recognition under the mercantile system of accounting.

894

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Excel Industries Ltd. · Excel Industries Ltd SC 2013 · Revenue Neutral principle · mercantile system of accounting · right to receive income · taxability of revenue neutral transactions · Section 147 Income Tax Act · reassessment · Section 148 Income Tax Act · profits and gains of business or profession · no tax liability revenue neutral · income accrual reversal

Also reported as

38 Taxmann.com 100219 Taxmann 379

Sections most often in play

Section 143(3)Section 37(1)Section 147 Section 14A Section 132 Section 153A Section 1961 Section 148

Issues it is cited on

right to receive mercantile system of accounting rule of consistency section 35 profits and gains of business or profession revenue expenditure liable to tax section 80i section 37(1)section 28 section 32 capital expenditure

Judgments citing CIT v. Excel Industries Ltd.

SUMITOMO CORPORATION INDIA PVT LTD,DELHI vs. DCIT,CIRCLE-22(2), DELHI

In the result, the appeals of the assessee are partly allowed as indicated above and the stay application is dismissed as infructuous

ITA 4400/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Apr 2026AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member Assessment Year 2020-21 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent It(Tp) Appeal No.14/Del/2025 Assessment Year 2021-22 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor Delhi West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 154Section 80GSection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘I’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCONTANT MEMBER Assessment Year 2020-21 Sumitomo Corporation India Vs. DCIT Pvt. Ltd. Circle -22 (2) 501 & 502, 5th Floor West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 PAN No.AABCS1887M Appellant Respondent IT(TP) Appeal No.14/Del/2025 Assessment Year 2021-22 Sumitomo Corporation India Vs. DCIT Pvt. Ltd. Circle -22 (2) 501 & 502, 5th Floor Delhi West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 PAN No.AABCS18…

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

…ements as listed below were relied upon by the ld.AR in support of this contention: - a. CIT v. GE India Technology Centre Pvt. Ltd. [2020-TII-50-HC-KAR- TP] b. Godrej & Boyce Manufacturing Company Limited [TS-176-SC-2017] 12 c. CIT v. Excel Industries Ltd [358 ITR 295 SC (2013)] d. Radha Swami Satsang vs. CIT [193 ITR 321] 15. Considered the rival submissions and perused the material placed on record. Undisputedly, the issue is covered by the orders of coordinate bench in assessee’s own case for preceding AY 2016-17 and 2017-18 where on similar facts, the addition made on transfer of steam was deleted. The li…

ACIT, MUMBAI vs. BAU DEVELOPERS PRIVATE LIMITED, MUMBAI

ITA 6014/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-19

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Fenil BhattFor Respondent: Shri Solgy Jose T. Kottaram

Section 142(1)Section 143(3)Section 144Section 263

…details in respect of the same during the assessment proceedings. It was contended that in such a situation, no addition was warranted. In support, reliance was placed on the judgment of the Hon'ble Supreme Court in the case of CIT vs. Excel Industries Ltd. (358 ITR 295) (Para 32) and the judgment of the Hon’ble Bombay High Court in the case of CIT vs. Nagri Mills Co. Ltd. (33 ITR 181), Pr. CIT vs. Rajendra Sitaram Goel (166 taxmann.com 221) (Para 5 and 6) and Pr. CIT vs. Rohan Projects (113 taxmann.com 339) (Para 8-9) wherein Courts have held that where the rate of tax is uniform, taxability in one year or anot…

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

ITA 429/RJT/2025[2014-15]Status: DisposedITAT Rajkot10 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 271(1)(c)Section 80P(2)(b)Section 80P(2)(d)

…isdictional ITAT Rajkot, 111 taxmann.com69 ( Rajkot-trib). The Tribunal has allowed the deduction u/s 80P(2)(b) of the Act to the assessee, by giving the findings at para no. 6.1 to 6.3. The Tribunal further placed reliance on CIT v. Excel Industries Ltd (SC) 358 ITR 295 and allowed the deduction thereby following the principle of consistency. Since assessee has been claiming the deduction u/s 80P(2)(b) of the Act, consistently for the last several assessment years and there was no disallowance even in the assessment framed under section 143(3) of the Act Page 5 of 25 Surendranagar Dist. Co-op. Milk Producer per…

