CIT v. Puttaiah Seshaiah& Co.

146 ITR 168High Court1984#16814 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2017.

Judgments citing CIT v. Puttaiah Seshaiah& Co.

VISTEON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,CHENGALPUT vs. ADDL CIT, CHENNAI

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

ITA 1395/CHNY/2016[2007-08]Status: DisposedITAT Chennai15 Mar 2017AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1551 & 1552/Mds/2015 "नधा"रण वष"/Assessment Years: 2005-06 & 2008-09 & आयकर अपील सं./Ita Nos.1394 & 1395/Mds/2016 "नधा"रण वष"/Assessment Years: 2006-07 & 2007-08

Section 43(5)

…gral part of the assessee’s business and they cannot be considered in isolation. But in the case of the assessee, the assessee has not proved that the forward contract of foreign exchange is an integral part of the business. The AO relied on the decision of 146 ITR 168 CIT AP-III v. Pullaiah Seshaiah & Company and held that the forward contract entered into by the assessee in respect of foreign exchange is well within the definition of speculative transaction enshrined in Sec.43(5) of Income Tax Act and hence, the amount of ₹1,15,06,084/- was disallowed u/s.73(1) of Income Tax Act. 4.0 Aggrieved by the orde…

VISTEON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,CHENGALPUT vs. ADDL CIT, CHENNAI

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

ITA 1394/CHNY/2016[2006-07]Status: DisposedITAT Chennai15 Mar 2017AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1551 & 1552/Mds/2015 "नधा"रण वष"/Assessment Years: 2005-06 & 2008-09 & आयकर अपील सं./Ita Nos.1394 & 1395/Mds/2016 "नधा"रण वष"/Assessment Years: 2006-07 & 2007-08

Section 43(5)

…gral part of the assessee’s business and they cannot be considered in isolation. But in the case of the assessee, the assessee has not proved that the forward contract of foreign exchange is an integral part of the business. The AO relied on the decision of 146 ITR 168 CIT AP-III v. Pullaiah Seshaiah & Company and held that the forward contract entered into by the assessee in respect of foreign exchange is well within the definition of speculative transaction enshrined in Sec.43(5) of Income Tax Act and hence, the amount of ₹1,15,06,084/- was disallowed u/s.73(1) of Income Tax Act. 4.0 Aggrieved by the orde…

VISTEON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,CHENGALPUT vs. DCIT, CHENNAI

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

ITA 1552/CHNY/2015[2008-09]Status: DisposedITAT Chennai15 Mar 2017AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1551 & 1552/Mds/2015 "नधा"रण वष"/Assessment Years: 2005-06 & 2008-09 & आयकर अपील सं./Ita Nos.1394 & 1395/Mds/2016 "नधा"रण वष"/Assessment Years: 2006-07 & 2007-08

Section 43(5)

…gral part of the assessee’s business and they cannot be considered in isolation. But in the case of the assessee, the assessee has not proved that the forward contract of foreign exchange is an integral part of the business. The AO relied on the decision of 146 ITR 168 CIT AP-III v. Pullaiah Seshaiah & Company and held that the forward contract entered into by the assessee in respect of foreign exchange is well within the definition of speculative transaction enshrined in Sec.43(5) of Income Tax Act and hence, the amount of ₹1,15,06,084/- was disallowed u/s.73(1) of Income Tax Act. 4.0 Aggrieved by the orde…

VISTEON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,CHENGALPUT vs. DCIT, CHENNAI

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

ITA 1551/CHNY/2015[2005-06]Status: DisposedITAT Chennai15 Mar 2017AY 2005-06

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1551 & 1552/Mds/2015 "नधा"रण वष"/Assessment Years: 2005-06 & 2008-09 & आयकर अपील सं./Ita Nos.1394 & 1395/Mds/2016 "नधा"रण वष"/Assessment Years: 2006-07 & 2007-08

Section 43(5)

…gral part of the assessee’s business and they cannot be considered in isolation. But in the case of the assessee, the assessee has not proved that the forward contract of foreign exchange is an integral part of the business. The AO relied on the decision of 146 ITR 168 CIT AP-III v. Pullaiah Seshaiah & Company and held that the forward contract entered into by the assessee in respect of foreign exchange is well within the definition of speculative transaction enshrined in Sec.43(5) of Income Tax Act and hence, the amount of ₹1,15,06,084/- was disallowed u/s.73(1) of Income Tax Act. 4.0 Aggrieved by the orde…

C. BHARAT KUMAR,BANGALORE vs. ITO, BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 123/BANG/2012[2001-02]Status: DisposedITAT Bangalore08 Jan 2016AY 2001-02

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri H.N.Khincha, CAFor Respondent: Shri Nambirajan, JCIT
Section 143(3)Section 43(5)

…tructive or implied delivery of scripts. Further, the Hon’ble Andhra Pradesh High Court in the case of CIT Vs Lakshminarayana Trading Co. after referring the decisions of the Hon’ble Supreme Court…. ITA No.123(B)/12 a. CIT Vs Puttaiah Seshaiah& Co. (1984) 146 ITR 168 (AP) b. CIT Vs Shantilal Pvt.Ltd (1983) 144 ITR 57(SC) c. Davenport & Co.Pvt.Ltd Vs CIT (1975) 100 ITR 715 (SC) d. Jute Investment Co.Ltd. Vs CIT (1980) 121 ITR 56 (SC) e.Raghunath Prasad Poddar Vs CIT (1973) 90 ITR 140(SC) f. Sind National Sugar Mills Pvt. Ltd Vs CIT (1980) 121 ITR 742(Bom.) and its earlier decisions in the case of CIT Vs Putta…

CIT v. Puttaiah Seshaiah& Co. (146 ITR 168) — Cited in 5 Judgments | BharatTax