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 366,339 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.

ITO (International Taxation) Gurgaon, Udyog Vihar, Gurgaon vs. Bain and Company India Private Ltd., Gurgaon

In the result, appeals of the Revenue are dismissed

ITA 2867/DEL/2024[2012-13]Status: HeardITAT Delhi28 May 2025AY 2012-13

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…

ACIT, C. R. Building vs. Hansdeep Industries and Trading Company Ltd., Fourth Floor, Link House

In the result, the appeal is allowed

ITA 3466/DEL/2023[2016-17]Status: DisposedITAT Delhi28 May 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Acit, Hansdeep Industries C.R. Building & Trading Company Ltd., New Delhi 4Th Floor, Link House, 3 Bahadur Shah Zafar Marg, New Delhi Pan: Aabcj0776A (Appellant) (Respondent) Assessee By Sh. Ankit Kumar, Adv. Sh. Lalit Mohan, Ca Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 28.05.2025 Date Of Pronouncement 28.05.2025 Order

Section 143(3)Section 5Section 57

…CIT(Appeals) (1965) 57 ITR 21 (SC) held that income-tax is a tax on the real income, i.e., the profits arrived at on commercial principles subject to the provisions of the Income-tax Act. 5.3. Supreme Court in the case of CIT vs. Excel Industries Ltd. (2013) 358 ITR 295 (SC) had held “…going by the accounting standard though the revenue is collectible by certainty, the assessee in the present case, in fact, had not received any interest and hence, interest in question remained only notional interest. As canvassed by the learned counsel for the assessee, some of the parties did not repay even the principal amount…

Dlf Home Developers Limited, New Delhi vs. Principal Commissioner of Income Tax, Delhi-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2585/DEL/2024[2019-20]Status: DisposedITAT Delhi23 May 2025AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Dlf Home Developers Limited, Vs Pr.Cit, 9Th Floor, Dlf Centre, Sansad Delhi-1, Marg, New Delhi-110001. New Delhi Pan-Aaccd0037H Appellant Respondent Appellant By Shri R.S.Singhvi, Ca & Shri Satyajeet Goel, Ca Respondent By Shri Surender Pal, Cit Dr Date Of Hearing 19.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 263

…is. Further, PCIT has not recorded anu finding that the system followed by the assessee has caused any prejudice to the interest of the revenue. In this regard, reference is made to the decision of Apex Court in the case of CIT v. Excel Industries Ltd. [2013] 358 ITR 295 (SC). [Refer internal Page 22-41 & 83-85 of reply dated 22/03/24 placed at page no. 368-387 & 429-431 of the paperbook] [Details of projects - Annexure 9 placed at page no. 1040 of the paperbook] [working of Project wise POCM Annexure 9 placed at Page no. 1038 1060 of the paperbook] [Project-wise break-up of revenue till 31st March 18 and 31st Ma…

Herbalife International India Pvt Ltd vs. The Commissioner of Income Tax

In the result, the assessee's appeal for

ITA/433/2018HC Karnataka20 May 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 143(3)Section 144CSection 260Section 263

…- 1 - ITA No. 433 of 2018 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 20TH DAY OF MAY, 2025 PRESENT THE HON'BLE MR JUSTICE V KAMESWAR RAO AND THE HON'BLE MR JUSTICE S RACHAIAH ITA NO. 433 OF 2018 BETWEEN: HERBALIFE INTERNATIONAL INDIA PVT. LTD., RMZ PINNACLE, NO.15, COMMISSARIAT ROAD, BENGLAURU-560 025. REPRESENTED BY ITS AUTHORISED SIGNATORY, MR. SHANKAR M.S. …APPELLANT (BY SRI. PERCY PARDIWALA, SR. ADVOCATE FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. THE COMMISSIONER OF INCOME-TAX-I, BENGALURU, BMTC BUILDING, 80 FEET ROAD, KORAMAN…

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR
Section 143(3)

