CIT v. Gem India Manufacturing Co.

249 ITR 307Supreme Court of India2001#4721 most cited

What is CIT v. Gem India Manufacturing Co. authority for?

Cutting and polishing of uncut raw diamonds does not constitute manufacturing or production of a new article or thing, as the raw diamonds remain diamonds after the process.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2024.

Also referred to as

CIT v. Gem India Manufacturing Co. · 249 ITR 307 · manufacturing · production · diamond cutting · diamond polishing · raw diamonds · new article

Also reported as

117 Taxmann 368

Judgments citing CIT v. Gem India Manufacturing Co.

RAKESH KUMAR,PATNA vs. DCIT, CIRCLE-4, PATNA

In the result, both the appeals of the assessee for AYs 2012-13

ITA 86/PAT/2017[2013-14]Status: DisposedITAT Patna23 Jul 2024AY 2013-14

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. Nos.85 & 86/Pat/2017 Assessment Years: 2012-13 & 2013-14

Section 143(2)Section 143(3)Section 250Section 80I

…es rise to a new product is manufacturing activity. 16. As far as the judgments relied on by the Ld. AO for the propositions that assessee is not a manufacturer are not applicable on the facts of the instant appeal. In the case Gem India Manufacturing Company 249 ITR 307, the issue in this case was of cutting and polishing of uncut raw diamonds, it was held that raw diamonds remained diamonds even after cutting and polishing (ii) In Buhari Sons Pvt. Ltd.144 ITR 12, the issue in this case was altogether different as to whether Hotel is an industrial undertaking (iii) In before coordinate Bench Pune ITAT the issue…

RAKESH KUMAR,PATNA vs. DCIT, CIRCLE-4, PATNA

In the result, both the appeals of the assessee for AYs 2012-13

ITA 85/PAT/2017[2012-13]Status: DisposedITAT Patna23 Jul 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. Nos.85 & 86/Pat/2017 Assessment Years: 2012-13 & 2013-14

Section 143(2)Section 143(3)Section 250Section 80I

…es rise to a new product is manufacturing activity. 16. As far as the judgments relied on by the Ld. AO for the propositions that assessee is not a manufacturer are not applicable on the facts of the instant appeal. In the case Gem India Manufacturing Company 249 ITR 307, the issue in this case was of cutting and polishing of uncut raw diamonds, it was held that raw diamonds remained diamonds even after cutting and polishing (ii) In Buhari Sons Pvt. Ltd.144 ITR 12, the issue in this case was altogether different as to whether Hotel is an industrial undertaking (iii) In before coordinate Bench Pune ITAT the issue…

DILIP BUILDCON LTD ,BHOPAL vs. DCIT CENTRAL-1, BHOPAL

In the result, appeal of Assessee is allowed

ITA 163/IND/2021[2018-19]Status: DisposedITAT Indore20 Oct 2022AY 2018-19

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2018-19 M/S. Dilip Buildcon Ltd. Acit Central-1 Bhopal Bhopal बनाम/ Vs. (Appellant / Assessee) (Respondent /Revenue) Pan: Aaccd 6124 B Assessee By Shri Hitesh Chimnani & Shri Yash Kukreja, Ld. Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 18.10.2022 Date Of Pronouncement 20.10.2022

Section 143(2)Section 143(3)Section 32(1)(iia)Section 32A

…n cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

THED CIT ,CENTRAL-1, BHOPAL vs. M/S DILIP BUILDCON LTD, BHOPAL

In the result, revenue’s appeal for A

ITA 290/IND/2020[2017-18]Status: DisposedITAT Indore27 Jan 2022AY 2017-18

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

SHRI DILIP BUILDCON LTD,BHOPAL vs. DCIT CENTRAL -1, BHOPAL

In the result, revenue’s appeal for A

ITA 197/IND/2020[2017-18]Status: DisposedITAT Indore27 Jan 2022AY 2017-18

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

ITA 882/IND/2019[2016-17]Status: DisposedITAT Indore27 Jan 2022AY 2016-17

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

ITA 881/IND/2019[2015-16]Status: DisposedITAT Indore27 Jan 2022AY 2015-16

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 820/IND/2019[2016-17]Status: DisposedITAT Indore27 Jan 2022AY 2016-17

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 819/IND/2019[2015-16]Status: DisposedITAT Indore27 Jan 2022AY 2015-16

