CIT v. Punjab Stainless Steel Industries

364 ITR 144Supreme Court of India2014#1970 most cited

What is CIT v. Punjab Stainless Steel Industries authority for?

The Supreme Court holds that ICAI Guidance Notes and accounting methods prescribed by the Institute of Chartered Accountants of India (ICAI) can be relied upon for computing "turnover," especially for tax audit purposes under Section 44AB and for transactions involving shares and derivatives.

59

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Punjab Stainless Steel Industries · 364 ITR 144 · Section 44AB · ICAI Guidance Note · turnover computation · shares derivatives turnover · speculative transaction turnover · method of accounting · business income · Supreme Court

Also reported as

46 Taxmann.com 6815 SCC 129

Sections most often in play

Section 143(3)Section 80HHCSection 35DSection 40(a)(i)Section 14ASection 28(iiid)Section 1961Section 35(2AB)

Issues it is cited on

perquisite valuesection 108convertible foreign exchangesubstance over formsection 211section 10(33)section 35dsection 80hhcactual payment basisinterest u/s 234cspeculative transactionsection 80hh

Judgments citing CIT v. Punjab Stainless Steel Industries

TULIKA KEDIA, NEW DELHI,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

ITA 147/RPR/2025[2020-21]Status: DisposedITAT Raipur20 Nov 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 147/Rpr/2025 (िनधा"रण वष" Assessment Year: 2020-21)

For Appellant: Shri S. R. Rao, AdvFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 153DSection 250Section 271BSection 44A

…of accounts and relevant documents, the method for calculating the turnover should be in accordance with the methods prescribed by the ICAI, which are held to be adoptable by the Hon’ble Supreme Court in the case of CIT vs. Punjab Stainless Industries (2014) 364 ITR 144 (SC) and Hon’ble Hyderabad High Court in the case of CIT vs. Pact Securities and Financials Ltd (2003) 86 ITD 115 (HYD), wherein it is observed that the method of accounting prescribed by ICAI can be relied upon for computing turnover in case of share and derivatives. We also concur with and take support from the decision of ITAT, Mumbai in the c…

RADIANT TEXTILES PRIVATE LIMITED,PATIALA vs. ACIT, CIRCLE, PATIALA, PATIALA

In the result, the appeal stands dismissed

ITA 444/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh14 Oct 2025AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./ Ita No.444/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2019-20) M/S Radiant Textiles Pvt. Ltd. Acit Circle Patiala बनाम/ Village Chounth, Patiala Road Aaykar Bhawan Vs. Samana-147101 Patiala 147001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcr-1175-R (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 10-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 14/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2019-20 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 13-02-2025 In The Matter Of A Rectification Order Passed By Ld. Assessing Officer [Ao] U/S. 154 Of The Act On 28-11-2023. The Only Grievance Of The Assessee Is Application Of Correct Rates Of Taxes.

For Appellant: Shri Parikshit Aggarwal (CA) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 145ASection 154

…P&L A/c and cannot be considered as part of assessee's turnover. The question as to whether Sale of Scrap or wastage is part of turnover or is to be reduced from cost of goods sold came before the Hon'ble SC in CIT v. Punjab Stainless Steel Industries (2014) 364 ITR 144 (copy appended at page 1-17 of AJC) wherein their Lordships held that turnover must consist of receipts from sale of the commodities in which 'A' is engaged and sale of scrap cannot be considered as assessee's turnover and it is to be reduced from cost of goods sold. The case pertained to the computation of profits u/s 80HHC, which involves the t…

DELFIN FINANCE P.LTD.,NEW DELHI vs. ITO, WARD-7(1), NEW DELHI

In the result, the appeal filed by the assessee for AY 1997-98 is allowed

ITA 2958/DEL/2019[1998-99]Status: DisposedITAT Delhi22 Sept 2025AY 1998-99

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 142(1)Section 143(3)

…under the IT Act. Without a doubt, in a catena of cases, this court has discussed the relevancy of the Guidance Note. While dealing with one of such matters, this court, in commissioner of Income Tax-VIL, New Delhi us. Punjab Stainless Steel Industries (2014) 15 SCC 129 held as, under: “17 So as to be more accurate about the word “turnover", One can either refer to dictionaries or to material which are published by bodies of Accountants. The Institute of Chartered Accountants of India (hereinafter referred to as the "ICAI) has published some material under the head "Guidance Note on Tax Audit under Section 44B of…