…exercise of seeking to disturb year of allowability of expenditure would, in any case, be revenue neutral. The Appellant relies on the following decisions in this regard: Bilahari Investment Private Limited (299 ITR 1-Supreme Court) Excel Industries Limited (358 ITR 295-Supreme Court) Triveni Engg & Industries Ltd4 (336 ITR 374-Delhi High Court) Amec Foster Wheeler India Pvt. Ltd. (ITA 680/CHNY/2020-Chennai ITAT) The Appellant also submits that the aforesaid issue has been covered in Appellant's own case for AY 2016-17 in ITA No. 1284/CHNY/2023, where after considering and appreciating that the provision is an a…

Shri Mukund Bhavan Trust, Pune vs. CIT(E), Pune

In the result, the appeal filed by the assessee is allowed

ITA 1552/PUN/2024[-]Status: DisposedITAT Pune29 Apr 2025

Bench: Shri R. K. Panda & Ms. Astha Chandrashri Mukund Bhavan Trust Cit (Exemption), Pune 1105, Raviwar Peth, Mukund Vs. Bhavan, Pune – 411002 Pan: Aaats5170R (Appellant) (Respondent) Assessee By : Shri V.L. Jain Department By : Shri Mallikarjun Utture, Cit Date Of Hearing : 05-02-2025 Date Of Pronouncement : 29-04-2025 O R D E R

For Appellant: Shri V.L. JainFor Respondent: Shri Mallikarjun Utture, CIT
Section 12ASection 13(1)(a)

…en reopened and contrary to what had been decided by the Commissioner of Income Tax in the earlier proceedings, a different and contradictory stand should have been taken". 31. We find the Hon'ble Supreme Court in the case of Excel Industries Ltd reported in 358 ITR 295 (SC) has observed that "the Revenue cannot be allowed to flip-flop on the issue and it ought let the matter rest rather than spend the tax payers' money in pursuing litigation for the sake of it.” 23 32. In view of the above discussion, we hold that the Ld. CIT(E) is not justified in cancelling the registration on the ground that the trust is cr…

Housing & Urban Development Corporation Ltd, New Delhi vs. Addl. CIT, Range-4, New Delhi

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

ITA 7865/DEL/2018[2007-08]Status: DisposedITAT Delhi25 Apr 2025AY 2007-08

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…e whole exercise Revenue Neutral, e.g. March quarter-we go back up to September preceding year. The same becomes NPA when we reach September of the following year. Reliance in this regard is placed on Commissioner of Income-tax v. Excel Industries Ltd, [2013] 358 ITR 295 (SC) [@para 32] and Commissioner of Income-tax v. Nagri Mills Co, Ltd, [1958] 33 ITR 681 (Bombay) [@para 3].” 18. We have heard the rival submissions and have perused the relevant material on record. This issue was decided by the hon’ble Delhi High Court against the assessee vide its order in ITA 440/2016, 442/2016, 444/2016, 445/2016 & 446/2…

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

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

ITA 7629/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Apr 2025AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…e whole exercise Revenue Neutral, e.g. March quarter-we go back up to September preceding year. The same becomes NPA when we reach September of the following year. Reliance in this regard is placed on Commissioner of Income-tax v. Excel Industries Ltd, [2013] 358 ITR 295 (SC) [@para 32] and Commissioner of Income-tax v. Nagri Mills Co, Ltd, [1958] 33 ITR 681 (Bombay) [@para 3].” 18. We have heard the rival submissions and have perused the relevant material on record. This issue was decided by the hon’ble Delhi High Court against the assessee vide its order in ITA 440/2016, 442/2016, 444/2016, 445/2016 & 446/2…

