CIT v. Madras Motors Ltd.

257 ITR 60High Court2002#2367 most cited

What is CIT v. Madras Motors Ltd. authority for?

Interest received on delayed payments from trade debtors for sale consideration is considered income derived from the business of an industrial undertaking. This income is eligible for deduction under relevant provisions like Section 80IB or 80IE.

49

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2025.

Also referred to as

CIT v. Madras Motors Ltd. · 257 ITR 60 · Section 80IB · Section 80IE · interest on delayed payment · trade debtors interest · income derived from business · industrial undertaking deduction · sale consideration interest · business profits deduction

Sections most often in play

Section 250Section 10ASection 139(1)Section 143(3)Section 147Section 148Section 194ASection 194H

Issues it is cited on

convertible foreign exchangesection 2(28a)section 133a(2a)section 80hsection 80hhsection 80hhcsection 194hinterest under section 201(1a)interest on securitiessection 80ibsection 57section 194a

Judgments citing CIT v. Madras Motors Ltd.

ACIT, NEW DELHI vs. M/S NUWAVE E SOLUTIONS (P) LTD., NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 3676/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Sept 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2007-08] Acit, Vs M/S. Nuwave E Solutions (P) Circle-13(1), Ltd., 3Rd Floor, District Centre, New Delhi Dda Building, Nehru Place, New Delhi. Pan-Aabcn5790Q Appellant Respondent Appellant By Shri Pravin Rawal, Cit Dr Respondent By Dr. Rakesh Gutpa, Adv., Shri Saksham Agarwal, Ca, Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Date Of Hearing 26.06.2025 Date Of Pronouncement 12.09.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Revenue Against The Order Dated 15.03.2011 Passed By Ld. Commissioner Of Income Tax (Appeal)-Xvi, New Delhi [“Cit(A)”, In Short] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 31.12.2010 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2007-08. 2. Brief Facts Of The Case Are That Assessee Is A Company & E- Filed Its Return Of Income On 30.08.2007, Declaring Total Income Of Inr 1,45,48,453/-. The Said Return Was Revised On 20.08.2008, Declaring The Same Income As Was Declared The Return Of Income Filed U/S 139(1). The Case Of The Assessee Was Selected For Scrutiny & Various Queries Were Raised Which Were Replied By The Assessee. The Assessee Is Engaged In The Business Of Development & Export Of Software & 100% Eou Registered With Director Software Technology Park Of India In Terms Of Registration Certificate Dated 31.03.1999. The Major Shareholder In The Assessee Company Is Shri Anil Gutpa Who Is Having 99% Shareholding & Is Taking Substantial Interest In Day-To-Day Affairs Of The Assessee & Also In Its Associate Enterprises (“Ae”) At Us Who Is The Sole Buyer Of The Software Developed By The Assessee.

Section 10Section 10ASection 139(1)Section 143(3)Section 250Section 40Section 801A

…nder section 104/10B of the Act. Further reliance can be placed on the following judicial pronouncements:- a) Smt. Sujatha Grover v. Deputy CIT (2002) 74 TTJ 347 (Delhi) b) Priyanka Gems v. Asst. CIT [2005] 94 TTJ 557 (And) c) CIT v. Rane (Madras) Ltd. [1999] 238 ITR 377 (Mad), where even a forward contract in foreign exchange, which had nexus with the export of goods could be treated as relating to the activity eligible for deduction in the context of sections 80E and 80-I. In fact, the case of the appellant is also covered by the decision of Hon'ble Supreme Court in the case of CIT v/s. Woodward Governor P Ltd.…

