CIT v. Padukottai Company Pvt. Ltd.

84 ITR 788High Court1972#9923 most cited
11

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Sections most often in play

Section 36(1)(iii)Section 132Section 139Section 145(3)Section 147Section 250Section 36(1)(vii)Section 44AB

Issues it is cited on

put to usecommercial expediencysection 36(1)(iii)section 36(1)section 36section 28section 37commissioner (appeals)section 10personcompanyprescribed

Judgments citing CIT v. Padukottai Company Pvt. Ltd.

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

ITA 1252/CHNY/2025[2022-23]Status: DisposedITAT Chennai12 Sept 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…f the Act. In support, he relied on the following decisions:- ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 46 :: − Birla Gwalior Pvt Ltd Vs CIT (44 ITR 847) (MP HC) − CIT Vs. Pudukottai Co. Pvt. Ltd. (84 ITR 788) (Mad HC) − Hindalco Industries Co. Vs. CIT (389 ITR 430) (All HC) − CIT Vs Williamson Magor & Co Ltd (232 taxman 533) (Cal HC) − CIT Vs Sahni Silk Mills (P) Ltd (253 ITR 294) (Del HC) 10.24 The undisputed facts, as noted above, are that, the assessee had incurred average cost of borrowings at 10% per annum and that the loan advanced to JCT car…

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

ITA 1251/CHNY/2025[2021-22]Status: DisposedITAT Chennai12 Sept 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…f the Act. In support, he relied on the following decisions:- ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 46 :: − Birla Gwalior Pvt Ltd Vs CIT (44 ITR 847) (MP HC) − CIT Vs. Pudukottai Co. Pvt. Ltd. (84 ITR 788) (Mad HC) − Hindalco Industries Co. Vs. CIT (389 ITR 430) (All HC) − CIT Vs Williamson Magor & Co Ltd (232 taxman 533) (Cal HC) − CIT Vs Sahni Silk Mills (P) Ltd (253 ITR 294) (Del HC) 10.24 The undisputed facts, as noted above, are that, the assessee had incurred average cost of borrowings at 10% per annum and that the loan advanced to JCT car…

AMITABH DAS MUNDHRA,KOLKATA vs. D.C.I.T., CC-11(1), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 965/KOL/2024[2020-2021]Status: DisposedITAT Kolkata09 Oct 2024AY 2020-2021

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 57

…adequately proved that the interest paid on the loans was wholly and exclusively expended for the purpose of earning of interest income. In defense of his arguments the Ld. A.R relied on the following decisions: i) CIT vs. Pudukottai Company Pvt. Ltd. [1972] 84 ITR 788 (Mad-HC) 6 I.T.A. No.965/Kol/2024 Assessment Year: 2020-21 Amitabh Das Mundhra ii) Rupee Finance & Management Pvt. Ltd. in [2017] 81 taxmann.com 249 (Mum- Trib) Finally the Ld. A.R submitted that in view of the underlying facts, and also the fact of having done the similar activity in the preceding assessment years and ratio laid down in the abo…

ACIT 32(1) MUMBAI, MUMBAI vs. VKT VENTURES LLP, MUMBAI

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

ITA 2659/MUM/2024[2015-16]Status: DisposedITAT Mumbai27 Aug 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2015-16 Acit 32(1), Vkt Ventures Llp, 202, 2Nd Floor, Kautilya Bhavan, 318 A To Z Industrial Estate, Bkc, Bandra (East) Vs. Delisle Road, S.O. Mumbai-400051. Mumbai-400013. Pan No. Aajfv 3533 G Appellant Respondent

For Appellant: NoneFor Respondent: 11/07/2024
Section 143(3)Section 36(1)(iii)

…the decision of the Hon’ble Madras High Court in the the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the case of CIT v. Padukottai C CIT v. Padukottai Company Pvt. Ltd. 84 ITR 788 (Mad) ompany Pvt. Ltd. 84 ITR 788 (Mad) wherein it is held that once it is accepted that capital was borrowed wherein it is held that once it is accepted that capital was borrowed wherein it is held that once it is accepted that capital was borrowed for the purpose of business, payment of interest on such borrowed for the purpose of business, paym…

