CIT v. H.H. Maharani Vijaykuverba Saheb of Morvi

100 ITR 67High Court1975#4268 most cited

What is CIT v. H.H. Maharani Vijaykuverba Saheb of Morvi authority for?

The connection between an expenditure and the earning of income need not be direct; an indirect connection can establish the nexus between the expenditure incurred and the income earned for the purpose of Section 57(iii).

27

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. H.H. Maharani Vijaykuverba Saheb of Morvi · section 57 · section 57(iii) · proximate nexus · indirect connection · earning of income · expenditure · disallowance of expenditure · deduction

Sections most often in play

Section 57Section 144Section 147Section 143(3)Section 268ASection 234BSection 234DSection 251

Issues it is cited on

section 57(iii)proximate nexusright to receivesection 268asection 57audi alteram partemsection 234dsection 254section 220(2)section 220disallowance of interest expenditurerule of consistency

Judgments citing CIT v. H.H. Maharani Vijaykuverba Saheb of Morvi

Dy Commissioner of Income Tax, Mumbai vs. Hitesh Shantilal Mehta, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 7865/MUM/2025[2005-06]Status: DisposedITAT Mumbai09 Feb 2026AY 2005-06

Bench: adverting to the merits, it is necessary to record that Ground No. 1 raised in the cross-objection was expressly stated to be not pressed by the learned counsel for the assessee at the time of hearing. Accordingly, Ground No. 1 of the cross-objection is dismissed as not pressed. The adjudication hereinafter is, therefore, confined exclusively to Ground No. 2 of the cross- objection, which pertains to the allowability of interest expenditure under section 57 of the Act. 4. Briefly stated, th

Section 143(3)Section 57

…he dividend income is not sufficient. 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CFT, (1977) 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi (1975) 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT u/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, Le wherein th…

Dy Commissioner of Income Tax, Mumbai vs. Hitesh Shantilal Mehta, Mumbai

In the result, the cross-objections filed by the assessee are allowed

ITA 7798/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 144Section 147Section 268ASection 57

…rred is in some manner or sufficient. 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CFT, (1977) 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi (1975) 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT u/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, Le wherein th…

Dy Commissioner of Income Tax, Mumbai vs. Hitesh Shantilal Mehta, Mumbai

In the result, the cross-objections filed by the assessee are allowed

ITA 7797/MUM/2025[2004-05]Status: DisposedITAT Mumbai09 Feb 2026AY 2004-05

Bench: the Tribunal, as stipulated under CBDT Circular No.09/2024 dated 17.09.2024. It was also not the case of the Revenue that the present appeals fall within any of the exceptions carved out in the said Circular. In view of this admitted position and having regard to the binding nature of the Circular, which expressly applies even to pending appeals, the maintainability of the Revenue's appeals stands squarely governed by the said Circular. 3

Section 143(3)Section 144Section 147Section 268ASection 57

…rred is in some manner or sufficient. 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CFT, (1977) 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi (1975) 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT u/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, Le wherein th…

Dy Commissioner of Income Tax, Mumbai vs. Hitesh Shantilal Mehta, Mumbai

In the result, the cross-objections filed by the assessee are allowed

ITA 7796/MUM/2025[2000-01]Status: DisposedITAT Mumbai09 Feb 2026AY 2000-01

Bench: the Tribunal, as stipulated under CBDT Circular No.09/2024 dated 17.09.2024. It was also not the case of the Revenue that the present appeals fall within any of the exceptions carved out in the said Circular. In view of this admitted position and having regard to the binding nature of the Circular, which expressly applies even to pending appeals, the maintainability of the Revenue's appeals stands squarely governed by the said Circular. 3

Section 143(3)Section 144Section 147Section 268ASection 57

…rred is in some manner or sufficient. 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CFT, (1977) 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi (1975) 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT u/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, Le wherein th…

Dy. Commissioner of Income Tax, Mumbai vs. Pratima Hitesh Mehta, Mumbai

In the result, grounds of appeal raised by revenue in A

ITA 5453/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Nov 2025AY 2009-10

Bench: Shri Pawan Singh& Smt. Renu Jauhri

Section 254(1)Section 57

…he dividend Income is not sufficient." 31. We find that the Hon'ble Supreme Court In Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani VijaykuverbaSaheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, l.e. wherein…

Dy. Commissioner of Income Tax, Kautilya Bhawan vs. Pratima Hitesh Mehta, Mumbai

In the result, grounds of appeal raised by revenue in A

ITA 5452/MUM/2025[2008-09]Status: DisposedITAT Mumbai11 Nov 2025AY 2008-09

Bench: Shri Pawan Singh& Smt. Renu Jauhri

Section 254(1)Section 57

…he dividend Income is not sufficient." 31. We find that the Hon'ble Supreme Court In Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani VijaykuverbaSaheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, l.e. wherein…