DELFIN FINANCE P.LTD.,NEW DELHI vs. ITO, WARD-7(1), NEW DELHI

In the result, the appeal filed by the assessee for AY 1997-98 is allowed

ITA 2957/DEL/2019[1997-98]Status: DisposedITAT Delhi22 Sept 2025AY 1997-98

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 142(1)Section 143(3)

…under the IT Act. Without a doubt, in a catena of cases, this court has discussed the relevancy of the Guidance Note. While dealing with one of such matters, this court, in commissioner of Income Tax-VIL, New Delhi us. Punjab Stainless Steel Industries (2014) 15 SCC 129 held as, under: “17 So as to be more accurate about the word “turnover", One can either refer to dictionaries or to material which are published by bodies of Accountants. The Institute of Chartered Accountants of India (hereinafter referred to as the "ICAI) has published some material under the head "Guidance Note on Tax Audit under Section 44B of…

SAHIL GUPTA,DELHI vs. CIT(A), DELHI

In the result, appeal of the assessee is allowed

ITA 1708/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Aug 2025AY 2022-23

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.1708/Del/2025, (A.Y.2022-23) Sahil Gupta, Dy. Commissioner Of Income D-304, Vivek Vihar, Tax, Central Circle 58(1), New Delhi- 110095 Vs. Ara Building, Jhandewalan, Pan: Aoipg4087K New Delhi (Appellant) (Respondent) Appellant By None Respondent By Sh. Manish Gupta, Sr. Dr Date Of Hearing 21/08/2025 Date Of Pronouncement 29/08/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For The Assessment Year (‘Ay’) 2022-23 Is Directed Against The Order Dated 02.12.2024 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, New Delhi (‘Cit(A)’).

Section 143(3)Section 271ASection 44A

…unfavorable differences in case of squared off transactions shall be taken as turnover. 4. I would like to rely on the following judicial pronouncement. Sachin Marotrao Rangari v ACIT 2022 TaxPub(DT) 6494 (Rkt Trib) CIT vs. Punjab Stainless Industries (2014) 364 ITR 144 (SC) CIT vs. Pact Securities and Financials Ltd. (2003) 86 ITD 115 (Hyd.), which held that the method of accounting, prescribed by ICAI can be relied upon for computing turnover in case of shares and derivatives. 5. Section 44AA requires certain specific records for tax purposes which are maintained and provided during the course of assessment a…

SAHIL GUPTA,DELHI vs. CIT(A), DELHI

In the result, the appeal of the assessee in ITA No

ITA 1739/DEL/2025[2022-23]Status: DisposedITAT Delhi22 Aug 2025AY 2022-23

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Sahil Gupta, [Assessee himself]For Respondent: Shri Manish Gupta, Sr. DR
Section 143(3)Section 271BSection 44A

…ver of all such independent transactions for that financial year. The ld. counsel for the assessee relied on the following judicial pronouncements: • Sachin Marotrao Rangari v ACIT 2022 TaxPub(DT) 6494 (Rkt Trib) • CIT vs. Punjab Stainless Industries (2014) 364 ITR 144 (SC) • CIT vs. Pact Securities and Financials Ltd. (2003) 86 ITD 115 (Hyd.), Wherein it has been held that the method of accounting, prescribed by ICAI can be relied upon for computing turnover in case of shares and derivatives. Page 3 of 10 [A.Y. 2022-23] Shri Sahil Gupta 7. Per contra, the ld. DR relied on the orders of the authorities belo…

DCIT, SWARGATE PUNE vs. GRIHUM HOUSING FINANCE LIMITED, PUNE

In the result, the Cross Objection filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

ITA 1883/PUN/2024[2019-20]Status: DisposedITAT Pune12 Jun 2025AY 2019-20

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2019-20

For Appellant: S/Shri Nikhil Mutha and Abhilash HiranFor Respondent: Shri Ramnath P Murkunde
Section 143(1)Section 2(91)Section 36(1)(va)

…s than Rs.250 crore and therefore, the CPC should not have raised the demand by computing the tax rate at 30% as against 25% by the assessee. He also relied on the following decisions: 8 CO No.39/PUN/2024 (a) CIT vs. Punjab Stainless Steel Industries (2014) 364 ITR 144 (SC) (b) West Coast Paper Mills vs. ACIT (2024) 164 taxmann.com 712 (Bom) (c) JKs Employee Welfare Trust vs. ITO (1993) 199 ITR 765 (Raj) (d) Vodafone Idea Ltd. vs. ACIT (2020) 424 ITR 664 (SC) (e) Khatau Junkar Ltd. vs. K.S. Pathania (1992) 196 ITR 55 (Bom) (f) Rajesh Kumar vs. DCIT (2006) 157 Taxman 168 (SC) (g) Sahara India (Firm) vs. CIT (200…

