What is CIT v. Rajendra Prasad Moody authority for?

For deductions under Section 57(iii) relating to "Income from Other Sources," an expenditure is allowable if it is laid out wholly and exclusively for the purpose of making or earning such income, even if no income is actually earned in that previous year.

How many judgments cite CIT v. Rajendra Prasad Moody?

386 judgments on BharatTax cite CIT v. Rajendra Prasad Moody (115 ITR 519), spanning 2009 to 2026.

Which sections of the Income Tax Act does CIT v. Rajendra Prasad Moody come up under?

It is most often cited in judgments turning on Section 143(3), Section 57(iii), Section 1961, Section 14A, Section 37(1), Section 68.

CIT v. Rajendra Prasad Moody (115 ITR 519)

Delhi Metro Rail Corporation Ltd, New Delhi vs. CIT, New Delhi

The appeal of the assessee is dismissed

ITA 1153/DEL/2009[2003-04]Status: DisposedITAT Delhi26 Sept 2019AY 2003-04

Bench: Ms Suchitra Kamble & Shri Prashant Maharishii.T.A. No. 4432/Del/2005 (A.Y. 2000-01) I.T.A. No. 4433/Del/2005 (A.Y. 2001-02)

Section 10Section 143(3)Section 263Section 271(1)(c)Section 56

…is held assessable under the head ‘income from other sources’ that will make no difference in as much as business loss will go up and the same has to be set off from the purported income from other sources. The Ld. AR relied upon CIT vs. Rajendra Prasad Moody 115 ITR 519 (SC). 11. The Ld. DR submitted that the assessee has earned huge amount of interest income in years under consideration. The surplus funds have been deposit as fixed deposit/flexi deposit. The business of the assessee is planning, development, construction, maintenance, operation and financing of mass transit and urban transport system in nation…

DCIT, Circle-10(1) vs. Delhi Metro Rail Corporation Ltd

The appeal of the assessee is dismissed

ITA 4433/DEL/2005[2001-2002]Status: DisposedITAT Delhi26 Sept 2019AY 2001-2002

Bench: Ms Suchitra Kamble & Shri Prashant Maharishii.T.A. No. 4432/Del/2005 (A.Y. 2000-01) I.T.A. No. 4433/Del/2005 (A.Y. 2001-02)

Section 10Section 143(3)Section 263Section 271(1)(c)Section 56

…is held assessable under the head ‘income from other sources’ that will make no difference in as much as business loss will go up and the same has to be set off from the purported income from other sources. The Ld. AR relied upon CIT vs. Rajendra Prasad Moody 115 ITR 519 (SC). 11. The Ld. DR submitted that the assessee has earned huge amount of interest income in years under consideration. The surplus funds have been deposit as fixed deposit/flexi deposit. The business of the assessee is planning, development, construction, maintenance, operation and financing of mass transit and urban transport system in nation…

Svl Limited, Chennai vs. ITO Corporate Ward 6(3), Chennai

In the result, the appeal filed by the Revenue in ITA

ITA 3004/CHNY/2017[2014-15]Status: DisposedITAT Chennai16 Sept 2019AY 2014-15

Bench: Shri George Mathan & Shri Inturi Rama Rao

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Mr. M.Srinivasa Rao, CIT

Section 115JSection 143(3)Section 14A

…dition u/s.14A, holding the assessee did not earn any exempt income during the year when Rule 8D does not make distinction and the intention of the assessee in making such investment is relevant to the issue as held by the Apex Court in Rajendra Prasad Moody (115 ITR 519) and actual earning of interest in a particular year. 2.3) The Ld CIT(A) failed to appreciate that disallowance u/s.14A is attracted even in a case where there is no exempt income earned as held in the Chennai ITAT decision in the case of M/s.Siva Industries & Holding Ltd Vs ACIT (54 SOT 49) and which is in conformity' with department view as cla…

