CIT v. Indo Saudi Services (Travel) Pvt. Ltd.

310 ITR 306High Court2009#998 most cited

What is CIT v. Indo Saudi Services (Travel) Pvt. Ltd. authority for?

An expenditure disallowance is not sustainable solely because both the payer and payee are assessed to tax at the same rate, particularly in the context of sections like 40A(2) or 36(1)(iii).

109

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Indo Saudi Services · 310 ITR 306 · Section 40A(2) · Section 36(1)(iii) · expenditure disallowance · payer payee same tax rate · business expediency · reasonableness of expenditure · 40A(2)(b) · interest disallowance

Sections most often in play

Section 40A(2)Section 37(1)Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)(b)Section 8DSection 250

Issues it is cited on

section 40a(2)(b)section 40a(2)annual letting valueannual valuesection 40abusiness expediencyblock of assetssection 40mercantile system of accountingsection 36(1)(iii)section 115jdisallowance u/s 14a

Judgments citing CIT v. Indo Saudi Services (Travel) Pvt. Ltd.

DENTSU AEGIS NETWORK INDIA PRIVATE LIMITED(ERSTWHILE VIZEUM MEDIA SERVICE INDIA MERGED IN DAN INDIA),MUMBAI vs. INCOME TAX OFFICER, CIRCLE 8(3)(2), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6122/MUM/2025[2014-15]Status: DisposedITAT Mumbai20 Feb 2026AY 2014-15

Bench: Shri Rahul Chaudhary & Shri Makarand Vasant Mahadeokardentsu Aegis Network Dcit Central India Private Limited Circle-1(1), (Erstwhile Vizeum Media Vs. Aayakar Bhavan, Service India Merged Maharashi Karve With Dentsu Aegis Marg, Mumbai-400 Network India Private 020 Limited W.E.F. 1St April 2017) 2Nd Floor, Devchand House, Dr. A. B. Road, Shiv Sagar Estate Mumbai, Worli So, Mumbai-400 018 Pan/Gir No. Aahca3058N (Applicant) (Respondent) Assessee By Shri Ketan Ved & Shri Abdul Kadir Jawadwala, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 02.02.2026 Date Of Pronouncement 20.02.2026

Section 142(1)Section 143(3)Section 250Section 37(1)Section 40Section 40A(2)(b)

…allowance under section 37(1) read with section 40A(2)(b) was not warranted either on facts or in law. 24. The learned AR also placed reliance on the decision of the Hon’ble Bombay High Court in the case of CIT v. Indo Saudi Services (Travel) (P.) Ltd. [2009] 310 ITR 306 to submit that where both the assessee and the payee concern are assessed to tax at the same rate, and there is no allegation of tax evasion, disallowance under section 40A(2) on the ground of excessive or unreasonable payment is not justified. It was submitted that in the present case also both Aegis and Carat were taxable at the effect of tax e…

PROACTIVE IN & OUT ADVERTISING PRIVATE LIMITED,MUMBAI vs. THE COMMISSIONER OF INCOME TAX (APPEALS)-26, NEW DELHI

Appeal is allowed

ITA 1025/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 1025/Del/2025 : Asstt. Year : 2020-21 Proactive In & Out Advertising Pvt. Vs Cit(A)-26, Ltd., B Wing, Samkeet Apartment, New Delhi Vileeparle (East), S.O. Mumbai, Maharashtra-400057 (Appellant) (Respondent) Pan No. Aaccp6306R Assessee By : None Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2020-21, Arises Against The Cit(A)-26, New Delhi’S Order Dated 08.01.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 143(3)Section 40A(2)(b)

…able at the maximum marginal rate. This being the clinching factual position, we notice that various judicial precedents i.e. PCIT Vs. Future First Info Services (P.) Ltd. (2022) 145 taxmann.com 35 (Del.), CIT vs. Indo Saudi Services (Travel) (P.) Ltd. (2009) 310 ITR 306, CIT Vs. V.S. Dempo & Co. Ltd. (2011) 336 ITR 209 (Bom.) as well as the CBDT’s landmark Circular No. 6-P issued way back on 18.06.1967 have settled the issue against the department that when both the payer and payee are assessed at maximum marginal rate, the impugned disallowance is not maintainable being a revenue neutral case. We thus reverse b…

GYAN ENTERPRISES PRIVATE LIMITED ,DELHI vs. DCIT CIRCLE 10(2), NEW DELHI

ITA 94/DEL/2024[2014-15]Status: DisposedITAT Delhi27 May 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

