What is CIT v. Nagri Mills Co. Ltd. authority for?

An addition to income is revenue neutral if its tax impact remains the same regardless of the year in which it is assessed. Assessments should not dispute the year of addition when the tax rate and impact are consistent, to avoid unnecessary disputes and potential loss to revenue.

How many judgments cite CIT v. Nagri Mills Co. Ltd.?

165 judgments on BharatTax cite CIT v. Nagri Mills Co. Ltd. (33 ITR 681), spanning 2010 to 2025.

Which sections of the Income Tax Act does CIT v. Nagri Mills Co. Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 14A, Section 36(1)(vii), Section 194H, Section 37(1), Section 40(a)(ia).

CIT v. Nagri Mills Co. Ltd. (33 ITR 681)

Axis Bank Limited, Ahmedabad vs. Jt.CIT., Circle-1(1)(1), Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 852/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad29 Mar 2022AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 852/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2015-2016 Axis Bank Limited, J.C.I.T., “Trishul”, 3Rd Floor, Vs. Circle-1(1)(1), Opp. Samtheshwar Mahadev, Ahmedabad. Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K

For Appellant: Shri S.N. Soparkar Sr. Advocate with Shri Parin Shah, A.RFor Respondent: Shri Vijaykumar Jaiswal, CIT.D.R

Section 133Section 14ASection 43D

…oncept of accrual is considered and guarantee commission is held to have accrued when the guarantee is issued. 7.3 8 As regards the contention that change in method is merely a timing difference and reliance on the decisions in the case of Nagri Mills Limited 33 ITR 681 and Excel Industries Limited relied upon by the appellant, the decision of the Nagri Mills was pertaining to deduction of bonus and year of allowabi/ity. In the case of Excel Industries Limited again, the Supreme Court was concerned with question of value of benefit in respect of benefit of duty on advance license pass book and issue was whether t…

M/S. Karnataka Power Corporation Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 11(5), Bangalore

In the result, both the appeals of the revenue and the assessee are dismissed

ITA 26/BANG/2020[2010-11]Status: DisposedITAT Bangalore02 Mar 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2010-11

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 115JSection 80I

…d to provide any evidence to support its submissions. Accordingly, he disallowed the claim of Rs.5.82 crores. 5.1 The Ld. CIT(A) deleted the disallowance by following the decision rendered by Hon’ble Bombay High Court in the case of CIT Vs. Nagri Mills Ltd. (33 ITR 681). The Ld CIT(A) also observed that the Tribunal, in the assessee’s own case relating to the assessment years 2006-07 & 2008-09 in ITA Nos.323 & 1341/Bang/2012, has decided the issue relating to prior period expenses in favour of the assessee. However, we notice that the nature of prior period expenses dealt with by the Tribunal in those years is d…

Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore vs. M/S. Karnataka Power Corporation Limited, Bangalore

In the result, both the appeals of the revenue and the assessee are dismissed

ITA 10/BANG/2020[2010-11]Status: DisposedITAT Bangalore02 Mar 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2010-11

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 115JSection 80I

…d to provide any evidence to support its submissions. Accordingly, he disallowed the claim of Rs.5.82 crores. 5.1 The Ld. CIT(A) deleted the disallowance by following the decision rendered by Hon’ble Bombay High Court in the case of CIT Vs. Nagri Mills Ltd. (33 ITR 681). The Ld CIT(A) also observed that the Tribunal, in the assessee’s own case relating to the assessment years 2006-07 & 2008-09 in ITA Nos.323 & 1341/Bang/2012, has decided the issue relating to prior period expenses in favour of the assessee. However, we notice that the nature of prior period expenses dealt with by the Tribunal in those years is d…

Shree Rama Multi-Tech Ltd., Ahmedabad vs. The ACIT(OSD) Circle-8, Ahmedabad

In the result, appeal of the assessee is partly allowed

ITA 1345/AHD/2015[2009-10]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2009-10