JINDAL SAW LTD.,NEW DELHI vs. ACIT, CIRCLE-13(2), NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 504/DEL/2022[2014-15]Status: DisposedITAT Delhi04 Jun 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…Nos.826 & 1000/Del/2016, 4693 & 4760/Del/2019 & 504/Del/2022 B. The decision of the learned CIT (A) that scarp sales is part of appellant turnover is contrary to the decision of the Hon'ble Supreme Court in the case of CIT V Punjab Stainless Steel Industries 364 ITR 144. 3. On the facts and circumstances of the case and in law the learned CIT(A) erred in dismissing appellant ground of appeal against charging of interest u/s 234B, 234C & 234D when prepaid taxes were more than the tax payable determined on assessment. 4. That the above grounds of appeal are without prejudice to each other. 5. Appellant craves for…

DCIT CIRCLE-13(2), NEW DELHI vs. JINDAL SAW LTD., NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 4760/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…Nos.826 & 1000/Del/2016, 4693 & 4760/Del/2019 & 504/Del/2022 B. The decision of the learned CIT (A) that scarp sales is part of appellant turnover is contrary to the decision of the Hon'ble Supreme Court in the case of CIT V Punjab Stainless Steel Industries 364 ITR 144. 3. On the facts and circumstances of the case and in law the learned CIT(A) erred in dismissing appellant ground of appeal against charging of interest u/s 234B, 234C & 234D when prepaid taxes were more than the tax payable determined on assessment. 4. That the above grounds of appeal are without prejudice to each other. 5. Appellant craves for…

JINDAL SAW LTD.,NEW DELHI vs. ACIT CIRCLE-13(2), NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 4693/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…Nos.826 & 1000/Del/2016, 4693 & 4760/Del/2019 & 504/Del/2022 B. The decision of the learned CIT (A) that scarp sales is part of appellant turnover is contrary to the decision of the Hon'ble Supreme Court in the case of CIT V Punjab Stainless Steel Industries 364 ITR 144. 3. On the facts and circumstances of the case and in law the learned CIT(A) erred in dismissing appellant ground of appeal against charging of interest u/s 234B, 234C & 234D when prepaid taxes were more than the tax payable determined on assessment. 4. That the above grounds of appeal are without prejudice to each other. 5. Appellant craves for…

BAJAJ HOLDINGS & INVESTMENTS LTD ( FORMERLY KNOWN AS BAJAJ AUTO LTD),MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

The appeals are partly allowed

ITA 6838/MUM/2008[2004-2005]Status: DisposedITAT Mumbai17 Feb 2025AY 2004-2005

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Ankush Kapoor
Section 143(3)

…ap sales, sundry sales, etc. aggregating to INR.301,41,79,718/- from Total Turnover for the purpose of computing deduction under Section 80HHC of the Act. 59.2. We note that in the case of Commissioner of Income Tax-VII Vs. Punjab Stainless Steel Industries: 364 ITR 144, the Hon’ble Supreme Court has held that that for purposes of computing allowable deduction under Section 80HHC of the Act, scrap sales cannot form part of 'Total Turnover'. Following the aforesaid judgment, the Tribunal has decided this issue in favour of the Assessee in the following appeals: (a) AY 1995-96 (ITA No.3144/Mum/1999, dated 20/01/20…

DCIT, NEW DELHI vs. M/S HUDCO LTD.,, NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 3904/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…it. ** ** 18. Without a doubt, in a catena of cases, this Court has discussed the relevancy of the Guidance Note. While dealing with one of such matters, this Court, in CIT v. Punjab Stainless Steel Industries [CIT v. Punjab Stainless Steel Industries, (2014) 15 SCC 129] held as under: (SCC p.134, para 17) "17. So as to be more accurate about the word "turnover", one can either refer to dictionaries or to material which are published by bodies of accountants. The Institute of Chartered Accountants of India (hereinafter referred to as "ICAI") has published some material under the head "Guidance Note on Tax Audit u…

