CIT v. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd.

274 ITR 119High Court2005#6948 most cited

What is CIT v. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd. authority for?

Where an assessee earns interest income from investments and cannot specifically identify expenses incurred to earn it, an estimated expenditure as a percentage of income can be allowed as a deduction.

16

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2022 to 2026.

Also referred to as

CIT v. Kisan Sahkari Chini Mills Ltd. · 274 ITR 119 · interest income · deduction of expenses · estimated expenditure · Section 57 · Section 57(iii) · income from other sources · expenditure not identified

Sections most often in play

Section 142(1)Section 143(2)Section 143(3)Section 2(24)Section 57Section 57(iii)

Judgments citing CIT v. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd.

Marathi Bandhkam Vya vs. Ayik Association, Punevs.ITO, Exemption Ward-1(1), Pune

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

ITA 2310/PUN/2025[2018-19]Status: DisposedITAT Pune10 Feb 2026AY 2018-19
For Appellant: Shri Suhas P. BoraFor Respondent: Shri Milind Debaje (Virtual)
Section 143(2)Section 143(3)

…y, the same should have been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Taluk Gopalpur Samabay Krishi Unnayan Samity Limited., Medinipur vs. ITO, Ward No-27(3), Haldia

In the result, the appellant fails with respect to ground no

ITA 1152/KOL/2023[2018-19]Status: DisposedITAT Kolkata07 Aug 2024AY 2018-19

Bench: Pradip Kumar Choubey & Sri Sanjay Awasthi

Section 80PSection 80P(2)(d)

…s Act, 2006. The ld. A/R also relied on the case of CIT vs. South Eastern Railway Employees Co-Op Credit Society Ltd. in ITA 484 of 2007 (which we will have occasion to advert to later) and the case of CIT vs. Kisan Sahkari Chini Mills Ltd. reported in [2005] 274 ITR 119 (Allahabad) to canvas the point that in case the impugned amount is held to be income from other sources then this case could guide in estimating expenses allowable to earn such income. 1.5. The ld. D/R relied on the Totgars, Co-operative Sale Society Ltd. (supra) case and the findings given in the orders of ld. CIT(A) and the ld. AO. 2. We have…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 892/PUN/2017[2008-09]Status: DisposedITAT Pune20 Apr 2022AY 2008-09

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 891/PUN/2017[2007-08]Status: DisposedITAT Pune20 Apr 2022AY 2007-08

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 890/PUN/2017[2006-07]Status: DisposedITAT Pune20 Apr 2022AY 2006-07

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income-Tax, Circle - 4, Pune vs. M/S. Poona Club Ltd, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1939/PUN/2017[2013-14]Status: DisposedITAT Pune20 Apr 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income Tax, Pune vs. M/S. Poona Club Ltd., Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1238/PUN/2017[2012-13]Status: DisposedITAT Pune20 Apr 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income Tax, Pune vs. M/S. Poona Club Ltd., Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1237/PUN/2017[2011-12]Status: DisposedITAT Pune20 Apr 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income Tax, Pune vs. M/S. Poona Club Ltd., Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1235/PUN/2017[2008-09]Status: DisposedITAT Pune20 Apr 2022AY 2008-09

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 895/PUN/2017[2012-13]Status: DisposedITAT Pune20 Apr 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 894/PUN/2017[2011-12]Status: DisposedITAT Pune20 Apr 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 893/PUN/2017[2009-10]Status: DisposedITAT Pune20 Apr 2022AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 4, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 2242/PUN/2017[2014-15]Status: DisposedITAT Pune20 Apr 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income-Tax, Circle - 4, Pune vs. M/S. Poona Club Ltd, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 2221/PUN/2017[2014-15]Status: DisposedITAT Pune20 Apr 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Poona Club Ltd., Pune vs. Deputy Commissioner of Income-Tax, Circle - 4, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1653/PUN/2017[2013-14]Status: DisposedITAT Pune20 Apr 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…

Assistant Commissioner of Income Tax, Pune vs. M/S. Poona Club Ltd., Pune

In the result, the appeal filed by the Revenue in ITA

ITA 1236/PUN/2017[2009-10]Status: DisposedITAT Pune20 Apr 2022AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri M. G. Jasnani
Section 143(1)Section 143(3)Section 147Section 148

…ave been followed by the lower authorities. The decision of the Hon’ble ITAT in assessee’s own case is also in consonance with the ratio of decision of the Hon’ble Allahabad High Court in the case of CIT vs. Kisan 21 Poona Club Ltd. Sahkari Chini Mills Ltd., 274 ITR 119, wherein, the Hon’ble Allahabad High Court confirmed the findings of the Tribunal that where the assessee held some interest income other than the exempted income, it must incur some expenses for earning the interest income and the expenditure cannot be identified. Then estimated expenditure in terms of the percentage of the income can be allowed…