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

Expenses incurred for community development, even if not directly linked to business operations, can be considered allowable business expenditure if they foster goodwill and are part of evolving business practices.

How many judgments cite CIT v. Madras Refineries Ltd.?

94 judgments on BharatTax cite CIT v. Madras Refineries Ltd. (266 ITR 170), spanning 2013 to 2026.

Which sections of the Income Tax Act does CIT v. Madras Refineries Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 37(1), Section 115JB, Section 135, Section 143(3), Section 154.

CIT v. Madras Refineries Ltd. (266 ITR 170)

Rane Engine Valves Limited, Chennai vs. DCIT, Chennai

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

ITA 1498/CHNY/2017[2012-13]Status: DisposedITAT Chennai03 Jul 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri G. Suresh, JCIT

Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं"ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1497, 1498/CHNY/2017, 1477, 2815/CHNY/2018 & 885/CHNY/2020 िनधा"रण वष"/Assessment Years:2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 Rane Engine Valve Limited, The Deputy Commissioner of “Maithri”, No.132, Vs. Income Tax, Cathedral Road, Corporate Circle 5(1), Chennai – 600 086. Chennai. PAN: AAACT 1279M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क"…

Rane Engine Valves Limited, Chennai vs. DCIT, Chennai

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

ITA 1497/CHNY/2017[2011-12]Status: DisposedITAT Chennai03 Jul 2024AY 2011-12

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri G. Suresh, JCIT

Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं"ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1497, 1498/CHNY/2017, 1477, 2815/CHNY/2018 & 885/CHNY/2020 िनधा"रण वष"/Assessment Years:2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 Rane Engine Valve Limited, The Deputy Commissioner of “Maithri”, No.132, Vs. Income Tax, Cathedral Road, Corporate Circle 5(1), Chennai – 600 086. Chennai. PAN: AAACT 1279M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क"…

Tata Chemicals Ltd, Mumbai vs. Addl Ciat 2(3), Mumbai

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

ITA 120/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Nov 2023AY 2008-09

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

Section 144C(5)Section 14ASection 43BSection 80

…MUM/2013 (A.Y: 2008-09) Tata Chemicals Ltd development of the community where the manufacturing facility exists is for the smooth carrying on of its business. In this regard, attention is invited to judgment of the Madras High Court in Madras Refinery Limited 266 ITR 170. Prior to the insertion of the limitation by way of Explanation 2 below section 37(1) of the Act by the Finance (No. 2) Act, 2014 w.e.f. 01.04.2015, it has been accepted that expenditure under the Corporate Social Responsibility was an allowable expenditure. This expenditure would be primarily for the community at large and not restricted to the…

Dy CIT CC 1(4), Mumbai vs. M/S Ultratech Cement Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 931/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

…the Hon' ble jurisdictional High Court in CIT v. Indian Rayon and Industries Ltd. 336 ITR 479 and PCIT v. Indian Oil Corporation Ltd. being Order dated 11.02.2019 in Income Tax Appeal No. 1765 of 2016 and the Madras High Court in CIT v. Madras Refineries Ltd.266 ITR 170. Based thereon, it is urged that the capital assets used to support the schools and the hospitals in the facts of the present case has been used for the purposes of its business.” 20. On the other hand, Ld.DR relied on the order of the lower authorities. 21. Considered the rival submissions and material placed on record, we observe that the ass…

Ultratech Cement Ltd, Mumbai vs. DCIT CC 1(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 465/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

…the Hon' ble jurisdictional High Court in CIT v. Indian Rayon and Industries Ltd. 336 ITR 479 and PCIT v. Indian Oil Corporation Ltd. being Order dated 11.02.2019 in Income Tax Appeal No. 1765 of 2016 and the Madras High Court in CIT v. Madras Refineries Ltd.266 ITR 170. Based thereon, it is urged that the capital assets used to support the schools and the hospitals in the facts of the present case has been used for the purposes of its business.” 20. On the other hand, Ld.DR relied on the order of the lower authorities. 21. Considered the rival submissions and material placed on record, we observe that the ass…