…the CIT(A)’s detailed discussion. 12 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 9. Faced with this situation, we hereby quote CBDT’s landmark circular issued way back on 06.07.1968 and CIT Vs. Indo Saudi Services (Travel) Pvt. Ltd., (2009) 310 ITR 306 (Bom.) to conclude that such a disallowance is not sustainable even when both the payer and payee are assessed at the same rate. The assessee succeeds in it’s second substant ground and Revenue fails in its third substantive ground in very terms. This former’s appeal ITA No. 94/Del/2024 is partly allowed. 10. We stay back in the Revenue’s cross a…

GYAN ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE 10(2), NEW DELHI

ITA 93/DEL/2024[2015-16]Status: DisposedITAT Delhi27 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

…the CIT(A)’s detailed discussion. 12 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 9. Faced with this situation, we hereby quote CBDT’s landmark circular issued way back on 06.07.1968 and CIT Vs. Indo Saudi Services (Travel) Pvt. Ltd., (2009) 310 ITR 306 (Bom.) to conclude that such a disallowance is not sustainable even when both the payer and payee are assessed at the same rate. The assessee succeeds in it’s second substant ground and Revenue fails in its third substantive ground in very terms. This former’s appeal ITA No. 94/Del/2024 is partly allowed. 10. We stay back in the Revenue’s cross a…

GYAN ENTERPRISES PVT LTD,NEW DELHI vs. DCIT CIRCLE 10(2), NEW DELHI

ITA 92/DEL/2024[2017-18]Status: DisposedITAT Delhi27 May 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

…the CIT(A)’s detailed discussion. 12 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 9. Faced with this situation, we hereby quote CBDT’s landmark circular issued way back on 06.07.1968 and CIT Vs. Indo Saudi Services (Travel) Pvt. Ltd., (2009) 310 ITR 306 (Bom.) to conclude that such a disallowance is not sustainable even when both the payer and payee are assessed at the same rate. The assessee succeeds in it’s second substant ground and Revenue fails in its third substantive ground in very terms. This former’s appeal ITA No. 94/Del/2024 is partly allowed. 10. We stay back in the Revenue’s cross a…

ACIT(OSD), RANGE-10, NEW DELHI, C.R. BUILDING ITO vs. GYAN ENTERPRISES PVT. LTD. , ROUSE AVENUE, NEW DELHI

ITA 176/DEL/2024[2015-16]Status: DisposedITAT Delhi27 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

…the CIT(A)’s detailed discussion. 12 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 9. Faced with this situation, we hereby quote CBDT’s landmark circular issued way back on 06.07.1968 and CIT Vs. Indo Saudi Services (Travel) Pvt. Ltd., (2009) 310 ITR 306 (Bom.) to conclude that such a disallowance is not sustainable even when both the payer and payee are assessed at the same rate. The assessee succeeds in it’s second substant ground and Revenue fails in its third substantive ground in very terms. This former’s appeal ITA No. 94/Del/2024 is partly allowed. 10. We stay back in the Revenue’s cross a…

ACIT(OSD), RANGE-10, NEW DELHI, C.R. BUILDING, ITO NEW DELHI vs. GYAN ENTERPRISES PVT. LTD. , PUNJABI BHAWAN, DELHI

ITA 109/DEL/2024[2014-15]Status: DisposedITAT Delhi27 May 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 14ASection 36(1)(iii)Section 40A(2)

…the CIT(A)’s detailed discussion. 12 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 9. Faced with this situation, we hereby quote CBDT’s landmark circular issued way back on 06.07.1968 and CIT Vs. Indo Saudi Services (Travel) Pvt. Ltd., (2009) 310 ITR 306 (Bom.) to conclude that such a disallowance is not sustainable even when both the payer and payee are assessed at the same rate. The assessee succeeds in it’s second substant ground and Revenue fails in its third substantive ground in very terms. This former’s appeal ITA No. 94/Del/2024 is partly allowed. 10. We stay back in the Revenue’s cross a…

FERANI HOTELS PVT LTD,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -4(2)(1), MUMBAI