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

ITA 2552/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER Maharashtra State Electricity Transmission Company Limited Plot No.C-19, Prakashganga, Bandra Kurla Complex, Bandra East, Bandra (East), Mumbai – 400051. Maharashtra. [PAN:AAECM2936N] …………. Appellant Income Tax Officer Circle 14(1)(1), Vs Mumbai Aayakar Bhavan, Mumbai – 400020. Maharashtra. …………. Respondent (ITA No.2093/Mum/2025) (Assessment Year:2016-2017) Income Tax Officer Circle 14(1)(1), Mumbai Aayakar Bhavan, Mumbai – 400020. Maharashtra. …………. Appellant Vs Maharashtra State…

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

ITA 2093/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose

Section 143(3)Section 14A

ELECTRIC LAMP AND COMPONENT MANUFACTURERS ASSOCIATION OF INDIA,NEW DELHI vs. CIT EXEMPTION, DELHI

In the result, the appeal of the appellant society is allowed

ITA 4309/DEL/2025[-]Status: DisposedITAT Delhi21 Jan 2026

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalelectric Lamp & Component Cit (Exemption) Manufacturers Association Of Delhi. India, Vs. (Civic Centre Minto Road, C/O Kapil Goel, Adv. Delhi-110002). G-8/5 Sector-11, Opposite Sfs Apartment, Rohini, Delhi-110085. Pan-Aaate0234A (Appellant) (Respondent) Assessee By Dr. Kapil Goel, Adv. Department By Shri Jitender Singh, Cit-Dr Date Of Hearing 24/11/2025 Date Of Pronouncement 21/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Exemptions) Dated 30.06.2025 Passed U/S 12Ab(1)(B) Of The Income Tax Act, 1961 (‘The Act’ In Short) Rejecting The Registration Applied By The Assessee U/S 12A Of The Act For The Period From Assessment Years 2021-22 To 2025-26. 2. Brief Facts Of The Case Are That The Appellant Society Was Incorporated On 29.06.1970 & Registered U/S 12A Of The Act In Terms Of Registration Certificate Issued On 30.09.1986. Thereafter, Assessment For Assessment Years 2013-14 & Electric Lamp & Component Manufacturers Association Of India Vs. Ito 2015-16 Were Completed On 29.03.2016 & 11.12.2017 Respectively, Wherein Assessee Was Allowed Exemption U/S 12A Of The Act. The Assessee Was Granted Registration U/S 12Ab Of The Act For Assessment Year 2021-12 To 2023-24 Vide Order Dated 27.05.2021, Thereafter, Assessee Applied For Permanent Approval U/S 12A Which Was Rejected By Ld. Cit(E) Vide Order Dated 30.06.2025 & Further Cancel The Provisional Registration Granted From Assessment Year Onwards.

Section 12ASection 143(3)Section 2(15)

…issued of consistency, reliance is placed on the judgment of Hon’ble Supreme Court in the case of Parsuram Pottery Works Co. Ltd. vs. ITO reported in 106 ITR 01 (SC) and Radhasoami Satsang Vs. CIT reported in 193 ITR 321 (SC) and CIT vs. Excel Industries Ltd. 358 ITR 295 (SC). 7. On the other hand, the Ld. CIT-DR vehemently supported the orders of CIT(E) and submit that CIT(E) has categorically observed that activities of the assessee are not charitable in nature and the entire receipts from the members were utilized for arranging seminars etc. which activities are commercial in nature and, Electric Lamp and Co…

M/S JINDAL EQUIPMENT LEASING CONSULTANCY SERVICES LTD. vs. COMMISSIONER OF INCOME TAX

Appeals stand disposed of in the aforesaid terms

C.A. No.-000152-000152 - 2026Supreme Court09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

