CIT v. Mahalakshmi Textile Mills Ltd.

66 ITR 710Supreme Court of India1967#1231 most cited

What is CIT v. Mahalakshmi Textile Mills Ltd. authority for?

Income tax law intends to avoid double taxation, and where an item is brought to tax in one form, appropriate relief or adjustment should be provided to prevent its taxation again in another form. This principle is applicable when considering government grants or subsidies included in income and their impact on the actual cost of assets for depreciation.

93

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. Mahalakshmi Textile Mills Ltd. · 66 ITR 710 · double taxation · alternate relief · government grants · subsidies · section 2(24)(xviii) · section 43(1) · section 32 · definition of income · actual cost · depreciation

Also reported as

3 SCR 957

Sections most often in play

Section 2(24)(xviii)Section 36(1)(va)Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 43(1)Section 148

Issues it is cited on

section 2(24)(xviii)section 143(1)(a)(ii)section 43(1)icdscomputer softwaresection 2(24)(x)section 2(24)section 143(1)(a)liable to taxsection 32section 36(1)(va)section 145

Judgments citing CIT v. Mahalakshmi Textile Mills Ltd.

VNG AUTOMOTIVE P. LTD. vs. ASSTT. COMMISSIONER OF INCOME

The appeals are disposed of as allowed

ITA-795/2004HC Delhi10 Apr 2026
For Appellant: Mr. Satyen Sethi & Mr. Arta Trana PandaFor Respondent: Mr Abhishek Maratha, SSC, Mr Apoorv
Section 148

…h Court held the action of the CIT(A) to be unjustified. He has also relied on the judgment in the case of CIT v. Lakshmi Vilas Bank, (2010) 329 ITR 591 (Mad), to support his case. 20. He submitted that, in CIT v. Mahalakshmi Textile Mills Ltd., (1967) 66 ITR 710 (SC), the expenditure on “Casablanca conversion bsystem” involving replacement was held to be allowable, not as „installation of new machinery‟ as claimed but as „current repairs‟ to the existing machinery. The Supreme Court while dealing with powers of the Tribunal, held as under: “If for reasons recorded by the departmental authorities in…

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

…Shareholders, Income Tax Appeal No. 3908 of 2010, dt. 21st June, 2012; ii. Anchor Pressings (P.) Ltd vs. CIT [1986] 27 Taxman 295 (SC); iii. CIT vs. Mahalaxmi Sugar Mills Co. Ltd., [1986] 27 Taxman 267 (SC); iv. CIT vs. Mahalakshmi Textile Mills Ltd., [1967] 66 ITR 710 (SC); v. CIT vs. Bharat Aluminium Co. Ltd.,[2007] 163 Taxman 430 (Delhi); vi. Dilip Dharmsey Khatau vs. ITO [2017] 83 taxmann.com 21 (Mumbai – Trib.]; vii. Van Oord Atlanta B.V. vs. ADIT [2008] 23 SOT 29 (Kolkata) (URO) 8. Per contra, the Ld. CIT-DR submitted that the case of the assessee was selected for limited scrutiny to examine double taxati…

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

…Shareholders, Income Tax Appeal No. 3908 of 2010, dt. 21st June, 2012; ii. Anchor Pressings (P.) Ltd vs. CIT [1986] 27 Taxman 295 (SC); iii. CIT vs. Mahalaxmi Sugar Mills Co. Ltd., [1986] 27 Taxman 267 (SC); iv. CIT vs. Mahalakshmi Textile Mills Ltd., [1967] 66 ITR 710 (SC); v. CIT vs. Bharat Aluminium Co. Ltd.,[2007] 163 Taxman 430 (Delhi); vi. Dilip Dharmsey Khatau vs. ITO [2017] 83 taxmann.com 21 (Mumbai – Trib.]; vii. Van Oord Atlanta B.V. vs. ADIT [2008] 23 SOT 29 (Kolkata) (URO) 8. Per contra, the Ld. CIT-DR submitted that the case of the assessee was selected for limited scrutiny to examine double taxati…

SHRI NARAYAN RAO HEBRI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal stands dismissed

ITA/166/2025HC Karnataka20 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 115BSection 133ASection 143(2)Section 260Section 260A

…- 1 - ITA No. 166 of 2025 Reserved on : 20.01.2026 Pronounced on : 20.02.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 20TH DAY OF FEBRUARY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL No. 166 OF 2025 BETWEEN: 1. SHRI NARAYAN RAO HEBRI, (PAN: AASPH2926A; S/O SHRI DHUMANNA, AGE ABOUT 71 YEARS) (RESIDING AT No.1, CHINNA, S. N. NAGAR MAIN ROAD, SAGAR 577204). …APPELLANT (BY SRI K.K. CHYTHANYA, SENIOR COUNSEL A/W SRI TATA KRISHNA, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIO…

