CIT v. Havells India Ltd.

352 ITR 376High Court2013#1171 most cited

What is CIT v. Havells India Ltd. authority for?

For royalty income, especially in the context of Double Taxation Avoidance Agreements (DTAA), the 'source of income' is the determinative factor for taxability, rather than merely the 'source of receipt'.

97

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Havells India Ltd. · Havells India · Section 9(1)(vii) · Section 9(1)(vii)(b) · royalty income · source of income · DTAA · Double Taxation Avoidance Agreement · taxability of royalty · deemed to accrue or arise in India

Also reported as

21 Taxmann.com 476208 Taxmann 114

Sections most often in play

Section 1961Section 9(1)(vii)Section 234BSection 9(1)(vii)(b)Section 144C(13)Section 10AASection 14ASection 234A
Read the full judgment

Issues it is cited on

section 50(1)section 80absection 54esection 70(2)section 10(15)section 80msection 10(33)section 14a(1)section 54ecsection 9(1)(vii)(b)long-term capital assetsection 80ie

Judgments citing CIT v. Havells India Ltd.

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

ITA 1480/HYD/2025[2011-12]Status: DisposedITAT Hyderabad27 Mar 2026AY 2011-12
Section 139Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250

…., (2008) 304 ITR 67 (Mad.) 6. CIT vs. Secure Meters Ltd., 321 ITR 611 7. CIT vs. ITC Hotels Ltd., 334 ITR 109 8. M/s. Crane Software International Ltd. vs. DCIT, Bangalore Order dated 08.02.2011 in ITA.Nos. 741 & 742/Bang/2010. 9. CIT vs. Havells India Ltd., 352 ITR 376 10. DCIT vs. UAG Builders (P) Ltd., Delhi (2012) 25 taxmann.com 205 (Del.) 3.1. Further he has also relied upon the CBDT circular No.56 dated 19th March, 1971 on the provisions of section 35Dwherein it was clarified that the provisions of section 35D will not have the effect of bringing the expenditure covered by the decision of the Hon'ble Supre…

SUPERHOUSE LIMITED,KANPUR vs. CIT, INTERNATIONAL TAXATION-3, DELHI, DELHI

In the result, both appeals of the assessee are allowed

ITA 356/LKW/2024[2014-15]Status: DisposedITAT Lucknow25 Feb 2026AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos. 356 & 357/Lkw/2024 A.Ys. 2014-15 & A.Ys. 2015-16 Superhouse Limited, 150 Feet Vs. The Commissioner Of Income Tax Road, Jajmau, Kanpur-208010 International Taxation-3, Delhi Pan: Aabcs9328K (Appellant) (Respondent) Assessee By: Sh. G.C. Srivastava, Adv & Sh. Kalrav Mehrotra, Adv Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 03.12.2025 Date Of Pronouncement: 25.02.2026 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed By The Assessee Against The Orders Of The Cit, (International Taxation)-3, Delhi Passed Under Section 263 Of The Act For The A.Ys. 2014-15 & 2015-16, Both Dated 29.03.2024, Wherein The Ld. Cit Has Set Aside The Earlier Orders Of The Assessing Officer For Making Of Fresh Orders In Accordance With The Directions Issued By Her. The Grounds Of Appeal Are As Under:- “1. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming Jurisdiction Under Section 263 Of The Act & In Doing So, Has Sought To Substitute His Opinion With The Order Under Section 201(1)/201(1A) Passed After Undertaking Extensive & Detailed Consideration Of The Issue By The Ito (Tds). 2. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming The Jurisdiction Under Section 263 Of The Act Without Appreciating That The Order Under Section 201(1)/201(1A) Passed By The Ito (Tds) Was Unerring & In Consonance With The Settled Principles Of Law. 3. Because, On The Facts & Circumstances Of The Case & In Law, The Impugned Order While Premised On An Illegal Assumption Of Jurisdiction, Further Suffers From Non-Application Of Mind Since The Submissions Of The Assessee Have Not Been Considered [As Illustrated Infra]. A.Ys. 2014-15 & 2015-16

For Appellant: Sh. G.C. Srivastava, Adv & Sh. KalravFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 201(1)Section 263Section 90

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘A’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER ITA Nos. 356 & 357/LKW/2024 A.Ys. 2014-15 & A.Ys. 2015-16 Superhouse Limited, 150 Feet vs. The Commissioner of Income Tax Road, Jajmau, Kanpur-208010 International Taxation-3, Delhi PAN: AABCS9328K (Appellant) (Respondent) Assessee by: Sh. G.C. Srivastava, Adv & Sh. Kalrav Mehrotra, Adv Revenue by: Sh. R.K. Agarwal, CIT DR Date of hearing: 03.12.2025 Date of pronouncement: 25.02.2026 O R D E R PER NIKHIL CHOUDHARY, A.M.: These two appeals have been file…