NIHO CONSTRUCTION LTD.,NEW DELHI vs. ITO, WARD- 18(2), NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 3676/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Apr 2025AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2007-08] Acit, Vs M/S. Nuwave E Solutions (P) Circle-13(1), Ltd., 3Rd Floor, District Centre, New Delhi Dda Building, Nehru Place, New Delhi. Pan-Aabcn5790Q Appellant Respondent Appellant By Shri Pravin Rawal, Cit Dr Respondent By Dr. Rakesh Gutpa, Adv., Shri Saksham Agarwal, Ca, Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Date Of Hearing 26.06.2025 Date Of Pronouncement 12.09.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Revenue Against The Order Dated 15.03.2011 Passed By Ld. Commissioner Of Income Tax (Appeal)-Xvi, New Delhi [“Cit(A)”, In Short] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 31.12.2010 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2007-08. 2. Brief Facts Of The Case Are That Assessee Is A Company & E- Filed Its Return Of Income On 30.08.2007, Declaring Total Income Of Inr 1,45,48,453/-. The Said Return Was Revised On 20.08.2008, Declaring The Same Income As Was Declared The Return Of Income Filed U/S 139(1). The Case Of The Assessee Was Selected For Scrutiny & Various Queries Were Raised Which Were Replied By The Assessee. The Assessee Is Engaged In The Business Of Development & Export Of Software & 100% Eou Registered With Director Software Technology Park Of India In Terms Of Registration Certificate Dated 31.03.1999. The Major Shareholder In The Assessee Company Is Shri Anil Gutpa Who Is Having 99% Shareholding & Is Taking Substantial Interest In Day-To-Day Affairs Of The Assessee & Also In Its Associate Enterprises (“Ae”) At Us Who Is The Sole Buyer Of The Software Developed By The Assessee.

Section 10Section 10ASection 139(1)Section 143(3)Section 250Section 40Section 801A

…nder section 104/10B of the Act. Further reliance can be placed on the following judicial pronouncements:- a) Smt. Sujatha Grover v. Deputy CIT (2002) 74 TTJ 347 (Delhi) b) Priyanka Gems v. Asst. CIT [2005] 94 TTJ 557 (And) c) CIT v. Rane (Madras) Ltd. [1999] 238 ITR 377 (Mad), where even a forward contract in foreign exchange, which had nexus with the export of goods could be treated as relating to the activity eligible for deduction in the context of sections 80E and 80-I. In fact, the case of the appellant is also covered by the decision of Hon'ble Supreme Court in the case of CIT v/s. Woodward Governor P Ltd.…

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

ITA 741/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…hich was subsequently followed in AY 2010-11 and 2011-12 wherein following the decision of Hon'ble Gujarat High Court in the case of Nirma Industries Ltd. Vs. CIT (2006) 155 Taxman 330 and decision of Hon'ble Madras High Court in the case of CIT Vs. Rane Ltd. 238 ITR 377 (Mad.) wherein it has been held that interest received by the assessee from its trade debtor towards late payment of sale consideration is not required to be excluded from the profit of the industrial undertaking for the purposes of computation of deduction u/s.80IB/80IE as the same is income derived from business of industrial undertaking. The r…

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…hich was subsequently followed in AY 2010-11 and 2011-12 wherein following the decision of Hon'ble Gujarat High Court in the case of Nirma Industries Ltd. Vs. CIT (2006) 155 Taxman 330 and decision of Hon'ble Madras High Court in the case of CIT Vs. Rane Ltd. 238 ITR 377 (Mad.) wherein it has been held that interest received by the assessee from its trade debtor towards late payment of sale consideration is not required to be excluded from the profit of the industrial undertaking for the purposes of computation of deduction u/s.80IB/80IE as the same is income derived from business of industrial undertaking. The r…

DCIT(OSD)(TDS)-2(3), MUMBAI, MUMBAI vs. WOCKHARDT LTD., MUMBAI

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

ITA 2633/MUM/2024[2015-16]Status: DisposedITAT Mumbai01 Aug 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

Section 194ASection 194HSection 2Section 201Section 201(1)Section 222Section 271C

…receivable by the assessee during the course of its business on account of sale, the interest would have to be included as the profits and gains derived from the business of the assessee. An another decision cited therein was CIT v. Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 (Mad.). 10. In the case of Phatela Cotgin Industries (P.) Ltd. (supra) the verdict was that the interest being received on delayed payment on account of sale to customers could clearly be termed to be an income derived from Industrial Undertaking. It was observed that such an interest is distinct from interest income which is bein…

PICRIC LTD vs. ITO WARD 14 (4),

In the result, the appeal of the assessee is allowed with directions contained in para 22 above