U C I L, Jadugoda vs. ACIT, Circle-3, Jamshedpur

In the result, the appeal of the revenue is dismissed

ITA 385/RAN/2018[14-15]Status: DisposedITAT Ranchi11 May 2023

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleita Nos.384 & 385/Ran/2018 Assessment Year: 2013-14 & 2014-15 M/S. Uranium Corporation Of Acit, Circle -(3), India Ltd. Jamshedpur Vs Jadugoda Mines, Jadugoda, East Singhbhum-832102, Jharkhand. Pan: Aaacu 2207 N (Appellant) (Respondent) Present For: Appellant By : Shri P.K. Barman With Arijit Bhattacherjee, Ar Respondent By : Smt. Rinku Singh, Cit, Dr Date Of Hearing : 03.05.2023 Date Of Pronouncement : 11.05.2023 O R D E R Per Sonjoy Sarma, Jm: The Captioned Appeals Are Filed By The Assessee Are Directed Against The Order Of Ld. Cit(A), Jamshedpur Vide Order Dated 07.10.2016 & 12.09.2017 Respectively For The A.Y. 2013-14 & 2014-15. The Assessee Has Raised Following Grounds Of Appeal For Each Of The Assessment Year Under Consideration: A.Y. 2013-14 “I. For That The Learned Lower Authorities Are Not Justified In Disallowing Rs. 2,23,90,022/- Under The Head Corporate Social Responsibility U/S 37(1) Of The Income-Tax Act, 1961 As The Same Was Altogether In The Past Allowed By The Income Tax Department/Hon’Ble Itat & Consequently The Addition Of Rs. 2,23,90,022/- Is Liable To Be Deleted In To-To.”

For Appellant: Shri P.K. Barman with Arijit Bhattacherjee, ARFor Respondent: Smt. Rinku Singh, CIT, DR

Section 143(1)Section 143(2)Section 37(1)

…nducting medical camps in many villages. The company has a corporate responsibility and company required to spend certain amount towards corporate responsibility. As per the judicial rulings relied upon by the assessee in the case of Madras Refineries Limited 266 ITR 170, the Hon’ble Madras High Court held as under: CIT v. Madras Refineries Ltd. [2004] 266 JTR 1701138 Taxman 261 (Mad). 'The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large and the people of the locality in which the business is lo…

M/S. U C I L, Jadugoda vs. ACIT, Circle-3, Jamshedpur

In the result, the appeal of the revenue is dismissed

ITA 384/RAN/2018[13-14]Status: DisposedITAT Ranchi11 May 2023

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleita Nos.384 & 385/Ran/2018 Assessment Year: 2013-14 & 2014-15 M/S. Uranium Corporation Of Acit, Circle -(3), India Ltd. Jamshedpur Vs Jadugoda Mines, Jadugoda, East Singhbhum-832102, Jharkhand. Pan: Aaacu 2207 N (Appellant) (Respondent) Present For: Appellant By : Shri P.K. Barman With Arijit Bhattacherjee, Ar Respondent By : Smt. Rinku Singh, Cit, Dr Date Of Hearing : 03.05.2023 Date Of Pronouncement : 11.05.2023 O R D E R Per Sonjoy Sarma, Jm: The Captioned Appeals Are Filed By The Assessee Are Directed Against The Order Of Ld. Cit(A), Jamshedpur Vide Order Dated 07.10.2016 & 12.09.2017 Respectively For The A.Y. 2013-14 & 2014-15. The Assessee Has Raised Following Grounds Of Appeal For Each Of The Assessment Year Under Consideration: A.Y. 2013-14 “I. For That The Learned Lower Authorities Are Not Justified In Disallowing Rs. 2,23,90,022/- Under The Head Corporate Social Responsibility U/S 37(1) Of The Income-Tax Act, 1961 As The Same Was Altogether In The Past Allowed By The Income Tax Department/Hon’Ble Itat & Consequently The Addition Of Rs. 2,23,90,022/- Is Liable To Be Deleted In To-To.”