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 143Section 143(3)Section 145ASection 147Section 148Section 43BSection 80I

…ive. It is for the reason that the expenses there is no loss to the revenue as there is no change in the rate of tax. In holding so we draw support and guidance from the judgment of Hon’ble Bombay High Court in case of CIT vs. Nagri Mills Co. Ltd. reported in 33 ITR 681 where the Hon’ble court held as under: “We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is allowable may be mate…

Shree Rama Multi-Tech Ltd., Ahmedabad vs. The Dy.CIT., Crcle-8, Ahmedabad

In the result, appeal of the assessee is partly allowed

ITA 722/AHD/2014[2000-01]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2000-01

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 143Section 143(3)Section 145ASection 147Section 148Section 43BSection 80I

…ive. It is for the reason that the expenses there is no loss to the revenue as there is no change in the rate of tax. In holding so we draw support and guidance from the judgment of Hon’ble Bombay High Court in case of CIT vs. Nagri Mills Co. Ltd. reported in 33 ITR 681 where the Hon’ble court held as under: “We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is allowable may be mate…

Torrent Power Ltd., Ahmedabad vs. The ACIT., Range-8, Ahmedabad

In the result cross objection filed by the assessee is partly allowed for statistical purposes

ITA 776/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad08 Dec 2021AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Vinod Tanwani, CIT.D.R

Section 143(3)Section 254

…/AHD/2015 with 8 others Asstt. Years 2006-07 & others 15 even claim of the assessee is allowed in the later assessment year. In holding so we draw support and guidance from the judgment of Hon’ble Bombay High Court in case of Nagri Mills Co. Ltd. reported in 33 ITR 681, the relevant portion of the finding is extracted herein: “We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is all…

The Income Tax Officer, Ward-2(1)(2), Ahmedabad vs. M/S. Kanak Castor Products Pvt. Ltd., Ahmedabad

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1715/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad10 Nov 2021AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedasst.Year : 2008-09

For Appellant: Shri Hemanshu Shah, ARFor Respondent: Shri R.R. Makwana, Sr. DR

Section 40

…prior period expense cannot be disallowed as there is no effect on the tax liability of the assessee. In holding so we draw support and AY 2008-09 14 guidance from the judgment of Hon’ble Bombay High Court in case of CIT vs. Nagri Mills Co. Ltd. reported in 33 ITR 681 where the Hon’ble court held as under: “We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is allowable may be mate…

Axis Bank Limited, Ahmedabad vs. The Dy.CIT, Circle-1 Now Circle-1(1)(1), Ahmedabad

In the result appeal of the Revenue is partly allowed for statistical purposes

ITA 311/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad28 Oct 2021AY 2010-11

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedsl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 311/Ahd/2016 2010-11 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 2. 2176/Ahd/2016 2011-12 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 3. 2173/Ahd/2016 2011-12 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 4. 165/Ahd/2017 2012-13 Axis Bank Limited, D.C.I.T., Ahmedabad. Circle-1(1)(1) Ahmedabad. Pan: Aaacu2414K 5. 287/Ahd/2017 2012-13 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 6-7 520 & 2013-14 Axis Bank Limited, D.C.I.T., 521/Ahd/2018 & Ahmedabad. Circle-1(1)(1) 2014-15 Ahmedabad. Pan: Aaacu2414K 8-9 604 & 605/ 2013-14 D.C.I.T., Axis Bank Limited, Ahd/2018 & Circle-1(1)(1) Ahmedabad. 2014-15 Ahmedabad. Pan: Aaacu2414K

For Appellant: Shri S.N. Soparkar, Sr. Advocate with Smt. Urvashi Shodhan, and Shri Parin Shah,For Respondent: Shri Anshu Prakash, CIT.DR

