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

Smt. Jyoti H Mehta, Mumbai vs. ACIT, CC-4(1), Mumbai

ITA 436/MUM/2023[1993-94]Status: DisposedITAT Mumbai27 Oct 2023AY 1993-94

Bench: Shri Amit Shukla & Shri Gagan Goyaljyoti H. Mehta 32, Madhuli Apartment, 3Rd Floor, Dr. A. B. Road, Worli, Mumbai-400 018 Pan: Abnpm8233B ..... Appellant Vs. Acit Circle 4(1) R. No. 1916, 19Th Floor, Air India Building, Nariman Point, Mumbai-400021 Mumbai ..... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: Dr. P. Daniel, Spl. Counsel
Section 234ASection 250Section 57

…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…

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

In the result, the present cross-appeals are partly allowed for statistical purposes

ITA 416/MUM/2023[1992-93]Status: DisposedITAT Mumbai26 Oct 2023AY 1992-93

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Dharmesh Shah a/wFor Respondent: Dr. P. Daniel
Section 133(6)Section 142(1)Section 144Section 145(2)Section 250Section 254

…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, Cent -Circle-4(1), Mumbai vs. Smt Pratima H. Mehta, Mumbai

In the result, the present cross-appeals are partly allowed for statistical purposes

ITA 1180/MUM/2023[1992-93]Status: DisposedITAT Mumbai26 Oct 2023AY 1992-93

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Dharmesh Shah a/wFor Respondent: Dr. P. Daniel
Section 133(6)Section 142(1)Section 144Section 145(2)Section 250Section 254

…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…

M/S Best Trading & Agencies Ltd vs. The Deputy Commissioner of Income Tax

In the result, the orders passed by the

ITA/32/2012HC Karnataka26 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 115JSection 260Section 260A

…ch expenses are expressly disallowed by the Act. In SETH M DALMIA supra, the Supreme Court referred to with approval the decision of the Bombay High Court in ‘COMMISSIONER OF INCOME TAX VS. H.H.MAHARANI VIJAYKUVERBA SAHEB OF MORVI’, (1975) 100 ITR 67, wherein the Bombay High Court while dealing with Section 12(2) of the Act, held that deduction permissible under the aforesaid provision is an expenditure incurred solely for the purpose of making or earning the income, which has been subjected to tax and dominant 17 purpose of expenditure incurred must be to earn income. It was…

M/S Best Trading & Agencies Ltd vs. The Deputy Commissioner of Income Tax

In the result, the orders passed by the

ITA/191/2011HC Karnataka26 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 115JSection 260Section 260A

…ch expenses are expressly disallowed by the Act. In SETH M DALMIA supra, the Supreme Court referred to with approval the decision of the Bombay High Court in ‘COMMISSIONER OF INCOME TAX VS. H.H.MAHARANI VIJAYKUVERBA SAHEB OF MORVI’, (1975) 100 ITR 67, wherein the Bombay High Court while dealing with Section 12(2) of the Act, held that deduction permissible under the aforesaid provision is an expenditure incurred solely for the purpose of making or earning the income, which has been subjected to tax and dominant 17 purpose of expenditure incurred must be to earn income. It was…

The Commissoner of Income Tax I vs. M/s. Alpha Thought Technologies P Ltd

ITTA/191/2011HC Telangana21 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Jiten P. Mathuria, Mumbai vs. ACIT 25(3), Mumbai

In the result appeal of the assessee is allowed

ITA 327/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Jan 2016AY 2009-10

Bench: Shri Amit Shukla & Shri Rajesh Kumarassessment Year: - 2009-10 Shri Jiten P. Mathuria Vs.` Acit – 25(3), Mumbai, 1702-4, Panchaseel Heights, C-11, 3Rd Floor, Mahavir Nagar, Bandra Kurla Complex, Kandivali (W) Bandra (East) Mumbai – 400 067. Mumbai – 400 051. Pan/Gir No. Aobps7066K Appellant Respondent

Section 143(3)Section 57

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH ‘J’ MUMBAI. BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER Assessment year: - 2009-10 Shri Jiten P. Mathuria Vs.` ACIT – 25(3), Mumbai, 1702-4, Panchaseel Heights, C-11, 3rd Floor, Mahavir Nagar, Bandra Kurla Complex, Kandivali (W) Bandra (East) Mumbai – 400 067. Mumbai – 400 051. PAN/GIR No. AOBPS7066K Appellant Respondent Assessed By Shri Biren Gabhawala Revenue By Shri Naveen Gupta Date of hearing 01.09.2015 Date of pronouncement 06.01.2016 ORDER Per Rajesh Kumar, AM This appeal by the assessee is directed against the o…

CIT v. H.H. Maharani Vijaykuverba Saheb of Morvi (100 ITR 67) — Cited in 27 Judgments | BharatTax