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LIMITED, BHOPAL

In the result, revenue’s appeal for A

ITA 816/IND/2018[14-15]Status: DisposedITAT Indore27 Jan 2022

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

DILIP BUILDCON LIMITED,BHOPAL vs. DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 782/IND/2018[2014-15]Status: DisposedITAT Indore27 Jan 2022AY 2014-15

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

…cannot be relied. (The copy of the decision is placed at page nos. 42-47 of the paper book). The relevant portion of the order is reproduced hereunder:- “10. Mr Kawoosa had cited the decision of the Supreme Court in CIT v. Gem India Manufacturing Co. [2001] 249 ITR 307/117 Taxman 368, which was a case where cutting and polishing of diamonds was held as not amounting to manufacture for the purposes of deduction under Section 80-I of the Income Tax Act, 1961. However, the facts of that case are different from the facts of the present case and from the processes employed in the present case. Moreover the definitio…

ADDL.CIT, SPECIAL RANGE- 4 , NEW DELHI vs. INDRAPRASTHA GAS LTD., NEW DELHI

The appeal of the assessee is hereby allowed

ITA 6714/DEL/2018[2011-12]Status: DisposedITAT Delhi19 Mar 2021AY 2011-12

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6714/Del/2018 : Asstt. Year : 2011-12 Ita No. 6715/Del/2018 : Asstt. Year : 2012-13 Addl. Cit, Vs Indraprastha Gas Ltd., Special Range-4, Plot No. 4, Igl Bhawan, Sector-9, New Delhi R.K. Puram, New Delhi-110022 (Appellant) (Respondent) Pan No. Aaaci5076R Assessee By : Sh. Rajat Jain, Ca Revenue By : Ms. Sunita Singh, Cit Dr Date Of Hearing: 01.03.2021 Date Of Pronouncement: 19.03.2021

For Appellant: Sh. Rajat Jain, CAFor Respondent: Ms. Sunita Singh, CIT DR
Section 147Section 32Section 32(1)(iia)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI Before Sh. Bhavnesh Saini, Judicial Member Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 6714/Del/2018 : Asstt. Year : 2011-12 ITA No. 6715/Del/2018 : Asstt. Year : 2012-13 Addl. CIT, Vs Indraprastha Gas Ltd., Special Range-4, Plot No. 4, IGL Bhawan, Sector-9, New Delhi R.K. Puram, New Delhi-110022 (APPELLANT) (RESPONDENT) PAN No. AAACI5076R Assessee by : Sh. Rajat Jain, CA Revenue by : Ms. Sunita Singh, CIT DR Date of Hearing: 01.03.2021 Date of Pronouncement: 19.03.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Memb…

INDRAPRASTHA GAS LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 4 , NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 6489/DEL/2017[2013-14]Status: DisposedITAT Delhi05 Jan 2021AY 2013-14

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6489/Del/2017 : Asstt. Year : 2013-14 Indraprastha Gas Ltd., Vs Addl. Cit, Plot No. 4, Igl Bhawan, Special Range-4, Sector-9, R.K. Puram, New Delhi New Delhi-110022 (Appellant) (Respondent) Pan No. Aaaci5076R Assessee By : Sh. Rajat Jain, Ca Revenue By : Sh. Gaurav Dudeja, Sr. Dr Date Of Hearing: 09.11.2020 Date Of Pronouncement: 05.01.2021

For Appellant: Sh. Rajat Jain, CAFor Respondent: Sh. Gaurav Dudeja, Sr. DR
Section 271(1)(c)Section 32Section 32(1)(iia)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI Before Sh. Amit Shukla, Judicial Member Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 6489/Del/2017 : Asstt. Year : 2013-14 Indraprastha Gas Ltd., Vs Addl. CIT, Plot No. 4, IGL Bhawan, Special Range-4, Sector-9, R.K. Puram, New Delhi New Delhi-110022 (APPELLANT) (RESPONDENT) PAN No. AAACI5076R Assessee by : Sh. Rajat Jain, CA Revenue by : Sh. Gaurav Dudeja, Sr. DR Date of Hearing: 09.11.2020 Date of Pronouncement: 05.01.2021 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the ass…

VEDANTA LTD ,GURGAON vs. ACIT, CIRCLE- 26(2), NEW DELHI

ITA 12/DEL/2020[2014-15]Status: FixedITAT Delhi18 Sept 2020AY 2014-15

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2014-15]