MR POPATRAO DASHRATHRAO SURYAWANSHI,PUNE vs. INCOME TAX OFFICER, WARD-7(4), PUNE, PUNE

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

ITA 234/PUN/2024[2017-18]Status: DisposedITAT Pune21 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mr. Popatrao Dashrathrao Suryawanshi Ito, Ward 7(4), Pune S.No.38, Tingre Nagar, Havaldar Mala, Vs. Vishrantwadi, Pune – 411015 Pan: Adhps2643F (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Manish Mehta, Addl.Cit Date Of Hearing : 19-01-2026 Date Of Pronouncement : 21-01-2026 O R D E R

For Appellant: Shri Suhas BoraFor Respondent: Shri Manish Mehta, Addl.CIT
Section 142(1)Section 143(2)Section 45(2)Section 54BSection 54F

…ha Foundation Pvt Ltd. vide ITA No.811 of 2016 dated 06.06.2017 iv) Sanchit Software & Solutions (P.) Ltd. Vs. CIT (2021) 349 ITR 404 (Bom) 16. Referring to the decision of Hon’ble Supreme Court in the case of CIT vs Mahalakshmi Textile Mills Ltd reported in 66 ITR 710 (SC) and the decision of 10 Hon’ble Bombay High Court in the case of Ciba of India Ltd vs. CIT reported in 70 Taxman 505 (Bom), he submitted that the assessee can raise an alternate plea / ground before the Tribunal even if not raised earlier. 17. The Ld. Counsel for the assessee submitted that both the lower authorities have given a concurrent f…

DCIT CENTRAL CIRCLE 1 DELHI, DELHI vs. SAHARA INDIA FINANCIAL CORPORATION LTD, LUCKNOW

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11
Section 142Section 250Section 269SSection 271D

…mean that the respondent should be denied the opportunity of supporting a decision in his favour which has come up on appeal on a ground decided against him by the authority whose decision is challenged. 3.2 In CIT v. Mahalakshmi Textile Mills Ltd reported in 66 ITR 710 (SC), after referring to the corresponding provision in the 1922 Act (section 33 (4) of the Act), the Hon'ble Supreme Court held as follows: "Under sub-section (4) of section 33 of the Indian Income-tax Act, 1922, the Appellate Tribunal is competent to pass such orders on the appeal 'as it thinks fit'. There is nothing in the Income-tax Act which…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25 NEW DELHI, DELHI vs. FARIDABAD PRESSWELL PVT LTD, DELHI

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

…an that the respondent should be denied the opportunity of supporting a decision in his favour which has come up on appeal on a ground decided against him by the authority whose decision is challenged. 5.2 In CIT v. Mahalakshmi Textile Mills Ltd reported in 66 ITR 710 (SC), after referring to the corresponding provision in the 1922 Act (section 33 (4) of the Act), the Hon’ble Supreme Court held as follows: "Under sub-section (4) of section 33 of the Indian Income-tax Act, 1922, the Appellate Tribunal is competent to pass such orders on the appeal ‘as it thinks fit’. There is nothing in the Income-tax Act whi…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…therwise it will result in double\ntaxation. In this regard reliance is placed on the judgement of the\nHon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd.\n\n7\nShriniwas Engineering Auto\nComponents Pvt. Ltd.\nA.Ys.2016-17 to 2020-21\n[1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in\nthe case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay).\n\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\n\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applica…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…elief. Otherwise it will result in double taxation. In this regard reliance is placed on the judgement of the Hon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd. Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 [1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in the case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable fro…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…Otherwise it will result in double\ntaxation. In this regard reliance is placed on the judgement of the\nHon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd.\n7\nShriniwas Engineering Auto\nComponents Pvt. Ltd.\nA.Ys.2016-17 to 2020-21\n[1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in\nthe case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay).\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applicable…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…elief. Otherwise it will result in double taxation. In this regard reliance is placed on the judgement of the Hon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd. Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 [1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in the case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable fro…

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…elief. Otherwise it will result in double taxation. In this regard reliance is placed on the judgement of the Hon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd. Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 [1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in the case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable fro…

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…elief. Otherwise it will result in double taxation. In this regard reliance is placed on the judgement of the Hon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd. Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 [1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in the case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable fro…

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…elief. Otherwise it will result in double taxation. In this regard reliance is placed on the judgement of the Hon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd. Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 [1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in the case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable fro…

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025
Section 2(24)(xviii)Section 43

…Otherwise it will result in double\ntaxation. In this regard reliance is placed on the judgement of the\nHon'ble Supreme Court in the case of Mahalakshmi Textile Mills Ltd.\n7\nShriniwas Engineering Auto\nComponents Pvt. Ltd.\nA.Ys.2016-17 to 2020-21\n[1967] 66 ITR 710 (SC) and the judgement of Bombay High Court in\nthe case of Ciba of India Ltd. (1989) 47 Taxman 366 (Bombay).\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applicable…

SHRI RAGHVENDRA MOHTA,KOLKATA vs. ACIT, CIRCLE - 36, KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 2416/KOL/2017[2014-15]Status: DisposedITAT Kolkata08 Apr 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri Miraj D. Shah, AdvocateFor Respondent: Shri P. P. Barman, Addl. CIT, Sr. DR
Section 10(38)Section 143(2)Section 143(3)Section 14ASection 68Section 69CSection 94(7)