Section 14A

…o RBI directives/guidelines in deciding income tax issues where there are no specific provisions eitherway in income tax. (v) Such charge of gain on securitization amortized is only timing difference based addition, tax-neutralized over the years [Nagri Mills 33 ITR 681 (Bom)] and also as per the ratio of Excel Industries 358 ITR 295 (SC] where the Hon. SC has directed the AO to take pragmatic view rather than pendatic view. 2.3 Without prejudice to above it is submitted that the AO be directed to allow reduction of Rs. 2.54 crores recognized as income during the previous year which was disallowed and taxed as ac…

Dy. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Forest Corporation, Lucknow

In the result, the appeal of the Revenue stands dismissed

ITA 574/LKW/2019[2016-17]Status: DisposedITAT Lucknow21 Sept 2021AY 2016-17

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2016-17

Section 11Section 12ASection 2(15)

…ard is placed on the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Vishnu Industrial Gases ITR No. 229/1988) wherein the Hon'ble Delhi High Court followed the ruling of the Hon'ble Mumbai High Court in the case of Nagri Mills Co. Ltd. [1958] 33 ITR 681. Relevant Extracts of the judgment in the case of Nagri Mills Co. Ltd (supra) are reproduced below: "We have often wondered why the Income tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the income tax Act, raise disputes as to the year in which the deduction should be allowed. The question…

DCIT (E)-1(1), Mumbai vs. Aditya Birla Foundation, Mumbai

In the result, Revenue’s appeal is partly allowed

ITA 4065/MUM/2019[2011-12]Status: DisposedITAT Mumbai16 Jun 2021AY 2011-12

Section 11Section 11(2)Section 12ASection 13(3)Section 143(2)Section 143(3)Section 145Section 154Section 25

…not provide any hindrance to the system of accounting in this regard being followed by the assessee. In this regard he placed reliance upon the following case laws :- • PCIT Vs. Quest Investment Advisors (P) Ltd. (409 ITR 545) • CIT Vs. Nagri Mills Co. Ltd. (33 ITR 681) 5 Aditya Birla Foundation • CIT Vs. Ganga Charity Trust Fund (162 ITR 612) • DCIT Vs. M/s. G.D. Birla Medical Research & Education Foundation (ITA No. 4348/Mum/2018) 11. We have carefully considered the submission and perused the record. We note that the assessee is a trust. It is undisputed that the assessee is following mercantile system of a…

DCIT Cir 3(2), Mumbai vs. Idea Cellular Ltd ( Successor to Idea Mobile Communication Ltd), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose and the appeal of the Revenue is dismissed

ITA 6908/MUM/2013[2005-06]Status: DisposedITAT Mumbai07 Jun 2021AY 2005-06

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2005-06

For Appellant: Shri J.D. Mistry, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R

Section 35ASection 37(1)

…orm. The assessee has 5 ITA No.6908/M/2013 & ITA No.6573/M/2013 M/s. Idea Cellular LTd. (Successor to Idea Mobile Communication Ltd., previously known as Escotel Mobile Communication Ltd.) placed reliance on the decision of CIT vs. Nagri Mills Co. Ltd. (1958) 33 ITR 681 (Bom.) and also 3 other decisions. We have perused the decisions and found that the case of the assessee is squarely covered by the ratio laid down in the said decisions. We also find that the addition made by the AO is tax neutral. Accordingly, we set aside the order of Ld. CIT(A) and direct the AO to delete the disallowance of Rs.21,78,491/-. 7…

Idea Cellular Limited, Mumbai vs. DCIT Circle 11(1), New Delhi

In the result, the appeal of the assessee is allowed for statistical purpose and the appeal of the Revenue is dismissed

ITA 6573/MUM/2013[2005-06]Status: DisposedITAT Mumbai07 Jun 2021AY 2005-06

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2005-06

For Appellant: Shri J.D. Mistry, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R

Section 35ASection 37(1)