In the result, appeal of the assessee bearing ITA No

ITA 3859/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Dec 2024AY 2016-17

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

For Appellant: Shri Sanjay SawantFor Respondent: Shri Ashish Heliwal, CIT DR
Section 143(3)Section 24Section 250Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.3859/Mum/2024 - A.Y. 2016-17 I.T.A No.3860/Mum/2024 - A.Y. 2017-18 Ferani Hotels Pvt Ltd vs The Deputy Commissioner of 2nd Construction House-B, Income-tax, Central Circle-4(2)(1), Floor, 623, Linking Road, Khar Mumbai 6th Floor, Aayakar Bhawan, Mumbai- (West), Mumbai-400 052 PAN: AAACF0693B 400020 APPELLANT RESPONDENT I.T.A No.3918/Mum/2024 - A.Y. 2016-17 I.T.A No.3917/Mum/2024 - A.Y. 2017-18 Assistant Commissioner of vs Ferani Hotels Pvt Ltd Construc…

EASTERN CARGO CARRIERS (INDIA) PRIVATE LIMITED,MUMBAI, MAHARASHTRA, INDIA vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT

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

ITA 4610/MUM/2023[2021-2022]Status: DisposedITAT Mumbai20 Dec 2024AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 M/S Eastern Cargo Carriers (India) The Assessment Unit, Income Tax Pvt. Ltd., Department, Vs. Unit No. 26, Adarsh Ind. Estates, Aaykar Bhavan, M.K. Road, Sahar Road, Andheri East, Mumbai-400020. Mumbai-400099. Pan No. Aaace 1520 E Appellant Respondent

For Appellant: Mr. Niraj Sheth a/wFor Respondent: Mr. Hemanshu Joshi, Sr. DR
Section 40A(2)(a)

…mbay Court in counsel further relied on the decision of Hon’ble Bombay Court in the case of CIT v. Indo Saudi Services (Travel) (P.) Ltd. reported CIT v. Indo Saudi Services (Travel) (P.) Ltd. reported CIT v. Indo Saudi Services (Travel) (P.) Ltd. reported in 310 ITR 306, decision of Hon’ble Bombay High C , decision of Hon’ble Bombay High C , decision of Hon’ble Bombay High Court in the case of CIT v. V.S. Dempo & Co. (P.) Ltd. 336 ITR 209 CIT v. V.S. Dempo & Co. (P.) Ltd. 336 ITR 209 CIT v. V.S. Dempo & Co. (P.) Ltd. 336 ITR 209, decision of Hon’ble Supreme Court in the case of CIT v. Glaxo Smithkline Glaxo Smit…

M/S SANOFI INDIA LTD (FORMERLY KNOWN AS AVENTIS PHARMA LTD,MUMBAI vs. THE ACIT RG 8(1), MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 1606/MUM/2007[2003-2004]Status: DisposedITAT Mumbai31 Oct 2023AY 2003-2004

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRI VIKAS AWASTHY, HON’BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA.NO.1606/MUM/2007(A.Y: 2003-04) ITA.NO.1128/MUM/2009 (A.Y. 2003-04) M/s. Sanofi India Ltd v. DCIT – Range – 8(1) {Formerly known as Aventis Pharma Limited} Room No. 210, Aayakar Bhavan 54/A, Sir MathuradasVasanji Road Maharshi Karve Road Andheri (E), Mumbai – 400093 Mumbai - 400020 PAN: AAACH2736F (Appellant) (Respondent) ITA.NO. 5939/MUM/2010 (A.Y. 2004-05) M/s. Sanofi India Ltd v. Addl. CIT – Range – 8(1) {Formerly known as Aventis Pharma Lim…

ACIT- 3(1)(1), MUMBAI vs. MM/S SANOFI INDIA LIMITED (FORMERLY KNOWN AS AVENTIS PHARMA LTD)., MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 1302/MUM/2007[2003-2004]Status: DisposedITAT Mumbai31 Oct 2023AY 2003-2004

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRI VIKAS AWASTHY, HON’BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA.NO.1606/MUM/2007(A.Y: 2003-04) ITA.NO.1128/MUM/2009 (A.Y. 2003-04) M/s. Sanofi India Ltd v. DCIT – Range – 8(1) {Formerly known as Aventis Pharma Limited} Room No. 210, Aayakar Bhavan 54/A, Sir MathuradasVasanji Road Maharshi Karve Road Andheri (E), Mumbai – 400093 Mumbai - 400020 PAN: AAACH2736F (Appellant) (Respondent) ITA.NO. 5939/MUM/2010 (A.Y. 2004-05) M/s. Sanofi India Ltd v. Addl. CIT – Range – 8(1) {Formerly known as Aventis Pharma Lim…

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL-1), RAIPUR, RAIPUR vs. M/S SUNIL SPONGE PVT. LTD., RAIPUR

