CIT v. Mahendra Sobhagchand Shah

203 ITR 857High Court1993#5226 most cited

What is CIT v. Mahendra Sobhagchand Shah authority for?

A pro-rata allocation of administrative expenditure is permissible when determining income eligible for deduction under section 80M, allowing the assessee's grounds while dismissing those of the revenue.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

CIT v. Mahendra Sobhagchand Shah · section 80M · administrative expenditure · pro-rata allocation · eligible income · business deductions · income tax act

Sections most often in play

Section 115JBSection 115USection 14ASection 244ASection 271(1)(c)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

Issues it is cited on

section 50(1)section 80absection 54esection 70(2)section 10(15)section 80msection 10(33)section 14a(1)section 54eclong-term capital assetsection 36(1)(viii)section 111a

Judgments citing CIT v. Mahendra Sobhagchand Shah

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

ITA 2980/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Jan 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate a

…re. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - HDFC Bank Ltd. 14. 1. Fact of the matter is th…

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

ITA 2665/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jan 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Section 143(3)

…iture. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year | Ground No. in Assessee's appeal | Ground No. in Revenue's appeal ---|---|--- 2003-04 | 4 | - 14. 1. Fact of the matter is that ass…

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LIMITED (MERGED ENTITY HOUSING DEVELOPMENT FINANCE CORPORATION LIMITED), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below:\n\nSr

ITA 2597/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Jan 2025AY 2020-21

…Thus, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions:\n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom)\n\ni) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal)\n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom)\n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals:\n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n2003-04 \n4 \n-\n\nHDFC Bank Ltd. \nITA No.4315/MUM/20…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2049/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

…expenditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13.6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 2020…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2047/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 Jan 2025AY 2018-19

…e. Thus, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n13. 6. Our findings are fortified by the following decisions: \ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \nVI. Deduction of income by the amount credited to lease \nequalization account. \n14. This issue arises in the following appeals: \n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n2003-04 \n4 \n- \n54 \nHDFC Bank Ltd. \nITA No.4315/MUM/200…

ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 2046/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-2018

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

…ure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - 14. 1. Fact of the matter is that assessee credit…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

ITA 1890/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi

…re. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - 14. 1. Fact of the matter is that assessee cred…

DCIT RANGE-1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 5110/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…s, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n\n2003-04 4 \n\n54 \nHDFC Bank Ltd. \nITA No.4315/M…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RANGE-1(1)(2), MUMBAI

ITA 4983/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…ure. Thus, grounds taken by the Revenue are\ndismissed and those by the assessee are allowed.\n\n13. 6. Our findings are fortified by the following decisions:\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom)\nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal)\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom)\n\nVI. Deduction of income by the amount credited to lease\nequalization account.\n\n14. This issue arises in the following appeals:\n\n Assessment year\nGround No. in\nAssessee's appeal\nGround No. in Revenue's\nappeal\n2003-04\n4\n-\n\n\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and…

DCIT - 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORARTION LTD., MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

ITA 2861/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Jan 2025AY 2011-12

…, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\ni i) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n2003-04 \n4 \n-\n\n54 \nHDFC Bank Ltd. \nITA No.431…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

ITA 2609/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Jan 2025AY 2011-12

…s, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n2003-04 \n4 \n-\n\n54 \nHDFC Bank Ltd. \nITA No.431…

DCIT 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

Accordingly, ground so raised for Assessment \nYear 2004-05 is dismissed as infructuous

ITA 2326/MUM/2017[2009-10]Status: DisposedITAT Mumbai28 Jan 2025AY 2009-10

…s, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n Assessment year \n\nGround No. in \nAssessee's appeal \n\nGround No. in Revenue's \nappeal \n\n2003-04 \n\n4 \n\n-\n\n54 \nHDFC Bank Ltd. \n…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\n| Sr

ITA 2093/MUM/2017[2009-10]Status: DisposedITAT Mumbai28 Jan 2025AY 2009-10

…s, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\nii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n| Assessment year | Ground No. in \nAssessee's appeal | Ground No. in Revenue's \nappeal \n\n|---|---|---| \n| 2003-04 | 4 | - \n\n14. 1. Fa…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

ITA 2867/MUM/2012[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…xpenditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13.6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Revenue's Assessee's appeal appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 20…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

ITA 5033/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…xpenditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13.6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Revenue's Assessee's appeal appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 20…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

ITA 4314/MUM/2010[2003-04]Status: DisposedITAT Mumbai28 Jan 2025AY 2003-04

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

…penditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 2020…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

ITA 4313/MUM/2010[2002-03]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-03

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…xpenditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13.6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Revenue's Assessee's appeal appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 20…

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

ITA 3785/MUM/2009[2004-05]Status: DisposedITAT Mumbai28 Jan 2025AY 2004-05

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…xpenditure. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13.6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Ground No. in Revenue's Assessee's appeal appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 20…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. THE ADDL CIT RG 1(1), MUMBAI

ITA 4315/MUM/2007[2002-2003]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-2003

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

…iture. Thus, grounds taken by the Revenue are dismissed and those by the assessee are allowed. 13. 6. Our findings are fortified by the following decisions: i) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) ii) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) iii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) VI. Deduction of income by the amount credited to lease equalization account. 14. This issue arises in the following appeals: Assessment year Ground No. in Assessee's appeal Ground No. in Revenue's appeal 2003-04 4 - 54 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs…

DCIT CIR 1(1), MUMBAI vs. M/S HOUSING DEVELOPEMENT FINANCE CORPORATION LTD, MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

ITA 4161/MUM/2007[2002-2003]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-2003

…us, grounds taken by the Revenue are \ndismissed and those by the assessee are allowed. \n\n13. 6. Our findings are fortified by the following decisions: \n\ni) CIT vs. Mahendra Sobhagchand Shah, 203 ITR 178 (Bom) \n\ni) CIT vs. United Colleries Ltd., [1993] 203 ITR 857 (Cal) \n\niii) CIT vs. Modern Terry Towels Ltd., 357 ITR 750 (Bom) \n\nVI. Deduction of income by the amount credited to lease \nequalization account. \n\n14. This issue arises in the following appeals: \n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in Revenue's \nappeal \n2003-04 \n4 \n-\n\n54 \nHDFC Bank Ltd. \nITA No.431…

Showing 1–20 of 22 · Page 1 of 2

CIT v. Mahendra Sobhagchand Shah (203 ITR 857) — Cited in 22 Judgments | BharatTax