…ck-in-trade, does not constitute a “sale” or “exchange” giving rise to taxable business income. Any benefit is, at best, hypothetical until the shares are actually sold. The impugned judgment of the High Court, which 15 (1997) 225 ITR 746 (SC) 16 (2013) 358 ITR 295 (SC) 11 disregards settled principles and binding precedents, is erroneous and liable to be set aside. 5. On the other hand, the learned Additional Solicitor General appearing for the respondent(s) – Department opposed the present appeals and supported the impugned judgment of the High Court. It was submitted that if shares are h…

M/S HALCROW GROUP LTD.,,NEW DELHI vs. DCIT (INTERNTIONAL TAXATION), NEW DELHI

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

ITA 1266/DEL/2017[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Vikas Awasthy & Shri M. Balaganeshm/S. Halcrow Group Ltd, Vs. Dcit, R-27, 2Nd Floor, Pratap Circle-2(1)(1)- Market, Jangpura, B, New It, Delhi-110014 New Delhi (Appellant) (Respondent) Pan: Aaach7866E Assessee By : Shri Salil Kapoor, Adv Ms. Soumya Sigh, Adv Ms. Ananya Kapoor, Adv Revenue By: Ms. Ekta Jain, Cit Dr Date Of Hearing 03/12/2025 Date Of Pronouncement 09/01/2026

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Ms. Ekta Jain, CIT DR

Section 144C(5)

…oss to the exchequer making an addition of an issue arising out of timing difference is not warranted. Reliance in this regard has been rightly placed by the ld AR on the decision of Hon'ble Supreme Court in the case of CIT vs Excel Industries ltd reported in 358 ITR 295 (SC). The relevant operative portion of the said order is reproduced herein:- 28. Thirdly, the real question concerning us is the year in which the assessee is required to pay tax. There is no dispute that in the subsequent accounting year, the assessee did make imports and did derive benefits under the advance licence and the duty entitlement p…

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

…le. This is based on well accepted and acknowledged legal principle of "consistency" and "stare decisis". Refer hon'ble sc decisions in cases of Parsuram Pottery Works Co Ltd vs ITO 106 ITR 1; Radhasoami Satsang vs CIT 193 ITR 321; CIT vs Excel Industries Ltd 358 ITR 295 (three judge bench); Shasun Chemical & Drugs Lid vs CIT 388 ITR 1; Godrej & Boyce Manufacturing Company Ltd vs DCIT 394 ITR 449; PCIT vs Maruti Suzuki ltd 416 ITR 1). Nothing prevented revenue to hold in purchase year and later on that assessee trust has not bonafidely purchased held subject immovable property for "charitable" purposes of trust.…

ASST CIT CIR 29, MUMBAI vs. SHOPPERS STOP LTD, MUMBAI

Accordingly, respectfully following the above decisions of the Tribunal, we confirm the aforesaid action of the CIT(A). All the grounds raised by the Revenue are, therefore, dismissed

ITA 6977/MUM/2014[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Madhur Agrawala &For Respondent: Shri Swapnil Choudhary

Section 143(3)Section 14A

…free fund generated or available with the company, if the interest-free funds were sufficient to meet the investments. In this case this presumption is established considering the finding of fact both by the CIT(A) and Tribunal." 20.2 In Excel Industries Ltd. 358 ITR 295 (SC), it has been held that to recognize income, it has to pass through three tests, namely, (a) whether the income accrued to the assessee is real or hypothetical; (b) whether there is a corresponding liability of the other party to pay the amount; and (c) probability or improbability of realization to be considered from a realistic and practica…

INCOME TAX OFFICER, WARD-3(4), GUWAHATI vs. M/S. S.R.K.M. STEELS (P) LTD, GUWAHATI

In the result, the appeal of the Revenue is dismissed

ITA 274/GTY/2018[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Income Tax Officer, Ward 3(4) M/S S.R.K.M Steels (P) Ltd. Room No.707, 7Th Floor, Aayakar M/S Srkm Steels (P) Ltd. Lokhra Bhawan Poorva, G.S. Road, Road, P.O. Sawkuchi, Guwahati- Vs. Guwahati-781005, Assam 781034, Assam (Appellant) (Respondent) Pan No. Aalcs5046E Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Santosh Kumar Karnani, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 18.12.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar karnani, DR

Section 133(6)