ACIT-32(1), MUMBAI, MUMBAI vs. VKT VENTURES LLP, MUMBAI

In the result, both the appeals of the Reven

ITA 2349/MUM/2024[2014-15]Status: DisposedITAT Mumbai19 Aug 2024AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: NoneFor Respondent: 09/07/2024
Section 36(1)(iii)

…relied on the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the case of CIT v. Padukottai Company Pvt. Ltd. 84 ITR 788 Padukottai Company Pvt. Ltd. 84 ITR 788 Padukottai Company Pvt. Ltd. 84 ITR 788 (Mad) wherein it is held that once it is accepted that capital was wherein it is held that once it is accepted that capital was wherein it is held that once it is accepted that capital was borrowed for the purpose of business, payment of interest on such borrowed for t…

ACIT 32(1), MUMBAI, MUMBAI vs. VKT VENTURES LLP, MUMBAI

In the result, both the appeals of the Reven

ITA 2322/MUM/2024[2013-14]Status: DisposedITAT Mumbai19 Aug 2024AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: NoneFor Respondent: 09/07/2024
Section 36(1)(iii)

…relied on the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the Ld. CIT(A) on the decision of the Hon’ble Madras High Court in the case of CIT v. Padukottai Company Pvt. Ltd. 84 ITR 788 Padukottai Company Pvt. Ltd. 84 ITR 788 Padukottai Company Pvt. Ltd. 84 ITR 788 (Mad) wherein it is held that once it is accepted that capital was wherein it is held that once it is accepted that capital was wherein it is held that once it is accepted that capital was borrowed for the purpose of business, payment of interest on such borrowed for t…

BABA SATYANARAYAN HIMGHAR P. LTD.,,HOOGHLY vs. DCIT, CIRCLE - 23, , HOOGHLY

In the result, the appeal of the assessee is allowed

ITA 830/KOL/2019[2013-14]Status: DisposedITAT Kolkata06 Nov 2019AY 2013-14

Bench: Shri P.M. Jagtap, Vice-

Section 142(1)Section 143(2)Section 144

…ee borrowed capital for business purposes, no portion of the interest could be disallowed even if the assessee had dissipated the funds by giving interest-free loans. Similarly, the Madras High Court held in the case of CIT vs. Pudukkottai Co. (P) Ltd. (1972) 84 ITR 788 (Mad) that, in view of the finding that the amounts borrowed were for the purpose of business, no disallowance of interest paid could be made if the assessee borrowed the funds at a higher rate of interest and lent it at a lower rate”. So it is evident from the aforesaid discussion that there is an element of business expediency involved in this…

PRAHAM INDIA LLP,MUMBAI vs. ITO 31(2)(5), MUMBAI

In the result, appeal is dismissed

ITA 3416/MUM/2018[2014-15]Status: DisposedITAT Mumbai31 May 2019AY 2014-15

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Mayur KisnadwalaFor Respondent: Shri Chaitanya Anjaria
Section 36(1)(iii)

…such contention, the learned Authorised Representative relied upon the following decisions:– i) S.A. Builders v/s CIT, 92007] 288 ITR 001 (SC); ii) Hindalco Industries Co. v/s CIT, [2016] 389 ITR 430 (All.); and iii) CIT v/s Pudukottai Co. Pvt. Ltd., [1972] 84 ITR 788 (Mad.). 7. The learned Departmental Representative strongly relied upon the observations of the Assessing Officer and learned Commissioner (Appeals). 8. We have considered rival submissions and perused the material on record. As could be seen from the factual matrix of the case, the assessee had availed loan of ` 37.50 lakh from Kotak Mahindra P…

ALCATEL-LUCENT INDIA LTD.,,GURGAON vs. ADDL.CIT, SPECIAL RANGE-1, NEW DELHI

In the result, the appeal of the assessee is allowed partly for statistical purposes