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 143(3)Section 153

…g officer was of the opinion that the process of extraction of mining iron ore and processing the same do not constitute ‘manufacture’ or ‘production’. 49. Referring to the decision of the Hon'ble Supreme Court in the case of Gem India Manufacturing Company 249 ITR 307 wherein the Hon'ble Supreme Court has held that raw and un-cut diamonds is subjected to a process of cutting and polishing which yields the polished diamond but that is not to say that polished diamond is a new article or thing which is the result of manufacture or production. Further, referring to the decision of the Hon'ble Supreme Court in t…

M/S BHOLE BABA MILK FOOD INDUSTRIES DHOLPUR,AGRA vs. J.C.I.T., RANGE -4, AGRA

In the result appeal is dismissed

ITA 242/AGR/2014[2010-11]Status: DisposedITAT Agra11 Sept 2019AY 2010-11

Bench: Shri Laliet Kumar,And Dr. Mitha Lal Meena

Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH: AGRA BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER,AND DR. MITHA LAL MEENA, ACCOUNTANT MEMBER I.T.A No.242/Agra/2014 (ASSESSMENT YEAR: 2010-11) M/s Bhole Baba Milk Food Vs. JCIT, Range-4, Industries, Dholpur P. Ltd. Agra. Nagla Jawahar, Agra. PAN: AACCB7111J (Appellant) (Respondent) Appellant by Shri Rajendra Sharma, Adv. Respondent by Shri Waseem Arshad, Sr. DR. Date of Hearing 19.07.2019 Date of 11.09.2019 Pronouncement ORDER Per Dr. M.L. Meena, A.M.: This appeal by the assessee is directed against the order of the ld. Commissioner of Income Tax(A)-II, Agra…

ACIT 19(2), MUMBAI vs. K.P. SANGHAVI & SONS, MUMBAI

In the result, both appeal of the Revenue and Cross Objection of the assessee are dismissed

ITA 2455/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Sept 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Blea.C.I.T Circle – 19(2) V. M/S. K.P. Sanghvi & Sons Llp Room No. 207, {Formerly Known As M/S. K.P. Sanghvi & Sons} Gw-7011/7012, Mathru Mandir, Bharat Diamond Bourse, Mumbai – 400 007 Bandra Kurla Complex, Bandra (E), Mumbai – 400 051 Pan: Aaafk 8390 F (Appellant) (Respondent) Co No.237/Mum/2018 (A.Y: 2011-12) [Arising Out Of Ita No.2455/Mum/2017] M/S. K.P. Sanghvi & Sons Llp V. A.C.I.T Circle – 19(2) {Formerly Known As M/S. K.P. Sanghvi & Sons} Room No. 207, 2Nd Floor Gw-7011/7012, Mathru Mandir, Tardeo Bharat Diamond Bourse, Road, Mumbai – 400 007 Bandra Kurla Complex, Bandra (E), Mumbai – 400 051 Pan: Aaafk 8390 F (Appellant) (Respondent) Assessee By : Shri Aditya R. Ajgaonkar Department By : Shri Manoj Kumar Singh

For Appellant: Shri Aditya R. AjgaonkarFor Respondent: Shri Manoj Kumar Singh

…s erred in allowing the additional depreciation claimed of ₹.23,21,714/-. 4. Whether on facts and circumstances of the case, the Ld.CIT(A) erred in not appreciating the fact that Hon'ble Supreme Court in the case of CIT Vs. Gem India Manufacturing Co. (2001) 249 ITR 307 (Supreme Court) & Hon'ble High Court of Bombay in the case of London star Diamond Co (L) Ltd., 213 ITR 517 (BOM) had held that the diamond cutting & polishing amounts to processing of goods and not manufacturing of goods and decision relied upon in the case of M/s. Sheetal manufactures has not been accepted on merits.” 7. We have heard the rival…

ACIT 19(2), MUMBAI vs. K.P. SANGHVI & SONS, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 361/MUM/2016[2010-11]Status: DisposedITAT Mumbai13 Feb 2018AY 2010-11

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm Acit 19(2) Vs. M/S. K.P. Sanghvi & Sons R.No.L-207, 1301, Prasad Chambers Matru Mandir Mamam Parmanand Marg Mumbai – 400 007 Opera House, Mumbai – 400 004 Pan/Gir No. Aaafk8390F Appellant) .. Respondent)

