CIT v. Rajendra Prasad Moody

115 ITR 519Supreme Court of India1978#191 most cited

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.

386

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2009 to 2026.

Also referred to as

CIT v. Rajendra Prasad Moody · Rajendra Prasad Moody · 115 ITR 519 · Section 57(iii) · Income from Other Sources · deductibility of expenditure · expenses without income · wholly and exclusively · purpose of making income · Section 14A distinction · disallowance of expenses

Sections most often in play

Section 143(3)Section 57(iii)Section 1961Section 14ASection 37(1)Section 68Section 36(1)(iii)Section 143(2)

Issues it is cited on

section 57(iii)section 57disallowance u/s 14adisallowance under section 14asection 14acapital expendituresection 37(1)income from other sourcessection 37salaryprevious yearsection 10

Judgments citing CIT v. Rajendra Prasad Moody

Dy. Commissioner of Income Tax, Circle-2(1)., Hyderabad vs. Ksk Energy Company Private Limited, Hyderabad

In the result, all the appeals of revenue are allowed

ITA 1663/HYD/2017[2014-15]Status: DisposedITAT Hyderabad30 Aug 2021AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Rama RaoFor Respondent: Smt. Nivedita Biswas
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A”: HYDERABAD (THROUGH VIRTUAL CONFERENCE) BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos. 1745/H/2016 and 1120, 1121 & 1663/H/2017 AY.: 2010-11, 2011-12, 2013-14 & 2014-15 Dy. Commissioner of Vs. KSK Energy Company Income-tax, Circle – Pvt. Ltd., Hyderabad. 2(1), Hyderabad. PAN – AACCK9414B (Appellant) (Respondent) Revenue by: Smt. Nivedita Biswas Assessee by: Shri S. Rama Rao Date of hearing: 24/02/2021 Date of pronouncement: 30/08/2021 O R D E R PER L.P. SAHU, A.M.: All these appeals filed by the…

Dy. Commissioner of Income Tax, Circle-2(1)., Hyderabad vs. Ksk Energy Company Private Limited, Hyderabad

In the result, all the appeals of revenue are allowed

ITA 1121/HYD/2017[2013-14]Status: DisposedITAT Hyderabad30 Aug 2021AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Rama RaoFor Respondent: Smt. Nivedita Biswas
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A”: HYDERABAD (THROUGH VIRTUAL CONFERENCE) BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos. 1745/H/2016 and 1120, 1121 & 1663/H/2017 AY.: 2010-11, 2011-12, 2013-14 & 2014-15 Dy. Commissioner of Vs. KSK Energy Company Income-tax, Circle – Pvt. Ltd., Hyderabad. 2(1), Hyderabad. PAN – AACCK9414B (Appellant) (Respondent) Revenue by: Smt. Nivedita Biswas Assessee by: Shri S. Rama Rao Date of hearing: 24/02/2021 Date of pronouncement: 30/08/2021 O R D E R PER L.P. SAHU, A.M.: All these appeals filed by the…

Dy. Commissioner of Income Tax, Circle-2(1)., Hyderabad vs. Ksk Energy Company Private Limited., Hyderabad

In the result, all the appeals of revenue are allowed

ITA 1120/HYD/2017[2011-12]Status: DisposedITAT Hyderabad30 Aug 2021AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Rama RaoFor Respondent: Smt. Nivedita Biswas
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A”: HYDERABAD (THROUGH VIRTUAL CONFERENCE) BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos. 1745/H/2016 and 1120, 1121 & 1663/H/2017 AY.: 2010-11, 2011-12, 2013-14 & 2014-15 Dy. Commissioner of Vs. KSK Energy Company Income-tax, Circle – Pvt. Ltd., Hyderabad. 2(1), Hyderabad. PAN – AACCK9414B (Appellant) (Respondent) Revenue by: Smt. Nivedita Biswas Assessee by: Shri S. Rama Rao Date of hearing: 24/02/2021 Date of pronouncement: 30/08/2021 O R D E R PER L.P. SAHU, A.M.: All these appeals filed by the…