ITA 4115/DEL/2007[2004-2005]Status: DisposedITAT Delhi06 Apr 2023AY 2004-2005

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Neeraj Jain,AdvocateFor Respondent: Shri H.K. Chaudhary, CIT(DR)
Section 10BSection 143(1)Section 143(3)Section 80H

…ome is at best “attributable to” the export activity of the assessee and has only incidental nexus with the export activity and constitute a ‘step removed’ from the export activity. Citing the decision of the Hon’ble Madras High Court in CIT vs. Madras Motors 257 ITR 60 (Mad) wherein it is held that interest earned on fixed deposits is not eligible for deduction under section 10B, and stating that the Tribunal in its order (supra) has fortified the stand of the Revenue that interest income could not be said to be derived from the against the assessee by the decision of Hon’ble Supreme Court in CIT vs. V.P. Gopina…

ADDL.CIT, SPECIAL RANGE- 9, NEW DELHI vs. VLCC PERSONAL CARE LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 3126/DEL/2018[2014-15]Status: DisposedITAT Delhi17 Feb 2023AY 2014-15

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2014-15

For Appellant: Shri Vinod Bindal, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 10BSection 143(1)Section 143(3)Section 80Section 80I

…ustrial undertaking. This principle was reiterated in CIT vs. Pandian Chemicals (2003) 262 ITR 278 3. Hon’ble Madras High Court has held that interest earned on fixed deposits is not eligible for deduction under section 10B in the case of CIT vs Madras Motors 257 ITR 60. 4. Hon’ble Supreme Court in the case of Liberty India Vs. CIT (317 ITR 218) has held that the phrase “derived from” is narrower in connotation as compared to the phrase “ attributable to”. By using the word derived from the Parliament intended to cover sources not beyond the first degree. Profits derived by way of incentives should be treated as…

DCIT (TDS)(OSD) - 2(3), MUMBAI vs. M/S. WOCKHARDT LTD., MUMBAI

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

ITA 2131/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Dec 2022AY 2014-15

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 Dcit (Tds) (Osd)-2(3), M/S Wockhardt Ltd., Room No. 310, 3Rd Floor, Mtnl Wockhardt Towers, Bandra Building, Cumballa Hill, Vs. Kurla Complex, Mumbai-400026. Mumbai-400051. Pan No. Aaacw 2472 M Appellant Respondent : Assessee By Mr. Pranay Gandhi, Ar : Revenue By Mr. Byomakesh Pradipta Kumar Panda, Cit-Dr : Date Of Hearing 20/12/2022 : Date Of Pronouncement 30/12/2022

For Respondent: Assessee by Mr. Pranay Gandhi, AR
Section 194H

…ed as the profits and gains derived from the business of the assessee. An another decision cited therein was CIT v. the assessee. An another decision cited therein was CIT v. the assessee. An another decision cited therein was CIT v. Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 (Mad.). 10. In the case of Phatela Cotgin Indust 10. In the case of Phatela Cotgin Industries (P.) Ltd. (supra) the ries (P.) Ltd. (supra) the verdict was that the interest being received on delayed verdict was that the int…

DCIT (TDS)-2(3), MUMBAI vs. WOCKHARDT LIMITED, MUMBAI

Appeal is dismissed

ITA 2314/MUM/2022[2013-14]Status: DisposedITAT Mumbai20 Dec 2022AY 2013-14

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2013-14

For Appellant: Shri Vallabh Gokhale, A.RFor Respondent: Shri Byomakesh Pradipta Kumar Panda, D.R
Section 133ASection 194ASection 194HSection 201Section 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “G”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2013-14 DCIT (TDS)(OSD)-2(3), M/s. Wockhardt Ltd., Room No.310, Wockhardt Towers, 3rd Floor, Vs. Bandra Kurla Complex, MTNL Building, Mumbai – 400 051 Cumballa Hill, PAN: AAACW2472M Mumbai - 400026 (Appellant) (Respondent) Present for: Assessee by : Shri Vallabh Gokhale, A.R. Revenue by : Shri Byomakesh Pradipta Kumar Panda, D.R. Date of Hearing : 15 . 12 . 2022 Date of Pronouncement : 20 . 12 . 2022 O R D E R Per : Kuldip Singh, Judicial Mem…

