CIT v. Excel Industries Ltd.

358 ITR 295Supreme Court of India2013#49 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.

935

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2011 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 147Section 14ASection 132Section 153ASection 1961Section 148
Read the full judgment

Issues it is cited on

right to receivemercantile system of accountingrule of consistencysection 35profits and gains of business or professionrevenue expenditureliable to taxsection 80isection 37(1)section 28section 32capital expenditure

Judgments citing CIT v. Excel Industries Ltd.

ACIT Circle-1(1) (E)New Delhi, Delhi vs. Delhi Bureau of Text Books, Delhi

In the result, both the appeals of the Revenue are dismissed

ITA 1115/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, therefore, while respectfully following the decision of the Hon'b…

ACIT Circle-1(1) (E) New Delhi, Delhi vs. Delhi Bureau of Text Books, Delhi

In the result, both the appeals of the Revenue are dismissed

ITA 1114/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Jun 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, therefore, while respectfully following the decision of the Hon'b…

Tata Teleservices Ltd., Noida vs. ACIT, New Delhi

The appeals are allowed and impugned additions stand deleted

ITA 28/DEL/2017[2010-11]Status: DisposedITAT Delhi18 Jun 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Salil Kapoor, Shri Shivam YadavFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)Section 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: G : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITAs No.27 & 28/Del/2017 Assessment Years: 2009-10 & 2010-11 Tata Teleservices Ltd., Vs ACIT, A-37, Circle-25(1), Sector-60, New Delhi. Noida. PAN: AAACT2438A (Appellant) (Respondent) Assessee by : Shri Salil Kapoor, Shri Shivam Yadav, Shri Tarun Chanana, Shri Anil Chachra & Ms Ananya Kapoor, Advocates Revenue by : Shri Mahesh Kumar, CIT-DR Date of Hearing : 02.06.2025 Date of Pronouncement : 18.06.2025 ORDER PER ANUBHAV SHARMA, JM: These appeals are prefer…

Tata Teleservices Ltd., Noida vs. ACIT, New Delhi

The appeals are allowed and impugned additions stand deleted

ITA 27/DEL/2017[2009-10]Status: DisposedITAT Delhi18 Jun 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Salil Kapoor, Shri Shivam YadavFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)Section 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: G : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITAs No.27 & 28/Del/2017 Assessment Years: 2009-10 & 2010-11 Tata Teleservices Ltd., Vs ACIT, A-37, Circle-25(1), Sector-60, New Delhi. Noida. PAN: AAACT2438A (Appellant) (Respondent) Assessee by : Shri Salil Kapoor, Shri Shivam Yadav, Shri Tarun Chanana, Shri Anil Chachra & Ms Ananya Kapoor, Advocates Revenue by : Shri Mahesh Kumar, CIT-DR Date of Hearing : 02.06.2025 Date of Pronouncement : 18.06.2025 ORDER PER ANUBHAV SHARMA, JM: These appeals are prefer…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1473/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Jun 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1696/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1695/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Jun 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 196/DEL/2015[2012-13]Status: DisposedITAT Delhi12 Jun 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 195/DEL/2015[2011-12]Status: DisposedITAT Delhi12 Jun 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

M/S. Ansal Housing & Construction Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 2627/DEL/2013[2008-09]Status: DisposedITAT Delhi12 Jun 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.2627/िद"ी/2013(िन.व. 2008-09) आअसं.1695 और 1696/िद"ी/2016(िन.व. 2009-10 और 2010-11)

For Appellant: Shri Rohit Jain & Ms. Manisha Sharma, Advocates &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 80I

…ng expenses. Therefore, the principle of consistency demand that no disallowance should be made on account of Directors traveling expense. In support of his submissions, he placed reliance on the decisions rendered in the case of CIT vs. Excel Industries Ltd. 358 ITR 295 and Radhasoami Satsang vs. CIT, 193 ITR 321 (SC). He further submitted that the AO for the first time in AY 2007-08 allocated aforesaid expenses to various eligible projects in the sales ratio. On appeal, the CIT(A) deleted 50% of Directors traveling expenses. On further appeal, the Tribunal vide order dated 26.07.2024(supra) upheld the order of…

Income Tax Officer, Parwanoo, H.P vs. Deyem Industry, Nalagarh Solan

In the result, appeal of the Revenue is dismissed

ITA 708/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh09 Jun 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 708/Chd/2023 निर्धारण वर्ष / Assessment Year : 2012-13 The ITO Parwanoo, Himachal Pradesh बनाम DEYEM INDUSTRY Nalagarh, Ropar Road Near Hazat Khana, Nalagarh, H.P.- 174101 स्थायी लेखा सं./ PAN NO: AAGFD0437L अपीलार्थी/ Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Ankit Awal, Ms. Khushbu Sood, Advocates राजस्व की ओर से/ Revenue by : Shri Rohit Sharma, CIT DR (Virtual) सुनवाई की ता