YOUCLOUD DMCC,DUBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, GURUGRAM

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1220/DEL/2024[2018-2019]Status: DisposedITAT Delhi06 Feb 2026AY 2018-2019

Bench: Shri Ramit Kochar & Shri Raj Kumar Chauhan

Section 143(2)Section 144C(1)Section 144C(5)Section 147Section 148Section 148(1)(d)Section 201(1)

…ITA No.1220/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : D : NEW DELHI BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER ITA No.1220/Del/2024 Assessment Year: 2018-19 Youcloud DMCC, Unit 1501, 15th Floor, Fortune Executive Tower, Cluster T Jumeirah Lake Tower, Dubai, UAE. PAN: AABCY5529Q (Appellant) V. DCIT, International Taxation, 3rd Floor, Vanijya Nikunj, HSIIDC Building, Udyog Vihar, Phase V, Gurgaon-122001, Haryana. (Respondent) Assessee by Revenue by Date of Hearing Date of Pronouncement : Shri Naman Maloo, CA (through VC) : Shri M.S. Nethrapal, CIT,…

WESTCOURT HOSPITALITY PVT LTD,NEW DELHI vs. DCIT, CIRCLE-25(1), DELHI

In the result appeal of the assessee is allowed

ITA 3351/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…and disallowed the expenses which are not applicable to the facts of the present case as the assessee has issued CCD. Ld. AR submits that ld. CIT(A) has relied upon the judgement of hon’ble Delhi High Court in the case of CIT Vs. Havels India Ltd. reported in 352 ITR 376 (Delhi) which is squarely applicable to the present case and therefore he prayed for the confirmation of the order of ld. CIT(A) in this regard. 10. Heard the contentions of both the parties and perused the material available on record. It is seen that assessee has claimed only Rs. 1,200/- on the increase in share capital and remaining amount IT…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-25(1), NEW DELHI, NEW DELHI vs. WESTCOURT HOSPITALITY PRIVATE LIMITED, NEW DELHI

In the result appeal of the assessee is allowed

ITA 3294/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…and disallowed the expenses which are not applicable to the facts of the present case as the assessee has issued CCD. Ld. AR submits that ld. CIT(A) has relied upon the judgement of hon’ble Delhi High Court in the case of CIT Vs. Havels India Ltd. reported in 352 ITR 376 (Delhi) which is squarely applicable to the present case and therefore he prayed for the confirmation of the order of ld. CIT(A) in this regard. 10. Heard the contentions of both the parties and perused the material available on record. It is seen that assessee has claimed only Rs. 1,200/- on the increase in share capital and remaining amount IT…

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), NEW DELHI

In the result, the appeal of the assessee for AY 2022-23 is allowed for 14

ITA 2087/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Dec 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 115ASection 143(3)Section 144C(5)Section 153Section 234BSection 270ASection 9

…AT order dated 29.08.2024 reported in 167 taxmann.com 405 f) For AY 2021-22 - ITAT order dated 14.11.2024 in ITA No. 3742/Del/2023 The ld DR before us relied on the decision of the Hon'ble Delhi High Court 6. in the case of CIT Vs. Havells India reported in 352 ITR 376 (Del) wherein it was observed that source of income is to be seen and not the source of receipt. The ld DR submitted that the royalty is linked to source made in India. He submitted the ld AO had written letters to OEMs wherein they had responded that they have PE in India. However, he fairly admitted that though the issue is already decided by t…

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), NEW DELHI

In the result, the appeal of the assessee for AY 2022-23 is allowed for 14

ITA 2086/DEL/2025[2018-19]Status: DisposedITAT Delhi10 Dec 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 115ASection 143(3)Section 144C(5)Section 153Section 234BSection 270ASection 9

…AT order dated 29.08.2024 reported in 167 taxmann.com 405 f) For AY 2021-22 - ITAT order dated 14.11.2024 in ITA No. 3742/Del/2023 The ld DR before us relied on the decision of the Hon'ble Delhi High Court 6. in the case of CIT Vs. Havells India reported in 352 ITR 376 (Del) wherein it was observed that source of income is to be seen and not the source of receipt. The ld DR submitted that the royalty is linked to source made in India. He submitted the ld AO had written letters to OEMs wherein they had responded that they have PE in India. However, he fairly admitted that though the issue is already decided by t…