MURCURY RUBBER MILLS,,DELHI vs. ACIT CIRCLE 36(1), NEW DELHI

In the result, the Appeal of the Assessee is partly allowed for statistical purpose

ITA 1549/DEL/2019[2013-14]Status: DisposedITAT Delhi06 Dec 2022AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.I.T.A. No. 1549/Del/2019 (A.Y 2013-14)

Section 80I

…ner of Income Tax v. Metalman Auto (P) Ltd., (2011) 52 DTR (P&H) 385; (ii) Commissioner of Income Tax v. Vallabh Yarns (P.) Ltd., (2011) 51 DTR (P&H) 236; (iii) CIT v. Impel Forge & Allied Industries Ltd., (2010) 326 ITR 27 (P&H), (iv) CIT v. Rane (Mad) Ltd., 238 ITR 377 9 Murcery Rubber Mills Vs. ACIT (Mad), and (v) Dy. CIT v. Harjivandas Juthabhai Zaveri & Another, 258 ITR 785 (Gujarat). 13. Keeping in view the activities of the assessee in giving heat treatment for which it had earned labour charges and job-work charges, it can thus be said that the appellant had done a process on the raw material which was…

JCIT (OSD) (TDS)-2(3). MUMBAI, MUMBAI vs. M/S WOCKHARDT LTD, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2012–

ITA 894/MUM/2022[2011-12]Status: DisposedITAT Mumbai21 Nov 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Pranay GandhiFor Respondent: Shri A.B. Koli
Section 133ASection 194ASection 194HSection 201Section 201(1)Section 250

…receivable by the assessee during the course of its business on account of sale, the interest would have to be included as the profits and gains derived from the business of the assessee. An another decision cited therein was CIT v. Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 (Mad.). 10. In the case of Phatela Cotgin Industries (P.) Ltd. (supra) the verdict was that the interest being received on delayed payment on account of sale to customers could clearly be termed to be an income derived from Industrial Undertaking. It was observed that such an interest is distinct from interest income which is bein…

JCIT (OSD) (TDS)-2(3), MUMBAI., MUMBAI. vs. M/S WOCKHARDT LTD , MUMBAI

In the result, the appeal by the Revenue for the assessment year 2012–

ITA 893/MUM/2022[2012-13]Status: DisposedITAT Mumbai21 Nov 2022AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Pranay GandhiFor Respondent: Shri A.B. Koli
Section 133ASection 194ASection 194HSection 201Section 201(1)Section 250

…receivable by the assessee during the course of its business on account of sale, the interest would have to be included as the profits and gains derived from the business of the assessee. An another decision cited therein was CIT v. Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 (Mad.). 10. In the case of Phatela Cotgin Industries (P.) Ltd. (supra) the verdict was that the interest being received on delayed payment on account of sale to customers could clearly be termed to be an income derived from Industrial Undertaking. It was observed that such an interest is distinct from interest income which is bein…

DCIT (TDS)-2(3), MUMBAI vs. WOCKHARDT LIMITED, MUMBAI

Accordingly, the grounds (c) raised by the revenue are dismissed

ITA 6803/MUM/2018[2010-11]Status: DisposedITAT Mumbai11 Dec 2020AY 2010-11

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 6803/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2010-11) Dcit (Tds)-2(3), M/S Wockhardt Ltd. 6Th Floor, Wockhardt Smt. K. G. Mittal बिधम/ Ayurvedic Hospital Bldg. Tower, G Block, Bandra Vs. Room No. 718, 7Th Floor, Kurla Complex, Bandra, Charni Road (W), Mumbai-400 051 Mumbai-400 002 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaacw2472M (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : & C.O. No. 51/Mum/2020 (निर्धारणवर्ा / Assessment Year: 2010-11) M/S Wockhardt Ltd. Dcit (Tds)-2(3), 6Th Floor, Wockhardt Smt. K. G. Mittal बिधम/ Tower, G Block, Bandra Ayurvedic Hospital Bldg. Vs. Room No. 718, 7Th Floor, Kurla Complex, Bandra, Charni Road (W), Mumbai-400 051 Mumbai-400 002 (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Anand Mohan, Dr प्रत्यथीकीओरसे/Respondentby : Shri Kirit Kamdar, Ar सुनवाईकीतारीख/ : 02.11.2020 Date Of Hearing घोषणाकीतारीख / : 11.12.2020 Date Of Pronouncement