M/S. HOUSING & URBAN DEVELOPMENT CORPORATION LTD. (HUDCO),NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 3261/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…it. ** ** 18. Without a doubt, in a catena of cases, this Court has discussed the relevancy of the Guidance Note. While dealing with one of such matters, this Court, in CIT v. Punjab Stainless Steel Industries [CIT v. Punjab Stainless Steel Industries, (2014) 15 SCC 129] held as under: (SCC p.134, para 17) "17. So as to be more accurate about the word "turnover", one can either refer to dictionaries or to material which are published by bodies of accountants. The Institute of Chartered Accountants of India (hereinafter referred to as "ICAI") has published some material under the head "Guidance Note on Tax Audit u…

M/S. BAJAJ AUTO LTD.,MUMBAI vs. ADDL. CIT. RG. - 3(1), MUMBAI

ITA 1496/MUM/2007[2003-2004]Status: DisposedITAT Mumbai09 Sept 2024AY 2003-2004
Section 115JSection 14ASection 250Section 35DSection 40Section 80H

…the assessee carried the issue in appeal before the Tribunal in ITA No.3144/Mum/1999 (supra). The Co-ordinate Bench after placing reliance on the decision rendered by Hon'ble Supreme Court of India in the case of CIT vs. Punjab Stainless Steel Industries Ltd. 364 ITR 144 decided the issue in favour of assessee. Since, in the impugned assessment year there is no distinguishing feature, we see no reason to take a different view. Consequently, additional ground No.1 of the appeal is allowed” Following the decision of ITAT this ground of appeal of the assessee is allowed.' 42. In view of the above, as the issue is re…

BAJAJ HOLDNGS & INVESTMENT LTD ( ERSTWHILE BAJAJ AUTO LTD),MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

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

ITA 3043/MUM/2010[2002-013]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-013

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

…he assessee. He placed reliance on the following judicial pronouncements: a. ITAT-AY 1995-96 (ITA No.3144/Mum/1999) b. ITAT-AY 1996-97 (ITA No. 1781/Mum/1999) c. ITAT-AY 1997-98 (ITA No. 5030/Mum/2001) d. CIT vs. Punjab Stainless Steel Industries Ltd. [2014] 364 ITR 144 (SC) On the other hand, the ld. D.R supported the order lower authorities. 44. Heard both the sides and perused the material on record. The assessee claimed that such miscellaneous receipts do not form part of the sales of manufacture goods to represent cost of goods manufactured for the purpose of calculating the deduction u/s 80HHC and same oug…

ADDL CIT RG 3(1), MUMBAI vs. BAJAJ AUTO LTD, MUMBAI

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

ITA 2899/MUM/2010[2002-03]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-03

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

…he assessee. He placed reliance on the following judicial pronouncements: a. ITAT-AY 1995-96 (ITA No.3144/Mum/1999) b. ITAT-AY 1996-97 (ITA No. 1781/Mum/1999) c. ITAT-AY 1997-98 (ITA No. 5030/Mum/2001) d. CIT vs. Punjab Stainless Steel Industries Ltd. [2014] 364 ITR 144 (SC) On the other hand, the ld. D.R supported the order lower authorities. 44. Heard both the sides and perused the material on record. The assessee claimed that such miscellaneous receipts do not form part of the sales of manufacture goods to represent cost of goods manufactured for the purpose of calculating the deduction u/s 80HHC and same oug…

ACIT CIR 7(1), MUMBAI vs. NOVARTIS INDIA ( FORMELRY KNOWN AS HINDUSTAN CIBA GIEGY LTD), MUMBAI

In the result, (i) the appeal filed by the assessee is partly allowed for statistical purpose (ii) the appeal filed by the revenue is dismissed and (iii) the Cross Objections filed by the assessee ...

ITA 2188/MUM/2012[2003-04]Status: DisposedITAT Mumbai28 May 2024AY 2003-04

Bench: Pavan Kumar Gadale & Shri Girish Agrawal & Co 76/Mum/2013 (A.Y 2003-04) Novartis India Limited Vs. Deputy Commissioner Of Income–Tax–14(1)(1) Inspire Bkc, 7Th Floor, Room No 432, Bandra Kurla Complex, Aaykar Bhawan, Bandra (E) M.K. Marg, Mumbai-400051. Mumbai-400020. Pan/Gir No. Aaach2914F (अपीलाथ"/Appellant) (""यथ"/Respondent) Deputy Commissioner Vs. Novartis India Limited Of Income–Tax–14(1)(1) Inspire Bkc, 7Th Floor, Room No 432, Bandra Kurla Complex, Aaykar Bhawan, Bandra (E) M.K. Marg, Mumbai-400051 Mumbai-400020 Pan/Gir No. Aaach2914F (अपीलाथ"/Appellant (""यथ"/Respondent)