Section 143(3)Section 32(1)Section 32(1)(iia)Section 80

…CIT(A) has erred in allowing the additional depreciation of RS.29,38,884/- 4. Whether on facts and circumstances .of the case, the Ld.CIT(A) erred in not appreciating the fact that Hon'ble Supreme Court in the case of CIT Vs. Gem India Manufacturing Co.(2001) 249 ITR 307 (SC) & Hon'ble High Court of Bombay in the case of London Star Diamond Co(I)Ltd.213 ITR 517 (Bom) had held that the diamond cutting & polishing amounts to processing of goods and not manufacturing of goods and decision relied upon in the case of M/s Sheetal Manufactures has not been accepted on merits. 10. We have heard the rival contentions of…

ASST CIT 19(1), MUMBAI vs. BHAWANI GEMS, MUMBAI

In the result, appeal of Revenue is dismissed

ITA 4496/MUM/2015[2012-13]Status: DisposedITAT Mumbai20 Sept 2017AY 2012-13

Bench: Shri G.S. Pannu (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2012-13 The Acit- 19(1), M/S Bhavani Gems, 2Nd Floor, Matru Mandir, Bw 8012 & 8013, Tardeo Road, Bharat Diamond Bourse, Mumbai - 400007 Vs. Bandra Kurla Complex, Bandra (E), Mumbai - 400051 Pan: Aaafb2302G (Appellant) (Respondent)

For Appellant: Shri Reepal G. Traishawala (AR)For Respondent: Shri Suman Kumar (DR)
Section 143Section 32(1)(iia)

…depreciation. The AO after hearing the contention of the assessee disallowed the claim and added back the amount top the income of the assessee on the ground that as per the law laid down by the Hon’ble Supreme Court in CIT vs. Gem India Manufacturing Co Ltd.249 ITR 307 that cutting and polishing of diamonds cannot be called manufacturing or production of goods. In the first appeal the Ld. CIT(A) deleted the addition following the orders passed by the then CIT(A) in assessee’s own case for the assessment years 2009-10,2010-11 and 2011-12. 3. Aggrieved by the order of Ld. CIT (Appeals), the revenue has preferred…

BISWAJIT DAS,BHUBANESWAR vs. ITO, WARD-1(1), BHUBANESWAR, BHUBANESWAR

In the result, the appeal filed by the revenue is dismissed and the

ITA 493/CTK/2014[2010-11]Status: DisposedITAT Cuttack28 Feb 2017AY 2010-11

Bench: Shri N.S Saini & Shri Aby T. Varkeyassessment Year :2010-2011

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri D.K.Pradhan, DR
Section 10Section 10BSection 2

…t and lastly of any other High Court." 45.7 We noted that the coordinate Bench in the case of Chowgule & Co. Ltd. ITA No. 162/PNJ/2006 decided the issue only on the basis of the decision of the Supreme Court in the case of CIT Vs. Gem India Manufacturing Co. 249 ITR 307, while the said decision has not been followed by the Supreme Court in their subsequent decisions. Even the case relate to A. Y. 2002-03. No contrary decision subsequent to the decision of the Special Bench, Kerala High Court and that of the Supreme Court rendered in the case of India Cine Agency (supra) as well as Arihant Tiles & Marbles (Supra)…

ITO, WARD-2(2), BHUBANESWAR, BHUBANESWAR vs. BISWAJIT DAS, BHUBANESWAR

In the result, the appeal filed by the revenue is dismissed and the

ITA 473/CTK/2014[2010-11]Status: DisposedITAT Cuttack28 Feb 2017AY 2010-11

Bench: Shri N.S Saini & Shri Aby T. Varkeyassessment Year :2010-2011

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri D.K.Pradhan, DR
Section 10Section 10BSection 2

…t and lastly of any other High Court." 45.7 We noted that the coordinate Bench in the case of Chowgule & Co. Ltd. ITA No. 162/PNJ/2006 decided the issue only on the basis of the decision of the Supreme Court in the case of CIT Vs. Gem India Manufacturing Co. 249 ITR 307, while the said decision has not been followed by the Supreme Court in their subsequent decisions. Even the case relate to A. Y. 2002-03. No contrary decision subsequent to the decision of the Special Bench, Kerala High Court and that of the Supreme Court rendered in the case of India Cine Agency (supra) as well as Arihant Tiles & Marbles (Supra)…

Showing 1–20 of 25 · Page 1 of 2