For Appellant: Shri Anand Mohan, DRFor Respondent: Shri Kirit Kamdar, AR
Section 133ASection 194ASection 194HSection 201(1)

…receivable by the assessee during the course of its business on account of sale, the interest would have to be included as the profits and gains derived from the business of the assessee. An another decision cited therein was CIT v. Madras Motors Ltd. [2002] 257 ITR 60 / 122 Taxman 516 (Mad.). 10. In the case of Phatela Cotgin Industries (P.) Ltd. (supra) the verdict was that the interest being received on delayed payment on account of sale to customers could clearly be termed to be an income derived from Industrial Undertaking. It was observed that such an interest is distinct from interest income which is bei…

ACIT (LTU), NEW DELHI vs. M/S HAVELLS INDIA LTD., NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 466/DEL/2011[2007-08]Status: DisposedITAT Delhi25 Aug 2020AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishihavells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Circle-12(1), Civil Lines, New Delhi Cr Building Ip Estate, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Havells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Ltu, Nbcc Plaza, Civil Lines, New Delhi Pusp Vihar, Sector-4, Saket, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Acit (Ltu), Vs. Havells India Ltd, Nbcc Plaza, Pusp Vihar, Sector- 1/7 Ram Kishore Road, 4, Saket, New Delhi Civil Lines, New Delhi Pan: Aaach0351E (Appellant) (Respondent)

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri Saras Kumar, Sr. DR
Section 143(3)Section 144ASection 14ASection 80H

…n under Chapter VI-A of the Act: i. CIT v. Govinda Choudhury and Sons.: 203 ITR 881 (SC) ii. CIT vs. Jindal Polyester And Steel Ltd.: 221 Taxman 30 (All) iii. Nirma Industries Ltd. v. DCIT: 283 ITR 402 (Guj) (SLP dismissed/rejected): CIT v. Madras Motors Ltd: 257 ITR 60 (Mad): 80HH and 80I iv. CIT v. Rane (Madras) Ltd.: 238 ITR 377 (Mad): 80I v. vi. CIT v. Indo Matsushita Carbon Co. Ltd.: 286 ITR 201 (Mad): 80HH Tata Sponge Iron Ltd. v. CIT: 292 ITR 175 (Orissa): 80HH vii. viii. JCIT v. Sidheshwari Paper Udyog Ltd.: 94 ITD 187 (Del. Trib.) (TM): 80IA 145 taxman 22 ix. Joyco India P. Ltd. v. ITO: [2009] 122 T…

M/S HAVELLS INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 6073/DEL/2010[2007-08]Status: DisposedITAT Delhi25 Aug 2020AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishihavells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Circle-12(1), Civil Lines, New Delhi Cr Building Ip Estate, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Havells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Ltu, Nbcc Plaza, Civil Lines, New Delhi Pusp Vihar, Sector-4, Saket, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Acit (Ltu), Vs. Havells India Ltd, Nbcc Plaza, Pusp Vihar, Sector- 1/7 Ram Kishore Road, 4, Saket, New Delhi Civil Lines, New Delhi Pan: Aaach0351E (Appellant) (Respondent)

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri Saras Kumar, Sr. DR
Section 143(3)Section 144ASection 14ASection 80H