…orm. The assessee has 5 ITA No.6908/M/2013 & ITA No.6573/M/2013 M/s. Idea Cellular LTd. (Successor to Idea Mobile Communication Ltd., previously known as Escotel Mobile Communication Ltd.) placed reliance on the decision of CIT vs. Nagri Mills Co. Ltd. (1958) 33 ITR 681 (Bom.) and also 3 other decisions. We have perused the decisions and found that the case of the assessee is squarely covered by the ratio laid down in the said decisions. We also find that the addition made by the AO is tax neutral. Accordingly, we set aside the order of Ld. CIT(A) and direct the AO to delete the disallowance of Rs.21,78,491/-. 7…

Shivam Enterprise, Althan vs. Pr. CIT-2, Surat

In the result, the appeals of the assessees (in ITA Nos

ITA 108/SRT/2020[2015-16]Status: DisposedITAT Surat27 May 2021AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.107 & 108/Srt/2020 ("नधा"रणवष" / Assessment Year:(2015-16) (Virtual Court Hearing) Shyam Corporation, Vs. The Pcit-2, Surat. S. No. 84/1, 885 Block No.137, T.P. No.58, F.P. No.38, B/H. Siddhivinayak Complex, Bamroli, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgfs7598M (Assessee) (Respondent) Shivam Enterprises, Vs. The Pcit-2, Surat. Tp. 43, Block No.50, Fp.30, At Post Bhimrad, Althan, Surat-395017. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acdfs9748Q

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri S. T. Bidari, Sr. DR

Section 115Section 131Section 133ASection 143(3)Section 263Section 37

…it is requested to your honour considered the facts and drop the proceeding u/s 263 of Act. The addition, if any, is revenue neutral, if seen in a macro perspective and, therefore, no adjustment is called for. Reliance was placed on Nagri Mills Company Ltd.: 33 ITR 681 (Bom.): Triveni Engineering Industries Ltd.: 336ITR 374 (Del). Copy of the Income tax return of the partnership firm from AY 2015-16 to AY 2019-20 is enclosed herewith for your record. So, it is most humble submission that please do not pass the order u/s 263 of the Income tax act as it is revenue neutral and no prejudicial to the interest of reve…

Shyam Corporation, Surat vs. Pr. CIT-2, Surat

In the result, the appeals of the assessees (in ITA Nos

ITA 107/SRT/2020[2015-16]Status: DisposedITAT Surat27 May 2021AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.107 & 108/Srt/2020 ("नधा"रणवष" / Assessment Year:(2015-16) (Virtual Court Hearing) Shyam Corporation, Vs. The Pcit-2, Surat. S. No. 84/1, 885 Block No.137, T.P. No.58, F.P. No.38, B/H. Siddhivinayak Complex, Bamroli, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgfs7598M (Assessee) (Respondent) Shivam Enterprises, Vs. The Pcit-2, Surat. Tp. 43, Block No.50, Fp.30, At Post Bhimrad, Althan, Surat-395017. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acdfs9748Q

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri S. T. Bidari, Sr. DR

Section 115Section 131Section 133ASection 143(3)Section 263Section 37

…it is requested to your honour considered the facts and drop the proceeding u/s 263 of Act. The addition, if any, is revenue neutral, if seen in a macro perspective and, therefore, no adjustment is called for. Reliance was placed on Nagri Mills Company Ltd.: 33 ITR 681 (Bom.): Triveni Engineering Industries Ltd.: 336ITR 374 (Del). Copy of the Income tax return of the partnership firm from AY 2015-16 to AY 2019-20 is enclosed herewith for your record. So, it is most humble submission that please do not pass the order u/s 263 of the Income tax act as it is revenue neutral and no prejudicial to the interest of reve…

Go Airlines (India) Limited, Mumbai vs. DCIT 5(1)(1), Mumbai

In the result, appeal is partly allowed

ITA 3789/MUM/2018[2012-13]Status: DisposedITAT Mumbai29 Jan 2021AY 2012-13

Section 37(1)