ACIT, CIRCLE LTU-1,, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

In the result, the appeals filed by Revenue in ITA Nos

ITA 140/CHNY/2025[2014-15]Status: DisposedITAT Chennai23 Jun 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

…ITAT without appreciating that the source of income is in India though the overseas - 3 - ITA Nos.117, 139 & 140/Chny/2025 commission agents are situated outside India and therefore as per the decision of the Delhi High Court in the case of Havells India Ltd(352 ITR 376), the same is taxable in India and accordingly liable for TDS. 5. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing officer be restored. Grounds for A.Y. 2014-15 1. The order of the learned Commissioner of Income Tax (Appeals) in…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE LTU-1, , CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

In the result, the appeals filed by Revenue in ITA Nos

ITA 139/CHNY/2025[2013-14]Status: DisposedITAT Chennai23 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

…ITAT without appreciating that the source of income is in India though the overseas - 3 - ITA Nos.117, 139 & 140/Chny/2025 commission agents are situated outside India and therefore as per the decision of the Delhi High Court in the case of Havells India Ltd(352 ITR 376), the same is taxable in India and accordingly liable for TDS. 5. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing officer be restored. Grounds for A.Y. 2014-15 1. The order of the learned Commissioner of Income Tax (Appeals) in…

ACIT, LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

In the result, the appeals filed by Revenue in ITA Nos

ITA 117/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Jun 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

…ITAT without appreciating that the source of income is in India though the overseas - 3 - ITA Nos.117, 139 & 140/Chny/2025 commission agents are situated outside India and therefore as per the decision of the Delhi High Court in the case of Havells India Ltd(352 ITR 376), the same is taxable in India and accordingly liable for TDS. 5. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing officer be restored. Grounds for A.Y. 2014-15 1. The order of the learned Commissioner of Income Tax (Appeals) in…

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

ITA 937/CHNY/2024[AY 2016-17]Status: DisposedITAT Chennai30 Jan 2025

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 147Section 148Section 250o

…आयकर अपीलीय अिधकरण,‘सी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी एबी टी वक", "याियक सद"य एवं "ी एस. आर.रघुनाथा, लेखा सद"य के सम" BEFORE SHRI ABY T VARKEY, HON’BLE JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, HON’BLE ACCOUNTANT MEMBER आयकर अपीलसं./ITA No.: 937/Chny/2024 िनधा"रण वष" / Assessment Year: 2016-17 M/s. Same SeutzFahr Italia SPA, Assistant Commissioner of No. 15, Viale Francesco Cassani v. Income Tax, 15,Italy. International Taxation Circle [72M SIPCOT Industrial Complex, 2(2), Ranipet, Vellore-632 403] Chennai. [PAN: AAKCS-1896-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपील…

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

ITA 2980/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Jan 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate a

…incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the above referred judicial precedents including that of Hon'ble Jurisdictional High Court…

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

ITA 2665/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jan 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Section 143(3)

…incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the above referred judicial precedents including that of Hon'ble Jurisdictional High Court…

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LIMITED (MERGED ENTITY HOUSING DEVELOPMENT FINANCE CORPORATION LIMITED), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below:\n\nSr

ITA 2597/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Jan 2025AY 2020-21

…urred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully following the above referred judicial \nprecedents including that of Hon'ble Jurisdictional High…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2049/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

…ture incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18.3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the above referred judicial precedents including that of Hon'ble Jurisdictional High Court of Bomb…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2047/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 Jan 2025AY 2018-19

…urred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully following the above referred judicial \nprecedents including that of Hon'ble Jurisdictional High C…

ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 2046/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-2018

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

…incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the above referred judicial precedents including that of Hon'ble Jurisdictional High Court…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

ITA 1890/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi

…incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the above referred judicial precedents including that of Hon'ble Jurisdictional High Court…

DCIT RANGE-1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 5110/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…urred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully following the above referred judicial \nprecedents including that of Hon'ble Jurisdictional High…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RANGE-1(1)(2), MUMBAI

ITA 4983/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…incurred\nthereon is revenue in nature.” Reliance was also placed on the decision\nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters\nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of\nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del).\n\n18. 3. On the given set of facts and judicial precedents discussed above,\nRevenue could not submit any reason as to why a different view on this\nissue should be taken as taken by various Hon'ble High Courts.\nAccordingly, respectfully following the above referred judicial\nprecedents including that of Hon'ble Jurisdictional High Cour…

Showing 1–20 of 97 · Page 1 of 5