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Special Range-4, New Delhi

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

ITA 7628/DEL/2018[2008-09]Status: DisposedITAT Delhi25 Apr 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…e whole exercise Revenue Neutral, e.g. March quarter-we go back up to September preceding year. The same becomes NPA when we reach September of the following year. Reliance in this regard is placed on Commissioner of Income-tax v. Excel Industries Ltd, [2013] 358 ITR 295 (SC) [@para 32] and Commissioner of Income-tax v. Nagri Mills Co, Ltd, [1958] 33 ITR 681 (Bombay) [@para 3].” 18. We have heard the rival submissions and have perused the relevant material on record. This issue was decided by the hon’ble Delhi High Court against the assessee vide its order in ITA 440/2016, 442/2016, 444/2016, 445/2016 & 446/2…

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

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

ITA 7626/DEL/2018[2005-06]Status: DisposedITAT Delhi25 Apr 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…e whole exercise Revenue Neutral, e.g. March quarter-we go back up to September preceding year. The same becomes NPA when we reach September of the following year. Reliance in this regard is placed on Commissioner of Income-tax v. Excel Industries Ltd, [2013] 358 ITR 295 (SC) [@para 32] and Commissioner of Income-tax v. Nagri Mills Co, Ltd, [1958] 33 ITR 681 (Bombay) [@para 3].” 18. We have heard the rival submissions and have perused the relevant material on record. This issue was decided by the hon’ble Delhi High Court against the assessee vide its order in ITA 440/2016, 442/2016, 444/2016, 445/2016 & 446/2…

Satish Kumar Agarwal, Jaipur vs. DCIT, Jaipur

In the result the appeal of the assessee is allowed

ITA 1170/JPR/2024[2013-14]Status: DisposedITAT Jaipur17 Apr 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Tarun Mittal, C.A., Ld. ARFor Respondent: Mr. Arvind Kumar, CIT, Ld. DR
Section 115BSection 132(1)Section 132(4)Section 142(1)Section 143(3)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “A”, JAIPUR BEFORE SHRI GAGAN GOYAL, ACCOUNTANT MEMBER AND SHRI NARINDER KUMAR, JUDICIAL MEMBER ITA No. 1170(A.Y. 2013-14)/JPR/2024 Shri Satish Kumar Agrawal, Through Legal Heir Smt. Santosh Agarwal, 462 Ekta Block, Mahaveer Nagar, Tonk Road, Jaipur 302018 PAN No. AAMPA9681K ...... Appellant vs. DCIT, Jaipur …...Respondent Appellant by : Mr. Tarun Mittal, C.A., Ld. AR Respondent by : Mr. Arvind Kumar, CIT, Ld. DR Date of hearing : 03/04/2025 Date of pronouncement :17/04/2025 O R D E R PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the o…

ACIT, Circle-12(2), New Delhi vs. Innovations India Advertising and Event Pvt. Ltd., New Delhi

In the result, appeal of Revenue in ITA No

ITA 534/DEL/2020[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Alok Bhachawat, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 37(1)

…for the proposition that notes on accounts forms part of balance sheet: 1. Bihar Vs. Ziqitza health Care Ltd 246 Comp Cas 180 2. CIT Vs. Shoorji Vallabhdas and Co. [1962] 46 ITR144 3. Godhra Electricity Co. Vs. CIT 4 SCC 530 4. CIT Vs. Excel Industries Ltd 13 SCC 459 10. We have heard the rival submissions and have perused the relevant material on record. We find that there is an entry by way of notes to the Account in the balance sheet with regard to receipt of Rs. 4.37 crore and expenses of Rs. 4.22 crore on account of conducting an event at Norway. The relevant extract from the Notes to Accounts under Re…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 454/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…or add claims unless there are strong, justifiable reasons. Permitting claims for expenditures that were not originally filed would go against these principles and could lead to uncertainty in tax assessments and audits. In CIT v. Excel Industries Ltd. (2013) 358 ITR 295 (SC), the Supreme Court ruled that claims not made in the original return cannot be considered in the absence of exceptional circumstances. The Court emphasized that the income-tax return should be final, subject to valid amendments or rectifications under the law, not as a vehicle for new claims. Taxpayer Cannot Benefit from Own Failure to File…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-I, Lucknow