…ed 28-02-2019 (2) Bharat Insulation Co (I) Ltd vs ACIT – ITA No.33/Mum/2013 dt 20-11-2015 (3) NCS Distilleries P. Ltd vs ITO – ITA No.699/Hyd/2012 dated 16-09-2014 (4) M/s Federal Moghul TPR (I) Ltd vs JCIT – ITA No.509/Del/2017 (5) CIT vs Nagari Mills Co Ltd 33 ITR 681 (Bom) I.T.A. No.3789/Mum/2018 5 10. The learned Departmental Representative strongly relying upon the observations of the Assessing Officer and learned Commissioner (Appeals) submitted, the expenditure claimed by the assessee, since, relates to prior period, it cannot be allowed in the impugned assessment year. Further, he submitted that CENVAT…

DCIT-1(2)(1), Mumbai vs. Kumar Properties Pvt Ltd, Mumbai

The appeal of the assessee is allowed, and appeal of the Assessing Officer is dismissed

ITA 605/MUM/2019[2014-15]Status: DisposedITAT Mumbai08 Jul 2020AY 2014-15

Bench: Shri Vikas Awasthy, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 605/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Dcit 1(2)(1), M/S Kumar Properties Pvt. R. No. 535, Ltd. बिधम/ Aayakarbhavan, 21, Woundboy Road, M. K. Road, Hazarimalsomani Marg, Vs. Mumbai-400 020 Opp-Mumbai Gymkhana, Fort, Mubmai-400 001 स्थायीलेखासं./जीआइआरसं./Pan No. Aabck8464E (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : &

For Appellant: ShriDrop Singh MeenaFor Respondent: ShriRajanVora/Shri

Section 143Section 143(2)Section 145(1)

…urt in case of CIT vs Excel Industries Ltd [2013] 358 ITR 295 (SC) [Copy enclosed at page no 212 to 218 of the Paper book]. 44. Further Assessee wishes to place reliance on the decision of Hon'ble Bombay High Court in case of CIT vs Nagri Mills Co. Ltd [1958] 33 ITR 681 (Bom) [Copy enclosed at page no 219 to 220 of the Paper book], wherein it has been held that the question as to the year in which a deduction is allowable may be material when the rate of tax chargeable on the assessee in two different years is different; but in the 18 I.T.A. No. 605/Mum/2019 & CO 14/Mum/2020 M/s Kumar Properties Pvt. Ltd. case of…

Knight Riders Sorts P. Ltd, Mumbai vs. DCIT Cen Cir 4(2), Mumbai

In the result, ground no. 6 & 7 of appeal are allowed

ITA 5092/MUM/2017[2010-11]Status: DisposedITAT Mumbai06 Mar 2020AY 2010-11

Bench: Shri M. Balaganesh, Am & Shri Amarjit Singh, Jm

For Appellant: Shri Hiten Chande (AR)For Respondent: Shri Padmapani Bora (DR)

Section 143(3)Section 271Section 271(1)(c)

…is same and the addition raised by AO has become ITA. Nos. 5237/M/2017 & 5092/M/2017 A.Y.2010-11 revenue neutral so no penalty is sustainable in the eyes of law in view of the decision of Hon’ble Bombay High Court in the case of CIT Vs. Nagri Mills Co. Ltd. 33 ITR 681. Moreover, the claim has not been accepted by AO so there is no concealment of income nor furnishing the inaccurate particulars of income so penalty is not liable to be sustainable in the eyes of law. In this regard we also find support of law settled by the Hon’ble Supreme Court in the case of CIT Vs. Reliance Petro Products Pvt. Ltd. 322 ITR 158…