DCIT Corporate Circle 6(2), Chennai vs. Svl Limited, Chennai

In the result, the appeal filed by the Revenue in ITA

ITA 2734/CHNY/2017[2014-15]Status: DisposedITAT Chennai16 Sept 2019AY 2014-15

Bench: Shri George Mathan & Shri Inturi Rama Rao

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Mr. M.Srinivasa Rao, CIT

Section 115JSection 143(3)Section 14A

…dition u/s.14A, holding the assessee did not earn any exempt income during the year when Rule 8D does not make distinction and the intention of the assessee in making such investment is relevant to the issue as held by the Apex Court in Rajendra Prasad Moody (115 ITR 519) and actual earning of interest in a particular year. 2.3) The Ld CIT(A) failed to appreciate that disallowance u/s.14A is attracted even in a case where there is no exempt income earned as held in the Chennai ITAT decision in the case of M/s.Siva Industries & Holding Ltd Vs ACIT (54 SOT 49) and which is in conformity' with department view as cla…

ACIT, New Delhi vs. M/S. Godavari Shilpkala Hospitality Pvt. Ltd., New Delhi

In the result, the appeal filed by the Revenue is therefore dismissed

ITA 4249/DEL/2016[2012-13]Status: DisposedITAT Delhi28 Aug 2019AY 2012-13

Bench: Shri Prashant Maharishi & Shri K. Narasimha Chary

For Appellant: Shri Amit Katoch, Senior DRFor Respondent: Shri Ajay Wadhwa, Advocate

Section 14ASection 194Section 37(1)

…ion 14A of the Act without consider a 2 ITA No.4249/Del./2016 legal principles that allowability of expenditure under the Act is not conditional upon the earning of the income as upheld by Hon'ble Supreme Court in case of CIT Vs. Rajendra Prasad Moody [1978] 115 ITR 519. 3. Whether on facts and circumstances of the case and law, the Ld. CIT(A) is justified in deleting the addition of Rs.66,75,874/- by ignoring the provisions of section 37(1) of the I.T. Act, 1961. 4. Whether on facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the addition of Rs.66,75,874/-, whereas the audi…

Sh. Dharam Pal Aggarwal, Ludhiana vs. ACIT, Ludhiana

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

ITA 91/CHANDI/2019[2013-14]Status: DisposedITAT Chandigarh26 Aug 2019AY 2013-14

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Chandrakanta, Sr. DR

Section 143(1)Section 250(6)Section 57

…s. Addl. CIT 166 ITR 176 (SC) • Mrs. Arundhati Balkrishna Vs. CIT, Ahmedabad. 177 ITR 275 (SC) • Vijay Laxmi Sugar Mills Ltd. Vs. CIT 191 ITR 647 (SC) • Karnataka Forest Plantations Corpn. Ltd. 156 ITR 275 (Karnataka HC) • CIT Vs. Rajendra Prasad Moody [1978] 115 ITR 519 (SC) • Smt. Virmati Ramakrishan Vs. CIT 131ITR 659 (Guj. HC) 8. Now the assessee is in appeal. 9. Ld. Counsel for the Assessee reiterated the submissions made before the authorities below and further submitted that the similar interest paid on the loans was disallowed by the A.O. in the preceding year i.e; 2012-13, however the same was deleted…

Shri Rashmin Ramniklal Vora, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(5), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1066/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad18 Jun 2019AY 2013-14

For Appellant: Shreekant S. Shah, A.RFor Respondent: Shri Virendra Singh, Sr. D.R

Section 143(2)Section 143(3)Section 57

…mmissioner (Appeals) ought to have observed from the details on record that there is a huge potentiality of higher income. 5. The Commissioner (Appeals) ought to have followed ratio of Hon'ble Supreme Court in the case of CIT v/s Rajendraprasad Mody, Calcutta 115 ITR 519 (SC) that "It is not necessary that any income should in fact have been earned as a result of the expenditure. What section 57(Hi) requires is that the expenditure must be laid out or expended wholly and exclusively for the purpose of making or earning income. It is the purpose of the expenditure that is relevant in determining the applicability…