CIT v. Punjab Tractors Co-operative Multi-purpose Society Ltd.

234 ITR 10Reported decision#15383 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2018 to 2025.

Sections most often in play

Section 133(6)Section 195(1)Section 244ASection 37(1)Section 40(a)(i)Section 9(1)(vii)Section 234DSection 194J

Issues it is cited on

section 195(1)section 234dright to receivesection 194jsection 244asection 9(1)(vii)section 40(a)(i)fees for technical servicesinterest under section 234btax treatysection 195section 9(1)

Judgments citing CIT v. Punjab Tractors Co-operative Multi-purpose Society Ltd.

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax-16(2), Mumbai

ITA 292/MUM/2024[2014-15]Status: DisposedITAT Mumbai04 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

…counsel for the assessee that income must accrue first. Receipt normally follows accrual. For this proposition, reliance was placed on the decision of the Hon'ble Punjab & Haryana High Court in the case of Punjab Tractors Co-operative Multipurpose Society Ltd 234 ITR 105 wherein the Hon'ble court has held that receipt by itself is not sufficient to attract tax. 22. The Id. counsel for the assessee further drew our attention to the decision of the co-ordinate bench in the case of DHS Chennai in ITA No. 2077/Mds/2016 order dated 25.11.2016. The Id. counsel for the assessee pointed out that similar issue was conside…

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax - 11(2), Mumbai

ITA 291/MUM/2024[2010-11]Status: DisposedITAT Mumbai04 Feb 2025AY 2010-11

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

…counsel for the assessee that income must accrue first. Receipt normally follows accrual. For this proposition, reliance was placed on the decision of the Hon'ble Punjab & Haryana High Court in the case of Punjab Tractors Co-operative Multipurpose Society Ltd 234 ITR 105 wherein the Hon'ble court has held that receipt by itself is not sufficient to attract tax. 22. The Id. counsel for the assessee further drew our attention to the decision of the co-ordinate bench in the case of DHS Chennai in ITA No. 2077/Mds/2016 order dated 25.11.2016. The Id. counsel for the assessee pointed out that similar issue was conside…

Deloitte Haskins and Sells LLP, Mumbai vs. Joint Range- 11(2), Mumbai

ITA 289/MUM/2024[2011-12]Status: DisposedITAT Mumbai04 Feb 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

…counsel for the assessee that income must accrue first. Receipt normally follows accrual. For this proposition, reliance was placed on the decision of the Hon'ble Punjab & Haryana High Court in the case of Punjab Tractors Co-operative Multipurpose Society Ltd 234 ITR 105 wherein the Hon'ble court has held that receipt by itself is not sufficient to attract tax. 22. The Id. counsel for the assessee further drew our attention to the decision of the co-ordinate bench in the case of DHS Chennai in ITA No. 2077/Mds/2016 order dated 25.11.2016. The Id. counsel for the assessee pointed out that similar issue was conside…

ACIT Non Corp Circle 1 (1) Formerly Known As Business Circle 1, Chennai vs. M/S Deolite Haskins & Sells, Chennai

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…n the services are rendered. The assessee is following the same method of accounting consistently for several years. The assessee placed reliance on the judgment of P& H High Court in the case of CIT vs Punjab Tractors Co- operative Multi-purpose Society Ltd, 234 ITR 10, decision of this Tribunal in S. Priyadarsan vs JCIT, 73 TTJ 738 and on identical issue in the case of associated concern of the assesseeviz. A.F. Ferguson & Co., in I.T.A.No.7792/Mum/2004 dated 30.1.2008, ITAT Mumbai. In the facts and circumstances of the case, we agree with the submission of the assessee that the advance cannot be treated as inc…

ACIT Non Corp Circle 1 (1) Formerly Known As Business Circle 1, Chennai vs. M/S Deolite Haskins & Sells, Chennai

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…n the services are rendered. The assessee is following the same method of accounting consistently for several years. The assessee placed reliance on the judgment of P& H High Court in the case of CIT vs Punjab Tractors Co- operative Multi-purpose Society Ltd, 234 ITR 10, decision of this Tribunal in S. Priyadarsan vs JCIT, 73 TTJ 738 and on identical issue in the case of associated concern of the assesseeviz. A.F. Ferguson & Co., in I.T.A.No.7792/Mum/2004 dated 30.1.2008, ITAT Mumbai. In the facts and circumstances of the case, we agree with the submission of the assessee that the advance cannot be treated as inc…

ACIT Non Corp Circle 1 (1) Formerly Known As Business Circle 1, Chennai vs. M/S Deolite Haskins & Sells, Chennai

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

…n the services are rendered. The assessee is following the same method of accounting consistently for several years. The assessee placed reliance on the judgment of P& H High Court in the case of CIT vs Punjab Tractors Co- operative Multi-purpose Society Ltd, 234 ITR 10, decision of this Tribunal in S. Priyadarsan vs JCIT, 73 TTJ 738 and on identical issue in the case of associated concern of the assesseeviz. A.F. Ferguson & Co., in I.T.A.No.7792/Mum/2004 dated 30.1.2008, ITAT Mumbai. In the facts and circumstances of the case, we agree with the submission of the assessee that the advance cannot be treated as inc…

CIT v. Punjab Tractors Co-operative Multi-purpose Society Ltd. (234 ITR 10) — Cited in 6 Judgments | BharatTax