For Appellant: Shri Ankit Awal & Ms. Khushbu Sood, AdvocatesFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 143(3)Section 147Section 2(47)Section 271(1)(c)Section 53A

…आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: HYBRID MODE "ी लिलत कुमार, "ाियक सद" एवं "ी कृणव" सहाय, लेखा सद" BEFORE: SHRI. LALIET KUMAR, JM & SHRI. KRINWANT SAHAY, AM आयकर अपील सं./ ITA No. 708/Chd/ 2023 िनधा"रण वष" / Assessment Year : 2012-13 The ITO बनाम DEYEM INDUSTRY Parwanoo, Himachal Pradesh Nalagarh, Ropar Road Near Hazat Khana, Nalagarh, H.P.- 174101 "ायी लेखा सं./PAN NO: AAGFD0437L अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Ankit Awal & Ms. Khushbu Sood, Advocates राज" की ओर से/ Revenue b…

ACIT, Circle-46(1), New Delhi vs. Dabur Invest Corp., Delhi

In the result, appeals of the Revenue are dismissed and appeal

ITA 2454/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

…to the tax matters is an established principle, but principle of consistency does. The principle of consistency is also cardinal principle of taxation as held by the honourable Supreme Court in Radhasoami Satsang v. Commissioner of Income-tax 193 ITR 321 and 358 ITR 295. Further, saying that there was an error in earlier acceptance of the order/stand of the assessee, therefore revenue‟s stand is changed stating that there is no heroism revenue and the assessee for such a long time. In the present case the only pillar on which changed stand of revenue stands is the decision of the coordinate bench in case of Mahi…

Dabur Invest Corp, New Delhi vs. JCIT, Range-46, New Delhi

In the result, appeals of the Revenue are dismissed and appeal

ITA 2447/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jun 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

…to the tax matters is an established principle, but principle of consistency does. The principle of consistency is also cardinal principle of taxation as held by the honourable Supreme Court in Radhasoami Satsang v. Commissioner of Income-tax 193 ITR 321 and 358 ITR 295. Further, saying that there was an error in earlier acceptance of the order/stand of the assessee, therefore revenue‟s stand is changed stating that there is no heroism revenue and the assessee for such a long time. In the present case the only pillar on which changed stand of revenue stands is the decision of the coordinate bench in case of Mahi…

Uniphos Enterprises Ltd, Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 3878/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04
For Appellant: "I. TAXABILITY OF ADVANCE LICENCE BENEFIT RECEIVABLE: Rs.9,79
Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…A.Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon'ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the Id AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition was m…

Asst CIT CC 38, Mumbai vs. Uniphos Enterprises Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 3534/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

….Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon’ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the ld AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition…

Addl CIT Cen RG IX, Mumbai vs. Uniphos Enterprises Ltd ( Formlery Known As United Phosphorus Ltd), Mumbai

In the result, the appeal of assessee is allowed

ITA 6236/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

….Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon’ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the ld AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition…

Uniphos Enterprises Ltd ( Formerly Known As United Phosphorus Ltd), Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 6224/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

….Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon’ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the ld AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition…

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

….Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon’ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the ld AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition…

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

….Y. 2000-01 in ITA No. 3456/2004 and in A.Y. 2001-02 in ITA No. 2990/M/2005 and by the decision of Gujarat High Court in A.Y. 1997-98 in tax appeal number 302/2001 as well as by the decision of Hon’ble Apex Court in CIT V Excel Industries Limited reported in 358 ITR 295(SC). 11. On the other hand, the Ld. DR for the revenue supported the order of lower authorities. 12. We have considered the rival submissions of the parties and have gone through the orders of lower authorities and the decisions relied by the ld AR of the assessee. The AO made addition of DEPB receivable by taking view that similar addition…

ITO (International Taxation) Gurgaon, Udyog Vihar, Gurgaon vs. Bain and Company India Private Ltd., Dlf Cyber City Phase-II

In the result, appeals of the Revenue are dismissed

ITA 2869/DEL/2024[2014-15]Status: HeardITAT Delhi28 May 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 195Section 201

…ITA Nos.2867, 2868 & 2869/D/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D” NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA Nos. 2867, 2868 & 2869/Del/2024 िनधा"रणवष"/Assessment Years: 2012-13 to 2014-15 बनाम ITO (INTERNATIONAL BAIN & COMPANY INDIA PVT. LTD., 20th Floor Building No.10, TAXATION), Vs. 3rd Floor, HSIIDC Building, Tower-C, DLF Cyber City, Udyog Vihar, Phase-5, Phase-II, Gurgaon, Gurgaon, Haryana. Haryana. PAN No.RTKB03408G अपीलाथ" Appellant ""यथ"/Respondent Revenue by Ms. Rini Handa, Sr. DR Assessee by Shri Prashant Mehar…