…n under Chapter VI-A of the Act: i. CIT v. Govinda Choudhury and Sons.: 203 ITR 881 (SC) ii. CIT vs. Jindal Polyester And Steel Ltd.: 221 Taxman 30 (All) iii. Nirma Industries Ltd. v. DCIT: 283 ITR 402 (Guj) (SLP dismissed/rejected): CIT v. Madras Motors Ltd: 257 ITR 60 (Mad): 80HH and 80I iv. CIT v. Rane (Madras) Ltd.: 238 ITR 377 (Mad): 80I v. vi. CIT v. Indo Matsushita Carbon Co. Ltd.: 286 ITR 201 (Mad): 80HH Tata Sponge Iron Ltd. v. CIT: 292 ITR 175 (Orissa): 80HH vii. viii. JCIT v. Sidheshwari Paper Udyog Ltd.: 94 ITD 187 (Del. Trib.) (TM): 80IA 145 taxman 22 ix. Joyco India P. Ltd. v. ITO: [2009] 122 T…

M/S HAVELLS INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 6072/DEL/2010[2004-05]Status: DisposedITAT Delhi25 Aug 2020AY 2004-05

Bench: Shri Amit Shukla & Shri Prashant Maharishihavells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Circle-12(1), Civil Lines, New Delhi Cr Building Ip Estate, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Havells India Ltd, Vs. Dcit, 1/7 Ram Kishore Road, Ltu, Nbcc Plaza, Civil Lines, New Delhi Pusp Vihar, Sector-4, Saket, Pan: Aaach0351E New Delhi (Appellant) (Respondent) Acit (Ltu), Vs. Havells India Ltd, Nbcc Plaza, Pusp Vihar, Sector- 1/7 Ram Kishore Road, 4, Saket, New Delhi Civil Lines, New Delhi Pan: Aaach0351E (Appellant) (Respondent)

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri Saras Kumar, Sr. DR
Section 143(3)Section 144ASection 14ASection 80H

…n under Chapter VI-A of the Act: i. CIT v. Govinda Choudhury and Sons.: 203 ITR 881 (SC) ii. CIT vs. Jindal Polyester And Steel Ltd.: 221 Taxman 30 (All) iii. Nirma Industries Ltd. v. DCIT: 283 ITR 402 (Guj) (SLP dismissed/rejected): CIT v. Madras Motors Ltd: 257 ITR 60 (Mad): 80HH and 80I iv. CIT v. Rane (Madras) Ltd.: 238 ITR 377 (Mad): 80I v. vi. CIT v. Indo Matsushita Carbon Co. Ltd.: 286 ITR 201 (Mad): 80HH Tata Sponge Iron Ltd. v. CIT: 292 ITR 175 (Orissa): 80HH vii. viii. JCIT v. Sidheshwari Paper Udyog Ltd.: 94 ITD 187 (Del. Trib.) (TM): 80IA 145 taxman 22 ix. Joyco India P. Ltd. v. ITO: [2009] 122 T…

ACIT, CHENNAI vs. M/S TELEDATA INFORMATICS LTD., CHENNAI

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 2427/CHNY/2007[2003-04]Status: DisposedITAT Chennai26 Feb 2020AY 2003-04

Bench: Shri Inturi Rama Rao & Shri Duvvuru R.L.Reddy

For Appellant: Mr.R.Vijayaraghavan, AdvFor Respondent: Mrs.Vijaya Prabha, JCIT
Section 10BSection 143(3)

…on of profit eligible for deduction u/s.10B of the Act, the Ld.CIT(A) following the decision of the Hon’ble Madras High Court in the case of CIT vs. Sundaram Clayton Ltd., reported in 281 ITR 425 and also in the case of IT vs. MM Forgings Ltd., reported in 257 ITR 60 and also the Hon’ble Kerala High Court in the case of CIT vs. Abad Fisheries Ltd., reported in 258 ITR 641 held that the export turnover in respect of the sale proceeds were not received within the stipulated period, should be reduced from both export turnover as well as the total turnover. Similarly, as regards to the allocation of depreciatio…