Dy. Commissioner of Income Tax, Kautilya Bhawan vs. Pratima Hitesh Mehta, Mumbai

In the result, grounds of appeal raised by revenue in A

ITA 5449/MUM/2025[1999-00]Status: DisposedITAT Mumbai11 Nov 2025AY 1999-00

Bench: Shri Pawan Singh& Smt. Renu Jauhri

Section 254(1)Section 57

…he dividend Income is not sufficient." 31. We find that the Hon'ble Supreme Court In Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani VijaykuverbaSaheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, l.e. wherein…

Pratima Hitesh Mehta, Mumbai vs. DCIT, CC -4(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 232/MUM/2025[1992-1993]Status: DisposedITAT Mumbai17 Oct 2025AY 1992-1993

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 1992-1993 Pratima Hitesh Mehta Vs Deputy Commissioner Of 32, Madhuli Apartment, Income-Tax, Cc -4(1), 3Rd Floor, Dr. A.B Road, Worli, Mumbai Mumbai - 400018 [Pan: Abnpm8226G] Appellant Respondent Present For: Appellant By : Shri Dharmesh Shah & Ms. Mitali Parekh, Advocates Respondent By : Dr. P. Daniel (Special Counsel For Dept.) Date Of Hearing : 29.07.2025 Date Of Pronouncement : 17.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A)-52, Mumbai, Vide Order No. Itba/Apl/S/250/2024-25/1070774879(1), Dated 29.11.2025 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax, Cc-4(1), Mumbai, U/S. 144 R.W.S. 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 19.07.2024 For Assessment Year 1992-93. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A) Has Erred In Law & In Fact In Partly Confirming The Assessment Order Passed U/S. 144 R.W.S. 254 Of The Act Dated 19.07.2024. 2. The Ld. Cit(A) Has Erred In Law & In Fact In Not Quashing The Assessment Order Which Is Time Barred & Hence Void.

For Appellant: Shri Dharmesh Shah and Ms. Mitali Parekh, AdvocatesFor Respondent: Dr. P. Daniel (Special Counsel for Dept.)
Section 132Section 132(4)Section 144Section 220Section 234D

…e dividend Income is not sufficient." 31. We find that the Hon'ble Supreme Court In Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, l.e. wherein…

Growmore Leasing & Investment Ltd, Mumbai vs. DCIT, CC-4(1) (Erstwhile DCIT-31, Mumbai

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

ITA 660/MUM/2023[1993-94]Status: DisposedITAT Mumbai17 Mar 2025AY 1993-94

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Dharmesh Shah, A/RFor Respondent: Shri Dr. P. Daniel, Spl. Counsel
Section 144

…Mum/2023 Assessment Year: 1993-94 13 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Growmore Leasing and Investments Ltd, Mumbai vs. DCIT, CC-4(1) (Erstwhile DCIT-31, Mumbai

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

ITA 452/MUM/2023[1993-94]Status: DisposedITAT Mumbai17 Mar 2025AY 1993-94

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Dharmesh Shah, A/RFor Respondent: Shri Dr. P. Daniel, Spl. Counsel
Section 144

…Mum/2023 Assessment Year: 1993-94 13 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Sudhir S. Mehta, Mumbai vs. DCIT, CC-4(1) (Erstwhile DCIT, CC -31), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 451/MUM/2023[1993-94]Status: DisposedITAT Mumbai12 Mar 2025AY 1993-94

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Vijay Mehta, A/RFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 234A

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s Η.Η. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Rasila S. Mehta, Mumbai vs. DCIT, CC-4(1), (Erstwhile ACIT, CC-23), Mumbai

In the result, appeals of the assessee are partly allowed and that

ITA 462/MUM/2023[1993-94]Status: DisposedITAT Mumbai19 Feb 2025AY 1993-94

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Ms. Mitali Parekh, A/RsFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 144Section 220(2)

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s Η.Η. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL I.T.A. No. 380/Mum/2023 I.T.A. No. 1181/Mum/2023 I.T.A. No. 462/Mum/2023 I.T.A. No. 118…

Rasila S. Mehta, Mumbai vs. ACIT, CC-4(1), Mumbai

In the result, appeals of the assessee are partly allowed and that

ITA 380/MUM/2023[1992-93]Status: DisposedITAT Mumbai19 Feb 2025AY 1992-93

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Ms. Mitali Parekh, A/RsFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 144Section 220(2)

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Dy Commissioner of Income Tax, Cen.Circle-4(1), Mumbai vs. Smt. Rasila S. Mehta, Mumbai