…adjudicating the same. He placed reliance on the decision of Hon’ble Supreme Court in the case of National Thermal Power Corporation Ltd. Vs. CIT (1998) 229 ITR 383 (SC). He also placed reliance on the decision of CIT Vs. Mahalaxmi Textiles Mills Ltd. (1967) 66 ITR 710 (SC) whereby even if such additional ground is not taken in appeal memo or before lower authorities , appellate authority has jurisdiction to entertain an alternative plea raised during hearing of the appeal. On confronting the submission to the Ld. Sr. DR, nothing objectionable was submitted on its admission. Accordingly, this additional ground r…

MOHAN KUMAR ROY,KOLKATA vs. ITO, WARD 29(1), KOLKATA

In the result, both the appeals filed by the assessee are allowed

ITA 104/KOL/2022[2012-13]Status: DisposedITAT Kolkata22 Sept 2023AY 2012-13

Bench: Sri Rajesh Kumar & Sonjoy Sarma

Section 143(3)Section 148Section 254Section 68

…r authorities the appellate authority has jurisdiction to entertain and alternatively be raised during the course of hearing which is in consonance with the ratio laid down by the Hon'ble Apex Court in the case of CIT Vs. Mahalakshmi Textile Mills Ltd. [1967] 66 ITR 710 (SC) wherein the Hon'ble Court has held as under: “There is nothing in the Income-tax Act which restricts the Tribunal to the determination of questions raised before the departmental authorities. All questions whether of law or of fact which relate to the assessment of the assessee may be raised before the Tribunal: If for reasons recorded by th…

MOHAN KUMAR ROY,KOLKATA vs. ITO, WARD 29(1), KOLKATA

In the result, both the appeals filed by the assessee are allowed

ITA 103/KOL/2022[2012-13]Status: DisposedITAT Kolkata22 Sept 2023AY 2012-13

Bench: Sri Rajesh Kumar & Sonjoy Sarma

Section 143(3)Section 148Section 254Section 68

…r authorities the appellate authority has jurisdiction to entertain and alternatively be raised during the course of hearing which is in consonance with the ratio laid down by the Hon'ble Apex Court in the case of CIT Vs. Mahalakshmi Textile Mills Ltd. [1967] 66 ITR 710 (SC) wherein the Hon'ble Court has held as under: “There is nothing in the Income-tax Act which restricts the Tribunal to the determination of questions raised before the departmental authorities. All questions whether of law or of fact which relate to the assessment of the assessee may be raised before the Tribunal: If for reasons recorded by th…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 2(1), BILASPUR vs. M/S JILA SAHKARI KENDRIYA BANK MARYADIT, BILASPUR

In the result, the appeal filed by the revenue is allowed in terms of our aforesaid observations

ITA 92/RPR/2018[2012-13]Status: DisposedITAT Raipur04 Jul 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 92/Rpr/2018 "नधा"रण वष" / Assessment Year : 2012-13 The Assistant Commissioner Of Income Tax, Circle-2(1), Bilaspur .......अपीलाथ" / Appellant बनाम / V/S. M/S. Jila Sahakari Kendriya Bank Maryadit, Sahakari Bhawan, Nehru Chowk, Bilaspur (C.G.) Pan : Aaaaj0607P ……""यथ" / Respondent

For Appellant: Shri Nikhilesh Begani, CAFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 263(1)

…d. (1973) 89 ITR 266 (SC) (viii) CIT Vs. Suman Dhamija (2016) 382 ITR 343 (SC) (ix) CIT Vs. Bechtel International Inc. (2019) 414 ITR 558 (Bom. HC) (x) CIT Vs. Asea Brown Boveri Ltd. (2020) 427 ITR 166 ( Kar.HC) (xi) CIT Vs. Mahalaxmi Textile Mill Ltd. (1967) 66 ITR 710 (SC) (xii) Wipro Finance Ltd. Vs. CIT (2022) 443 ITR 250 (SC) Our attention was specifically drawn by the Ld. AR to the judgment of the Hon’ble High Court of Bombay in the case of CIT (International Taxation) Vs. Bechtel International Inc. (2019) 414 ITR 558 (Bom. HC). Referring to the aforesaid judicial pronouncement, it was submitted by the Ld.…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed and appeal filed by the revenue is dismissed

ITA 3178/MUM/2019[2011-12]Status: DisposedITAT Mumbai28 Feb 2023AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 14Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON'BLE JUDICIAL MEMBER ITA.No. 3139/MUM/2019 (A.Y. 2011-12) M/s. ACC Ltd., V. Deputy CIT (LTU) 29th Floor, Centre-1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) ITA.No. 3178/MUM/2019 (A.Y. 2011-12) DCIT (LTU)-1 V. M/s. ACC Ltd., 29th Floor, Centre No.1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AA…

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