ACIT CENTRAL CIRCLE 3(1) , CHENNAI vs. PN POWER GENERATING COMPANY P LTD. , CHENNAI

In the result, Ground Nos

ITA 1631/CHNY/2017[2011-12]Status: DisposedITAT Chennai06 Jan 2020AY 2011-12

Bench: Shri George Mathan & Shri Inturi Rama Raoआयकर अपील सं./Ita No.1631/Chny/2017 धनिाजरण वर्ज Assessment Year: 2011-12 The Assistant Commissioner Of M/S. Ppn Power Generating Income Tax, Company P. Limited, Central Circle 3 (1), Vs. Jhaver Plaza, Iii Floor, No.46, Nungambakkam High Road, No.1A, Nungambakkam High Chennai – 600 034. Road, Chennai – 600 034 [Pan: Aabcp 8131D] (अपीलार्थी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/ Appellant By : Mr. A. Sundararajan, Addl.Cit प्रत्यथी की ओर से /Respondent By : Mr. S. Vidya, Advocate सुनवाई की तारीख/Date Of Hearing : 06.01.2020 घोर्णा की तारीख /Date Of Pronouncement : 06.01.2020 आदेश / O R D E R Per George Mathan: This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3 Chennai In I.T.A. No.98/2015-16/Cit(A)-3 Dated 28.03.2017 For The Assessment Year 2011- 12. 2. Mr. A. Sundararajan, Additional Cit Represented On Behalf Of The Revenue & Mr. S. Vidya Represented On Behalf Of The Assessee. :- 2 -:

For Appellant: Mr. A. Sundararajan, Addl.CITFor Respondent: Mr. S. Vidya, Advocate

…tive basis. It was a submission that on appeal the learned CIT(A) had :- 3 -: followed the principles laid down by the Hon’ble Jurisdictional High Court in the case of Commissioner of Income Tax vs. M/s. Madras Motors Limited/M.M. Forgings Limited reported in 257 ITR 60 (Mad.), wherein it has been held that the interest being directly relatable only to the amount receivable by the assessee during the course of its business on account of the sale of forging, the said interest would have to be included as the profit and gains derived from the business of the assessee. Consequently, the learned CIT(A) has held that…

ITO 2(1)(1), MUMBAI vs. ABBOTT INDIA LTD, MUMBAI

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

ITA 4881/MUM/2010[2004-05]Status: DisposedITAT Mumbai24 Aug 2018AY 2004-05
Section 143(2)Section 143(3)Section 14ASection 35ASection 80HSection 80I

…ipts for AY 1998-99, because the assessee did not press the issue, but fact remains that cash discount received from customers forms part of receipts eligible for deduction u/s 80I & 80IA as the Hon’ble Madras High Court in the case of CIT vs Madras Motors 257 ITR 60 has considered similar issue and held that cash discount is part of receipts being eligible for deductions u/s 80I & 80IA of the Income-tax Act, 1961. 13. We have heard both the parties and perused material available on record. The ITAT has considered interest from customers on delayed payments in the light of provisions of sections 80I & 80IA a…

DCIT, CIR.7(1)(1), MUMBAI vs. GALA PRECISION TECHNOLOGY PVT. LTD., THANE

In the result, appeal of the Revenue is dismissed

ITA 2675/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Jun 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Bleasst. Commissioner Of Income-Tax, V. M/S. Gala Precision Technology Pvt. Ltd. Circle – 7(1)(1), Room No. 23, 102-A, Orion Business Park, Near Cine Ground Floor, Aayakar Bhavan, Wonder, Ghodbunder Road, Thane (W) M.K.Road, Mumbai-400 020 Pan No: Aaacg 1777 F

For Appellant: Shri Vijay MehtaFor Respondent: Shri V. Vidhyadhar
Section 10BSection 143(3)Section 80H

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI N.K. PRADHAN, HON'BLE ACCOUNTANT MEMBER Asst. Commissioner of Income-tax, v. M/s. Gala Precision Technology Pvt. Ltd. Circle – 7(1)(1), Room No. 23, 102-A, Orion Business Park, Near Cine Ground Floor, Aayakar Bhavan, Wonder, Ghodbunder Road, Thane (W) M.K.Road, Mumbai-400 020 PAN NO: AAACG 1777 F (Appellant) (Respondent) Assessee by : Shri Vijay Mehta Department by : Shri V. Vidhyadhar Date of Hearing : 05.04.2018 Date of Pronouncement : 20.06.2018 O R D E R PER C.N. PRASAD 1. This appeal if…

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CIT v. Madras Motors Ltd. (257 ITR 60) — Cited in 49 Judgments | BharatTax