ITA 6979/DEL/2017[2013-14]Status: DisposedITAT Delhi09 May 2019AY 2013-14

Bench: Shri H.S. Sidhu & Shri O.P. Kantassessment Year: 2013-14 M/S. Alcatel-Lucent India Vs. Addl. Cit, Ltd., Special Range-1, New Delhi Dlf Cyber Greens, 14 & 15Th Floor, Tower C, Phase-Iii, Dlf City, Gurgaon Pan :Aacca8667N (Appellant) (Respondent) Appellant By Shri Deepak Chopra, Adv.; Ms. Manasvini Bajpai, Adv.; & Shri. Ankul Goyal, Adv. Respondent By Shri Sanjay I. Bara, Cit(Dr)

Section 143(3)Section 144CSection 144C(10)Section 92C

…rest on the borrowings for the assessment years 1993-94 to 1997-98.' Similar view has been followed in the case of Commissioner of income Tax v. Motor Sales Limited [(2008) 304 ITR 123 (All)], Commissioner of Income-tax Vs Pudukottai Company Pvt. Ltd. [(1972) 84 ITR 788 (Mad)], Chetan Dass Laxman Dass Vs Income Tax Officer {(2002) 122 Taxman 263 (Delhi) (Mag)], Gujarat Narmada Valley Fertiliser Co. Ltd. Vs Deputy Commissioner of Income Tax [(2000) 108 Taxman 213 (Ahd)(Mag)], Commissioner of Income-Tax vs. Hotel Savera [(1999) 239 ITR 795 (Mad)], Shree Digvijay Cement Co. Ltd. Vs Commissioner of Income-tax, Gujara…

I.T.O. WARD - 2,KHAMGAON, KHAMGAON vs. M/S SHRI HANUMAN ONION TRADING CO.,,

In the result this appeal filed by the Revenue is stands dismissed

ITA 534/NAG/2016[2008-09]Status: DisposedITAT Nagpur10 Jan 2017AY 2008-09

Bench: Shri Shamim Yahya. (S.M.C.)

For Appellant: Shri A.R. NinaweFor Respondent: Shri Vijay Chandak
Section 36(1)(iii)Section 69

…o them for short term get compensated by the business with which they support appellant. The appellant in support of his claim has relied on the 7 ITA No. 534/Nag/2016. decision of Hon. Madras High Court in the case of CIT vs. Pudukottai Co. Pvt. Ltd. (1972) 84 ITR 788 (Mad.) wherein it has been held that once it is considered that loan borrowed are for the purposes of business then u/s 36(i)(iii) interest paid is an allowable expenditure. The AR has also relied on the decision of CIT vs. Indian Explosive Ltd. (1991) 192 ITR 144 (Cal.), CIT Vs. Coimbatore Salem Transport (P) Ltd. (1966) 619 ITR 480 (Mad.) wherei…

ACIT CIR. 8(1), MUMBAI vs. M/S. AFCONS INFRASTRUCTURE LTD., MUMBAI

In the result, Department’s appeal is dismissed

ITA 4269/MUM/2005[2001-2002]Status: DisposedITAT Mumbai08 Jul 2016AY 2001-2002

Bench: Shri Jason P. Boaz, Accountant Mbmer & Shri Saktijit Dey

For Appellant: Shri J.D. Mistry a/wFor Respondent: Shri Jasbir Chauhan
Section 14A

…ee on borrowed capital, no disallowance can be made once it is accepted that capital was borrowed for the purpose of assessee’s business. In this context, he relied upon the decision of the Hon'ble Madras High Court in CIT v/s Pudukottai Co. Pvt. Ltd., [1972] 84 ITR 788 (Mad.). 10. Learned Departmental Representative on the other hand while supporting the disallowance sustained by the learned Commissioner (Appeals) also argued for restoration of the disallowance made by the Assessing Officer while pressing the corresponding ground raised by the Department on the same issue. 11. We have considered the submission…

CIT v. Padukottai Company Pvt. Ltd. (84 ITR 788) — Cited in 11 Judgments | BharatTax