For Appellant: Shri P.K. Barman with Arijit Bhattacherjee, ARFor Respondent: Smt. Rinku Singh, CIT, DR

Section 143(1)Section 143(2)Section 37(1)

…nducting medical camps in many villages. The company has a corporate responsibility and company required to spend certain amount towards corporate responsibility. As per the judicial rulings relied upon by the assessee in the case of Madras Refineries Limited 266 ITR 170, the Hon’ble Madras High Court held as under: CIT v. Madras Refineries Ltd. [2004] 266 JTR 1701138 Taxman 261 (Mad). 'The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large and the people of the locality in which the business is lo…

Mecon Limited, Ranchi vs. ACIT Circle-2, Ranchi

In the result, the appeal of the assessee is allowed

ITA 232/RAN/2017[13-14]Status: DisposedITAT Ranchi22 Feb 2023

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 135Section 37(1)

…citizen brings goodwill of the local community as also with the regulatory agencies and society at large, thereby creating an atmosphere in which the business can succeed in a greater measure with the aid of such goodwill (CIT v. Madras Refineries Ltd. [2004]266 ITR 170, Sri Venkata Satyanarayna Rice Mill Contractors Co. v. CIT [1997] 223 ITR 101, Hindustan Petroleum Corporation Ltd Vs DCIT [(2005) 96 ITO 186 (Bom)] (iii) The amendment in the scheme of Section 37(1), which has been introduced with effect from 1st April 2015, cannot be construed as to disadvantage to the assessee in the period prior to this amen…

Commissioner of Income Tax, Kol-III vs. M/S. Indian Aluminium Co. Ltd

In the result, the appeals filed by the revenue

ITA/96/2007HC Calcutta05 Jan 2023

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 5Th January, 2023 Appearance : Mr. Om Narain Rai, Adv. …For The Revenue. Mr. J.P. Khaitan, Sr. Adv. Ms. Arati Agarwal, Adv. Ms. Rosy Banerjee, Adv. Mr. Binayak Gupta, Adv. …For The Assessee The Court : These Appeals Filed By The Revenue As Well As The Assessee Under Section 260A Of The Income Tax Act, 1961 (The Act) Are Directed Against The Order Dated October 20, 2006, Passed By The Income Tax Appellate Tribunal `A’ Bench, Kolkata (Tribunal) In Ita 1221/Kol./2006 & Ita 1045/Kol./2006, For The Assessment Year 2002-03. The Appeal Being Ita 173 Of 2007 Was Admitted On 7Th May, 2008 On The Following Substantial Questions Of Law :- “Whether On The Facts & In The Circumstances Of The Case The Learned Tribunal Was Justified In Law In Not Allowing :

Section 14ASection 260ASection 36(1)(iii)Section 43BSection 80I

…ported in 100 Taxman 278 and the judgment delivered in the case of Eicher Motors Ltd. reported in 82 TTJ 61, (v) a sum of Rs. 51,86,256/- incurred by the appellant on community development without considering the decision of the Madras High Court reported in 266 ITR 170 and the decision of the Karnataka High Court reported in 166 ITR 866 and the Tribunal’s decision reported in 96 ITD 186, (vi) The contribution made towards person scheme under Section 43B of the Act before filing of the return by the appellant without considering the judgments reported in 284 ITR 619, 100 ITD 199(2004) 1 SOT 210, (vii) A part o…

Indian Aluminium Company Limited vs. Commissioner of Income Tax

In the result, the appeals filed by the revenue

ITA/173/2007HC Calcutta05 Jan 2023

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 5Th January, 2023 Appearance : Mr. Om Narain Rai, Adv. …For The Revenue. Mr. J.P. Khaitan, Sr. Adv. Ms. Arati Agarwal, Adv. Ms. Rosy Banerjee, Adv. Mr. Binayak Gupta, Adv. …For The Assessee The Court : These Appeals Filed By The Revenue As Well As The Assessee Under Section 260A Of The Income Tax Act, 1961 (The Act) Are Directed Against The Order Dated October 20, 2006, Passed By The Income Tax Appellate Tribunal `A’ Bench, Kolkata (Tribunal) In Ita 1221/Kol./2006 & Ita 1045/Kol./2006, For The Assessment Year 2002-03. The Appeal Being Ita 173 Of 2007 Was Admitted On 7Th May, 2008 On The Following Substantial Questions Of Law :- “Whether On The Facts & In The Circumstances Of The Case The Learned Tribunal Was Justified In Law In Not Allowing :