In the result, appeals of the assessee are partly allowed and that

ITA 1182/MUM/2023[1993-94]Status: DisposedITAT Mumbai19 Feb 2025AY 1993-94

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Dharmesh Shah & Ms. Mitali Parekh, A/RsFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 144Section 220(2)

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Sudhir S. Mehta, Mumbai vs. DCIT, CC-4(1), Mumbai

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

ITA 417/MUM/2023[1992-93]Status: DisposedITAT Mumbai06 Feb 2025AY 1992-93

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Vijay Mehta & Shri Dharmesh Shah, A/RsFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 132(4)Section 143(3)Section 144Section 220(2)Section 234ASection 271(1)(c)

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Dy Commissioner of Income Tax, Cen.Circle-4(1), Mumbai vs. Shri Sudhir Shantilal Mehta, Mumbai

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

ITA 1179/MUM/2023[1992-93]Status: DisposedITAT Mumbai06 Feb 2025AY 1992-93

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Vijay Mehta & Shri Dharmesh Shah, A/RsFor Respondent: Shri Dr. P. Daniel – Spl. Counsel
Section 132(4)Section 143(3)Section 144Section 234ASection 271(1)(c)

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Growmore Research and Assets Management, Mumbai vs. DCIT, CC-4(1) (Erstwhile DCIT-31, Mumbai

In the result, both the appeals are treated as partly allowed

ITA 453/MUM/2023[1992-93]Status: DisposedITAT Mumbai21 Jan 2025AY 1992-93

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Vijay Mehta and ShriDharmeshFor Respondent: Dr.P. Daniel – Spl. Counsel
Section 144

…ordinate bench is extracted below:- “31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Lanxes India P.Ltd, Thane vs. Asst CIT Cir 1, Thane

In the result, both the appeals are treated as partly allowed

ITA 1125/MUM/2017[2012-13]Status: DisposedITAT Mumbai01 Jan 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Vijay Mehta and ShriDharmeshFor Respondent: Dr.P. Daniel – Spl. Counsel
Section 144

…ordinate bench is extracted below:- “31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Deepika A. Mehta, Mumbi vs. DCIT, CC-4(1), Mumbai

In the result appeal of Department is dismissed

ITA 379/MUM/2023[1992-93]Status: DisposedITAT Mumbai05 Apr 2024AY 1992-93

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआ.अ.सं.379/मुं/2023 (नि.व. 1992-93) Ιτα No.379/Mum/2023 (A.Y.1992-93) Smt. Deepika A Mehta 32, Madhuli, Dr. A.B. Road, Worli, Mumbai – 400 018 Pan: Abnpm8231D अपीलार्थी / Appellant बनाम Vs. The Dy.Commissioner Of Income Tax, Cen.Circle-4(1), Mumbai-400 021 प्रतिवादी/Respondent आ.अ.सं. 1178/मुं/2023 (नि.व. 1992-93)

For Appellant: Shri Dharmesh Shah & Ms. Mitali GopaniFor Respondent: Dr. P. Daniel (Special Counsel)
Section 144Section 145Section 234ASection 234DSection 44ASection 69

…e dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…

Dy Commissioner of Income Tax, Cen-Circle-4(1), Mumbai vs. Smt. Deepika A. Mehta, Mumbai

In the result appeal of Department is dismissed

ITA 1178/MUM/2023[1992-93]Status: DisposedITAT Mumbai05 Apr 2024AY 1992-93

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआ.अ.सं.379/मुं/2023 (िन.व. 1992-93) Smt. Deepika A Mehta 32, Madhuli, Dr. A.B. Road, Worli, Mumbai – 400 018 ...... अपीलाथ" /Appellant Pan: Abnpm8231D बनाम Vs.

For Appellant: Shri Dharmesh Shah & Ms. Mitali GopaniFor Respondent: Dr. P. Daniel (Special Counsel)
Section 144Section 145Section 234ASection 234DSection 44ASection 69

…dividend income is not sufficient." 31. We find that the Hon'ble Supreme Court in Seth R. Dalmia v/s CIT, [1977] 110 ITR 644 (SC) agreed with the view taken by the Hon'ble jurisdictional High Court in CIT v/s H.H. Maharani Vijaykuverba Saheb of Morvi [1975] 100 ITR 67 (Bom), wherein it was held that the connection between the expenditure and the earning of income need not be direct, and even an indirect connection could prove the nexus between the expenditure incurred and the income. We further find that in CIT v/s Smt. Sushila Devi Khadaria, [2009] 319 ITR 413 (Bom.), in a similar factual matrix, i.e. wherein…