…ompany and rate of tax is uniform. The gain to one and the loss to the other is illusory since what is deferred in one year, would have to bedischarged in the next. In that sense, nobody has won and nobody has lost." In the case ofCIT vs. Excel Industries Ltd 358 ITR 295), theHon'ble Supreme Court had held as follows: "32. Thirdly, the real question concerning us is the year in which the assessee is required to pay tax. There is no dispute that in the subsequent accounting year, the assessee did make imports and did derive benefits under the advance licence and the duty entitlement pass book and paid tax thereon.…

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED ,BANGALORE vs. DCIT, CIRCLE-2(1)(2), BANGALORE

In the result appeal of the assessee is hereby allowed

ITA 980/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 143(3)Section 80J

…t be disputed in the subsequent 2nd and 3rd year of the claim. The assessee in this regard placed reliance on the judgment of Hon’ble Supreme Court in the case of Radhasoami Satsang vs. CIT reported in 193 ITR 321 and CIT vs. Excell Industries Ltd reported in 358 ITR 295. 6.2 Regarding the claim of deduction pertaining to new employees employed during the year under consideration, the assessee submitted that the AO rejected the claim mainly on the ground that the assessee did not submit PAN, Form 16 and other identity documents of all new employees. The assessee submits that this finding is not correct. All neces…

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2(1)(1), BANGALORE

In the result appeal of the assessee is hereby allowed

ITA 653/BANG/2025[2020-21]Status: DisposedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 143(3)Section 80J

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

ITA 652/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Smt. Kavita Jha, Advocate

Section 143(3)Section 80J

…t be disputed in the subsequent 2nd and 3rd year of the claim. The assessee in this regard placed reliance on the judgment of Hon'ble Supreme Court in the case of Radhasoami Satsang vs. CIT reported in 193 ITR 321 and CIT vs. Excell Industries Ltd reported in 358 ITR 295. 6.2 Regarding the claim of deduction pertaining to new employees employed during the year under consideration, the assessee submitted that the AO rejected the claim mainly on the ground that the assessee did not submit PAN, Form 16 and other identity documents of all new employees. The assessee submits that this finding is not correct. All nece…

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

Section 143(3)Section 32Section 80I

…wing decisions wherein it has been held that the Assessing Officer cannot be allowed to change its stance when the same fundamental aspect permits in different assessment years: i) Radhasoami Satsang vs. CIT (1992) 193 ITR 321 (SC) ii) Excel Industries (2013) 358 ITR 295 (SC)] iii) DIT vs. Escorts Cardiac Diseases Hospital Society (2008) 300 ITR 75 (Del) iv) PCIT vs. Shah Virchand Govanji Jewellers (P.) Ltd. (2024) 169 taxmann.com 80/TA No. 72, 73 & 74 of 2019 (Gujarat) v) Prasad Multi Services (P.) Ltd. vs. DCIT (2020) 423 ITR 542 (Gujarat) The assessee claimed following deductions for the administrative expens…

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 80/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

Section 143(3)Section 32Section 80I

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 244/AHD/2022[2019-20]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

Section 143(3)Section 32Section 80I

BHARTI TELEMEDIA LIMITED,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 624/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…is to take contrary stands in different years. Thus, no disallowance is called for even on principles of consistency. Reliance in this regard is placed on the following cases: - Radhasoami Satsang v. CIT 193 ITR 321(SC) - CIT vs. Excel Industries (P) Limited: 358 ITR 295 (SC) - Shasun Chemicals & Drugs Ltd. vs. CIT: 388 ITR 1 (SC) - DIT (E) v. Apparel Export Promotion Council: 244 ITR 734 (Del) - CIT v. Neo Polypack (P) Ltd: 245 ITR 492 (Del.) - CIT v. Girish Mohan Ganeriwala: 260 ITR 417 (P&H) - CIT V. Dalmia Promoters Developers (P) Ltd: 200 CTR 426 (Del.) - Escorts Cardiac Diseases Hospital: 300 ITR 75 (Del) -…

DCIT, CIRCLE 4(2), NEW DELHI vs. M/S BHARTI TELEMEDIA LTD, NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4966/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

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