Section 14ASection 260ASection 36(1)(iii)Section 43BSection 80I

…ported in 100 Taxman 278 and the judgment delivered in the case of Eicher Motors Ltd. reported in 82 TTJ 61, (v) a sum of Rs. 51,86,256/- incurred by the appellant on community development without considering the decision of the Madras High Court reported in 266 ITR 170 and the decision of the Karnataka High Court reported in 166 ITR 866 and the Tribunal’s decision reported in 96 ITD 186, (vi) The contribution made towards person scheme under Section 43B of the Act before filing of the return by the appellant without considering the judgments reported in 284 ITR 619, 100 ITD 199(2004) 1 SOT 210, (vii) A part o…

Mecon Ltd, Ranchi vs. DCIT Cir-2, Ranchi

In the result, the appeal of the assessee is allowed

ITA 267/RAN/2017[14-15]Status: DisposedITAT Ranchi23 Nov 2022

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 135Section 37(1)

…citizen brings goodwill of the local community as also with the regulatory agencies and society at large, thereby creating an atmosphere in which the business can succeed in a greater measure with the aid of such goodwill (CIT v. Madras Refineries Ltd. [2004]266 ITR 170, Sri Venkata Satyanarayna Rice Mill Contractors Co. v. CIT [1997] 223 ITR 101, Hindustan Petroleum Corporation Ltd Vs DCIT [(2005) 96 ITO 186 (Bom)] 4 AY: 2014-15 Mecon Limited (iii) The amendment in the scheme of Section 37(1), which has been introduced with effect from 1st April 2015, cannot be construed as to disadvantage to the assessee in t…

Super Seeds Pvt. Ltd., Ahmedabad vs. The DCIT, Circle-4(1)(1), Ahmedabad

In the result, Ground Number 2 of the appeal of the assessee is dismissed

ITA 260/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad19 Oct 2022AY 2015-16

Bench: Of The Final Hearing Of Appeal

For Appellant: NoneFor Respondent: Shri Shramdeep Sinha, Sr. D.R

Section 35Section 36(1)(va)

…separately for furnishing inaccurate particulars of income. (Addition of Rs.91,215/-)” 6. In appeal, the ld. CIT(A) confirmed the addition by holding that the issue is squarely covered by the judgment of Hon’ble Gujarat High Court in the case of CIT vs. GSRT 266 ITR 170 (Guj). While passing the order, the ld. CIT(A) made the following observations:- “6.1 I find that the issue is squarely covered by the judgment of Hon'ble High Court of Gujarat in the case of CIT v. GSRTC [2014] 366 ITR 170 (Gujarat), this case Hon'ble High Court have comprehensively dealt with the issue. The relevant part of the judgment is rep…

DCIT, Bhubaneswar vs. Serajuddin & Co., Kolkata

In the result, appeals of the revenue in ITA No

ITA 368/CTK/2015[2011-12]Status: HeardITAT Cuttack30 Sept 2022AY 2011-12

Bench: Shri George Mathan & Shri Arun Khodpia

…bligation, is allowable as business expenditure. Merely because an expenditure is in the nature of donation, it does not cease to be an expenditure deductible under s. 37(1)." 9.7 The Commissioner of Income tax had mentioned in his order that "the Apex Court (313 ITR 334 SC) CIT Vs Madras Refineries Ltd., while hearing the allowability of CSR expenses observed that neither the High Court nor the Tribunal concerned had given specific finding to the effect that the said CSR expenditure is allowable as business expenditure ". In the above mentioned case, the Apex court has not given any decision on merits of the cas…