Section 37(1)Section 41(3)Section 80H

…t. Hence, we do not find any merit in these appeals.” 37. The learned Counsel for the assessee similarly in respect to scrap sale argued that the issue is covered by Hon’ble Supreme Court decision in the case of CIT vs Punjab Stainless Steel Industries (2014) 364 ITR 144 (SC), wherein it is held as under: 39 ITA. No. 2308&2188/Mum/2012 &C.O.76/Mum/2013(A.Y.: 2003-04) Novartis India Limited, Mumbai “22. So far as the scrap is concerned, the sale proceeds from the scrap may either be shown separately in the Profit and Loss Account or may be deducted from the amount spent by the manufacturing unit on the raw mater…

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

ITA 6772/MUM/2010[2002-03]Status: DisposedITAT Mumbai20 Mar 2024AY 2002-03

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 2

…t. Hence, we do not find any merit in these appeals.” 37. The learned Counsel for the assessee similarly in respect to scrap sale argued that the issue is covered by Hon’ble Supreme Court decision in the case of CIT vs Punjab Stainless Steel Industries (2014) 364 ITR 144 (SC), wherein it is held as under: “22. So far as the scrap is concerned, the sale proceeds from the scrap may either be shown separately in the Profit and Loss Account or may be deducted from the amount spent by the manufacturing unit on the raw material, which is steel in the case of the respondent-assessee, as the respondent-assessee is using…

ACIT (LTU-1), MUMBAI vs. BAJAJ HOLDINGS & INVESTMENT LTD, MUMBAI

In the result, cross objection filed by the assessee is partly allowed

ITA 5030/MUM/2001[1997-98]Status: DisposedITAT Mumbai13 Apr 2023AY 1997-98

Bench: Shri Kuldip Singh, Hon’Ble & Shri S. Rifaur Rahman, Hon'Bleacit (Ltu-1) V. Bajaj Holdings Investment Ltd 29Th, Floor, Centre-1 226, Bajaj Bhavan, 2Nd Floor World Trade Centre Jamnalal Bajaj Marg, Nariman Point Mumbai- 400021 Cuffe Parade, Mumbai- 400075 Pan: Aaacb3370K (Appellant) (Respondent) C.O.No. 96/Mum/2002 [Arising Out Of Ita No.5030/Mum/2001 (A.Y: 1997-98)] Bhajaj Auto Limited V. Acit (Ltu-1) Bhajaj Bhavan 29Th, Floor, Centre-1 Nariman Point World Trade Centre Mumbai - 400020 Cuffe Parade, Mumbai- 400075 Pan: Aaacb3370K (Appellant) (Respondent) Assessee Represented By : Shri Percy Pardiwala& Ms. Vasanti Patel Department Represented By : Shri Rahul Kumar & Shri Vranda U Matkarri

Section 2(24)Section 35DSection 37(2)Section 80H

…the assessee carried the issue in appeal before the Tribunal in ITA No.3144/Mum/1999 (supra). The Co-ordinate Bench after placing reliance on the decision rendered by Hon'ble Supreme Court of India in the case of CIT vs. Punjab Stainless Steel Industries Ltd. 364 ITR 144 decided the issue in favour of assessee. Since, in the impugned assessment year there is no distinguishing feature, we see no reason to take a different view. Consequently, additional ground No.1 of the appeal is allowed.” Page No.| 21 C.O.No. 96/MUM/2002 Bajaj Holdings Investment Ltd 30. Respectfully following the above decision and following t…

CGI INFORMATION SYSTEMS vs. DEPUTY COMMISSIONER

Appeal is allowed;

ITA/822/2017HC Karnataka24 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 260Section 80H

…- 1 - ITA No. 822/2017 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF JANUARY, 2023 PRESENT THE HON'BLE MR. JUSTICE P.S.DINESH KUMAR AND THE HON'BLE MR. JUSTICE G BASAVARAJA INCOME TAX APPEAL NO.822 OF 2017 BETWEEN: CGI INFORMATION SYSTEMS AND MANAGEMENT CONSULTANTS PRIVATE LIMITED PRESENTLY ELECTRONIC CITY TOWER II NO.95/1 AND 95/2 ELECTRONIC CITY PHASE I (WEST) BANGALORE-560 100 REPRESENTED HEREIN BY ITS DIRECTOR MS. BABALUSHA ESTHER ALEXANDER PAN NO: AAACI 1994C. …APPELLANT (BY SHRI. T. SURYANA…

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