In the result, the appeal of the revenue is dismissed in terms of our aforesaid observations

ITA 73/RPR/2022[2007-08]Status: DisposedITAT Raipur12 Oct 2023AY 2007-08

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.73/Rpr/2022 "नधा"रण वष" / Assessment Year : 2007-08 The Deputy Commissioner Of Income Tax, (Central Circle)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunil Sponge Pvt. Ltd. H. No.11, Jalvihar Colony, Raipur (C.G.)-492 001 (C.G.) Pan : Aahcs7999A ……""यथ" / Respondent

For Appellant: S/shri, Sakshi Gopal Agrawal &For Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 143(3)Section 147Section 148Section 40A(2)(b)

…nd ruled out. 25. At this stage, we are reminded of the judgment of the Hon’ble High Court of Bombay in the case of Commissioner of Income Tax Vs. Indo 37 DCIT (Central Circle-1), Raipur Vs. M/s. Sunil Sponge Pvt. Ltd. Saudi Services (Travel) P. Ltd. (2009) 310 ITR 306 (Bom), wherein it was observed by the Hon’ble High Court that as the revenue was not in a position to point out how the assessee had evaded payment of tax by allegedly making payment of higher commission to its sister concern since the sister concern was also paying tax at higher rate and copies of the assessment orders of the sister concern were…

M/S. JYOTI PAPER UDYOG LTD,NASHIK vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NASHIK

In the result, appeal of the assessee is allowed

ITA 702/PUN/2023[2013-14]Status: DisposedITAT Pune20 Sept 2023AY 2013-14

Bench: Shri R.S. Syal, Hon. Vice- & Shri Partha Sarathi Chaudhury, Hon.M/S. Jyoti Paper Udyog Ltd., Vs Acit, Circle-1, Plot No.B67, Nice, Midc Nashik. Satpur, Nashik – 422 007 Pan: Aaacj 7288 E Appellant Respondent Assessee By : Shri Sanket M. Joshi, Ca Revenue By : Shri Ramnath P Murkunde, Dr Date Of Hearing : 06/09/2023 Date Of Pronouncement : 20/09/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Order Of National Faceless Appeal Centre [Nfac], Delhi, Dated 28.04.2023 For A.Y.2013-14 As Per The Grounds Of Appeal On Record.

For Appellant: Shri Sanket M. Joshi, CAFor Respondent: Shri Ramnath P Murkunde, DR
Section 271ASection 273BSection 40A(2)Section 40A(2)(b)Section 92CSection 92DSection 92E

…even if the FMV is found to be lower than the actual price paid by the assessee company to the two sister concerns, still there would be no loss of revenue and hence, in view of the settled position of law, as also held in Indo Saudi Travel Services P. Ltd. [310 ITR 306 (Bom)] and Glaxo SmithKline Asia Pvt. Ltd. (SC), the disallowance u/sec. 40A(2) would not be attracted. Accordingly, considering the intention of Legislature behind bringing the specified domestic transactions within the ambit of Transfer Pricing Regulations, in my opinion, the provisions of section 92C, 92D and 92E would not have application in…

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

…g the provisions of Section 40A(2)(b) as there is no question of diversion of profit to evade tax liability. We rely upon the following decisions:- (i) Hon'ble Bombay High Court in the case of CIT Vs. Indo Saudi Services (Travel) P. Ltd., reported in [2009] 310 ITR 306 (Bom.) (ii) CIT Vs. V.S. Dempo & Co. (P.) Ltd., reported in [2011] 196 TAXMAN 193. Hon'ble High Court has held that when the assessee as well as its subsidiaries were in the same tax bracket and paid the same rate of tax, there was no question of diversion of funds by paying higher rate to subsidiary companies and, therefore, no disallowance coul…

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

…g the provisions of Section 40A(2)(b) as there is no question of diversion of profit to evade tax liability. We rely upon the following decisions:- (i) Hon'ble Bombay High Court in the case of CIT Vs. Indo Saudi Services (Travel) P. Ltd., reported in [2009] 310 ITR 306 (Bom.) (ii) CIT Vs. V.S. Dempo & Co. (P.) Ltd., reported in [2011] 196 TAXMAN 193. Hon'ble High Court has held that when the assessee as well as its subsidiaries were in the same tax bracket and paid the same rate of tax, there was no question of diversion of funds by paying higher rate to subsidiary companies and, therefore, no disallowance coul…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1) , MUMBAI vs. RAYMOND LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 4082/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Dec 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