Universal Medicare P.Ltd, Mumbai vs. DCIT Cen Cir 3(2), Mumbai

In the result this ground of appeal is allowed for

ITA 4418/MUM/2016[2012-13]Status: DisposedITAT Mumbai06 Mar 2020AY 2012-13

Bench: Shri Pawan Singh & Shri S. Rifaur Rahmanuniversal Medicare Pvt. Ltd., Dcit, Central Cricle-3(2), Capsulation Premises, Mumbai (Erstwhile Asst. Sion Trombay Road, Deonar, Vs. Commissioner Of Income Mumbai-400088. Tax, Cc-20, Mumbai), Room No. 1923, 19Th Floor, Pan: Aaacu0717B Air India Building, Nariman Point, Mumbai-400021. Appellant Respondent C.O. No. 268/Mum/2017 (Assessment Year 2012-13) Dcit, Central Cricle-3(2), Universal Medicare Pvt. Ltd., Mumbai (Erstwhile Asst. Capsulation Premises, Commissioner Of Income Vs. Sion Trombay Road, Deonar, Tax, Cc-20, Mumbai), Room Mumbai-400088. No. 1923, 19Th Floor, Air Pan: Aaacu0717B India Building, Nariman Point, Mumbai-400021. Appellant Respondent Appellant By : Shri J.D. Mistry Senior Advocate With Shri Manish Shah Advocate Respondent By : Mrs. S. Padmaja (Cit-Dr)

For Appellant: Shri J.D. Mistry Senior Advocate with Shri Manish Shah AdvocateFor Respondent: Mrs. S. Padmaja (CIT-DR)

Section 143(3)Section 2Section 254(1)Section 50B

…ing (MOU), part of sale consideration was payable by purchasers on completion of assessee’s obligation under MOU, assessee having not met conditions of MOU during relevant year such amount was not taxable in relevant assessment year. The Hon’ble Ltd. [1958] 33 ITR 681 (Bom)] wherein it was held that as under: “3. We have often wondered why the Income-tax authorities, in a matter such as this where the deduction is obviously a permissible deduction under the Income-tax Act, raise disputes as to the year in which the deduction should be allowed. The question as to the year in which a deduction is allowable may b…

The ITO, Ward-1(1)(2), Ahmedabad vs. M/S. Bajaj Herbals Pvt. Ltd., Ahmedabad

In the result, assessee’s appeal is allowed, and that of the Revenue is dismissed

ITA 2350/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2020AY 2010-11

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं.Ita Nos. 2277/Ahd/2015 "नधा"रणवष"/Asstt. Year: 2010-11 M/S. Bajaj Herbals Pvt. Ltd. Vs. Ito A-401, Samundra Complex, Ward-1(2), 3Rd Floor, Pratyakash- Nr. Hotel Classic Gold, Ellisbridge, Ahmedabad Kar-Bhavan, Ambawadi, Ahmedabad- 380015 Pan No. Aaa Cb6 654 J अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent)

For Appellant: Shri Tushar Hemani, & Shri PFor Respondent: Shri O.P. Sharma CIT DR& L.P

Section 115JSection 142(1)Section 143(2)Section 143(3)

…आयकरअपील"यअ"धकरण, अहमदाबाद"यायपीठ ‘C’- अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD – BENCH ‘C’ BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & Ms. MADHUMITA ROY, JUDICIAL MEMBER आयकरअपीलसं.ITA Nos. 2277/Ahd/2015 "नधा"रणवष"/Asstt. Year: 2010-11 M/s. Bajaj Herbals Pvt. Ltd. Vs. ITO A-401, Samundra Complex, Ward-1(2), 3rd Floor, Pratyakash- Nr. Hotel Classic Gold, Ellisbridge, Ahmedabad Kar-Bhavan, Ambawadi, Ahmedabad- 380015 PAN No. AAA CB6 654 J अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) आयकरअपीलसं.ITA Nos. 2350/Ahd/2015 "नधा"रणवष"/Asstt. Years: 2010-11 ITO Vs. M/s. Bajaj Herbals Pvt. Ward-1(1)(2), Ltd…

M/S. Bajaj Herbals Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(2), Ahmedabad

In the result, assessee’s appeal is allowed, and that of the Revenue is dismissed