In the result, appeals vide I

ITA 357/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…r add claims unless there are strong, justifiable reasons. Permitting claims for expenditures that were not originally filed would go against these principles and could lead to uncertainty in tax assessments and audits. In CIT v. Excel Industries Ltd. (2013) 358 ITR 295 (SC), the Supreme Court ruled that claims not made in the original return cannot be considered in the absence of exceptional circumstances. The Court emphasized that the income-tax return should be final, subject to valid amendments or rectifications under the law, not as a vehicle for new claims. Taxpayer Cannot Benefit from Own Failure to File…

DCIT (Ltu), New Delhi vs. M/S. Mawana Sugar Ltd., New Delhi

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6081/DEL/2016[2012-13]Status: DisposedITAT Delhi26 Mar 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

Siel Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6301/DEL/2015[2011-12]Status: DisposedITAT Delhi26 Mar 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

Siel Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6300/DEL/2015[2003-04]Status: DisposedITAT Delhi26 Mar 2025AY 2003-04

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

Pr. CIT -3 vs. Dlf Ltd.(Fomerly Known As Dlf Universal Ltd

ITA/926/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…ed threshold of the total project cost estimated then to delete the addition of Rs. 1,02,84,93,509/-. While deciding this issue AD may however keep in mind the principle laid down by honourable Supreme court in case of CIT v. Excel Industries Ltd. [2013] 358 ITR 295, if AD is satisfied that issue is revenue neutral the matter may be set at rest. Therefore, ground no. 8 of the appeal is allowed with the above direction” 5. We thus find no justification to interfere with the view as expressed by the Tribunal. 6. The second aspect which was sought to be canvassed for our consideration pertained to the…

Pr. CIT -3 vs. Dlf Ltd. (Formerly Known As Dlf Universal Ltd.)

ITA/928/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…ed threshold of the total project cost estimated then to delete the addition of Rs. 1,02,84,93,509/-. While deciding this issue AD may however keep in mind the principle laid down by honourable Supreme court in case of CIT v. Excel Industries Ltd. [2013] 358 ITR 295, if AD is satisfied that issue is revenue neutral the matter may be set at rest. Therefore, ground no. 8 of the appeal is allowed with the above direction” 5. We thus find no justification to interfere with the view as expressed by the Tribunal. 6. The second aspect which was sought to be canvassed for our consideration pertained to the…

Lodha Foundation, Jaipur vs. CIT(Exemption), Jaipur

In the result, appeal of the Revenue is dismissed

ITA 12/JPR/2025[2025-26]Status: DisposedITAT Jaipur21 Feb 2025AY 2025-26

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalm/S. Kaizen Enterprises Pvt. Ltd., Opera Hospital Road, S-67-68, Indra Vihar, Kota- 324005 Pan No.: Aabck 7751L ...... Appellant Vs. Acit, Central Circle, Kota ...... Respondent Acit, Circle-2, Kota ...... Appellant Vs. M/S. Kaizen Enterprises Pvt. Ltd., Opera Hospital Road, S-67-68, Indra Vihar, Kota- 324005 Pan No.: Aabck7751L ...... Respondent

For Appellant: Mr. Mahendra Gargieya, Adv. &For Respondent: Ms. Alka Gautam, CIT-DR, Ld. DR
Section 132Section 143(3)Section 153ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “B”, JAIPUR BEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER M/s. Kaizen Enterprises Pvt. Ltd., Opera Hospital Road, S-67-68, Indra Vihar, Kota- 324005 PAN No.: AABCK 7751L ...... Appellant Vs. ACIT, Central Circle, Kota ...... Respondent ACIT, Circle-2, Kota ...... Appellant Vs. M/s. Kaizen Enterprises Pvt. Ltd., Opera Hospital Road, S-67-68, Indra Vihar, Kota- 324005 PAN No.: AABCK7751L ...... Respondent Appellant by : Mr. Mahendra Gargieya, Adv. & Mr. Hemang Gargieya, Adv., Ld. ARs Respondent by : Ms. Alka Gautam, CIT-D…