…nt of payment of higher expenditure by the company to its sister concern since the sister concern was also paying tax at higher rate. This ratio has been upheld by the Hon'ble Bombay High Court in the case of CIT vs Indo Saudi services (Travel)(P) Ltd. (2009] 310 ITR 306 (Bombay). Further, Ld. AR enclosed the assessment order of JK Investors Bombay Ltd for A.Y. 2009-10. He invited our attention to page 10 of such order, wherein it is evident that J.K. Investors Bombay Ltd is paying taxes at the rate of 30% and thus applying the principles of the aforesaid decision, there is no evasion of taxes by the appellant wo…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1) , MUMBAI vs. RAYMOND LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 4073/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Dec 2022AY 2011-12

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

…nt of payment of higher expenditure by the company to its sister concern since the sister concern was also paying tax at higher rate. This ratio has been upheld by the Hon'ble Bombay High Court in the case of CIT vs Indo Saudi services (Travel)(P) Ltd. (2009] 310 ITR 306 (Bombay). Further, Ld. AR enclosed the assessment order of JK Investors Bombay Ltd for A.Y. 2009-10. He invited our attention to page 10 of such order, wherein it is evident that J.K. Investors Bombay Ltd is paying taxes at the rate of 30% and thus applying the principles of the aforesaid decision, there is no evasion of taxes by the appellant wo…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1) , MUMBAI vs. RAYMOND LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 4072/MUM/2018[2010-11]Status: DisposedITAT Mumbai28 Dec 2022AY 2010-11

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

…nt of payment of higher expenditure by the company to its sister concern since the sister concern was also paying tax at higher rate. This ratio has been upheld by the Hon'ble Bombay High Court in the case of CIT vs Indo Saudi services (Travel)(P) Ltd. (2009] 310 ITR 306 (Bombay). Further, Ld. AR enclosed the assessment order of JK Investors Bombay Ltd for A.Y. 2009-10. He invited our attention to page 10 of such order, wherein it is evident that J.K. Investors Bombay Ltd is paying taxes at the rate of 30% and thus applying the principles of the aforesaid decision, there is no evasion of taxes by the appellant wo…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1) , MUMBAI vs. RAYMOND LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 202/MUM/2018[2009-10]Status: DisposedITAT Mumbai28 Dec 2022AY 2009-10

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

…nt of payment of higher expenditure by the company to its sister concern since the sister concern was also paying tax at higher rate. This ratio has been upheld by the Hon'ble Bombay High Court in the case of CIT vs Indo Saudi services (Travel)(P) Ltd. (2009] 310 ITR 306 (Bombay). Further, Ld. AR enclosed the assessment order of JK Investors Bombay Ltd for A.Y. 2009-10. He invited our attention to page 10 of such order, wherein it is evident that J.K. Investors Bombay Ltd is paying taxes at the rate of 30% and thus applying the principles of the aforesaid decision, there is no evasion of taxes by the appellant wo…

KKR AGRO MILLS P. LTD,ERNAKULAM vs. THE ACIT, COCHIN

In the result, appeal is allowed in favour of the assessee

ITA 328/COCH/2016[2010-11]Status: DisposedITAT Cochin19 Dec 2022AY 2010-11

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sassessment Year : 2010-11 Kkr Agro Mills Pvt. Ltd., Vs. Acit, Iii/678, Kkr Building, Okkal Kalady, Circle – 1(2), Ernakulam – 683 550. Kochi. Pan : Aabck 6542 K Assessee Respondent

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Smt. J M Jamuna Devi, Sr. AR
Section 40A(2)Section 40A(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL BENCH : COCHIN BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND MS. PADMAVATHY S, ACCOUNTANT MEMBER Assessment Year : 2010-11 KKR Agro Mills Pvt. Ltd., Vs. ACIT, III/678, KKR Building, Okkal Kalady, Circle – 1(2), Ernakulam – 683 550. Kochi. PAN : AABCK 6542 K ASSESSEE RESPONDENT Assessee by : Smt. Parvathy Ammal, CA Revenue by : Smt. J M Jamuna Devi, Sr. AR Date of hearing : 05.12.2022 Date of Pronouncement : 19.12.2022 O R D E R Per Padmavathy S, Accountant Member This is an appeal against the order of the CIT(A) - 1, Kochi, dated 11.05.2016, for Assessment Year 2010-11 rai…

Showing 1–20 of 109 · Page 1 of 6