ITA 2277/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2020AY 2010-11

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं.Ita Nos. 2277/Ahd/2015 "नधा"रणवष"/Asstt. Year: 2010-11 M/S. Bajaj Herbals Pvt. Ltd. Vs. Ito A-401, Samundra Complex, Ward-1(2), 3Rd Floor, Pratyakash- Nr. Hotel Classic Gold, Ellisbridge, Ahmedabad Kar-Bhavan, Ambawadi, Ahmedabad- 380015 Pan No. Aaa Cb6 654 J अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent)

For Appellant: Shri Tushar Hemani, & Shri PFor Respondent: Shri O.P. Sharma CIT DR& L.P

Section 115JSection 142(1)Section 143(2)Section 143(3)

…आयकरअपील"यअ"धकरण, अहमदाबाद"यायपीठ ‘C’- अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD – BENCH ‘C’ BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & Ms. MADHUMITA ROY, JUDICIAL MEMBER आयकरअपीलसं.ITA Nos. 2277/Ahd/2015 "नधा"रणवष"/Asstt. Year: 2010-11 M/s. Bajaj Herbals Pvt. Ltd. Vs. ITO A-401, Samundra Complex, Ward-1(2), 3rd Floor, Pratyakash- Nr. Hotel Classic Gold, Ellisbridge, Ahmedabad Kar-Bhavan, Ambawadi, Ahmedabad- 380015 PAN No. AAA CB6 654 J अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) आयकरअपीलसं.ITA Nos. 2350/Ahd/2015 "नधा"रणवष"/Asstt. Years: 2010-11 ITO Vs. M/s. Bajaj Herbals Pvt. Ward-1(1)(2), Ltd…

CIT v. Nagri Mills Co. Ltd.

What is CIT v. Nagri Mills Co. Ltd. authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. Nagri Mills Co. Ltd.

Axis Bank Limited, Ahmedabad vs. Jt.CIT., Circle-1(1)(1), Ahmedabad

M/S. Karnataka Power Corporation Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 11(5), Bangalore

Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore vs. M/S. Karnataka Power Corporation Limited, Bangalore

Shree Rama Multi-Tech Ltd., Ahmedabad vs. The ACIT(OSD) Circle-8, Ahmedabad

Shree Rama Multi-Tech Ltd., Ahmedabad vs. The Dy.CIT., Crcle-8, Ahmedabad

Torrent Power Ltd., Ahmedabad vs. The ACIT., Range-8, Ahmedabad

The Income Tax Officer, Ward-2(1)(2), Ahmedabad vs. M/S. Kanak Castor Products Pvt. Ltd., Ahmedabad

Axis Bank Limited, Ahmedabad vs. The Dy.CIT, Circle-1 Now Circle-1(1)(1), Ahmedabad

Dy. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Forest Corporation, Lucknow

DCIT (E)-1(1), Mumbai vs. Aditya Birla Foundation, Mumbai

DCIT Cir 3(2), Mumbai vs. Idea Cellular Ltd ( Successor to Idea Mobile Communication Ltd), Mumbai

Idea Cellular Limited, Mumbai vs. DCIT Circle 11(1), New Delhi

Shivam Enterprise, Althan vs. Pr. CIT-2, Surat

Shyam Corporation, Surat vs. Pr. CIT-2, Surat

Go Airlines (India) Limited, Mumbai vs. DCIT 5(1)(1), Mumbai

DCIT-1(2)(1), Mumbai vs. Kumar Properties Pvt Ltd, Mumbai

Knight Riders Sorts P. Ltd, Mumbai vs. DCIT Cen Cir 4(2), Mumbai

Universal Medicare P.Ltd, Mumbai vs. DCIT Cen Cir 3(2), Mumbai

The ITO, Ward-1(1)(2), Ahmedabad vs. M/S. Bajaj Herbals Pvt. Ltd., Ahmedabad

M/S. Bajaj Herbals Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(2), Ahmedabad