DCIT, Circle-2(1), Hyderabad vs. Ksk Energy Company Private Limited, Hyderabad

In the result, all the appeals of revenue are allowed

ITA 1745/HYD/2016[2010-11]Status: DisposedITAT Hyderabad30 Aug 2021AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Rama RaoFor Respondent: Smt. Nivedita Biswas
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A”: HYDERABAD (THROUGH VIRTUAL CONFERENCE) BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos. 1745/H/2016 and 1120, 1121 & 1663/H/2017 AY.: 2010-11, 2011-12, 2013-14 & 2014-15 Dy. Commissioner of Vs. KSK Energy Company Income-tax, Circle – Pvt. Ltd., Hyderabad. 2(1), Hyderabad. PAN – AACCK9414B (Appellant) (Respondent) Revenue by: Smt. Nivedita Biswas Assessee by: Shri S. Rama Rao Date of hearing: 24/02/2021 Date of pronouncement: 30/08/2021 O R D E R PER L.P. SAHU, A.M.: All these appeals filed by the…

Ht Media Ltd., New Delhi vs. Addlcit, Range-4, New Delhi

In the result, the assessee’s appeal is partly

ITA 1876/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Aug 2021AY 2013-14

Bench: Shri R.K. Panda & Shri Vijay Pal Rao

For Appellant: Sh. V.P. Gupta, AdvFor Respondent: Ms. Sunita Singh, CIT DR
Section 115JSection 14ASection 14A(1)

…the Income Tax Act, 1961 without considering a legal principle that allowability/disallowability of expenditure under the Act is not conditional upon the earning of income as upheld by Hon’ble Supreme Court in the case of CIT vs. Rajendra Prasad Moody (1978) 115 ITR 519? 7. Whether the CIT(A) is justified in excluding the investment in subsidiary company, namely, Hindustan Media Venture Ltd. for working out disallowance u/s 14A r.w.r. 8D, without appreciating that investment in subsidiary company also result in non-taxable income against the law of land decided by the Hon’ble Supreme Court in the case of Maxopp…

DCIT, Circle-12(1), New Delhi vs. Il & Fs Energy Development Co. Ltd., New Delhi

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

ITA 3851/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Aug 2021AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing) Ita Nos. 3479 & 3851/Del/2018 (Assessment Years : 2013-14 & 2014-15) Dcit Vs. Il & Fs Energy Circle – 12(1) Development Co. Ltd., New Delhi A-268, 1St Floor, Bhishm Pitamah Marg & Defence Colony, New Delhi Pan No. Aabci 6885 K (Appellant) (Respondent) Assessee By --None-- Revenue By Shri Sarwan Kumar Gautam, Cit-D.R. Date Of Hearing: 18.08.2021 Date Of Pronouncement: 25.08.2021

Section 143(3)Section 14ASection 14A(1)

…nce u/ sl4A of the IT Act without considering a legal principle that allowability/disallowability 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? 6. The appellant craves leave for reserving the right to amend, modify, add or forego any ground(s) of appeal at any time before or during the hearing of appeal.” 6. Before us, the Learned DR submitted that though the Revenue has raised various grounds but the sole controversy is with respect to disallowance made u/s 14A r.w.r 8D of the Act. 7…

DCIT, New Delhi vs. M/S. Metso Minerals (India) Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1820/DEL/2017[2011-12]Status: DisposedITAT Delhi25 Aug 2021AY 2011-12

Bench: Shri O.P. Kant & Shri K.N. Chary[Through Video Conferencing] Assessment Year: 2011-12

Section 14Section 143(3)Section 36(1)(iii)Section 37Section 37(1)

…41/- u/s 14 A of the Act without considering legal principles that allowability or disallowability 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? 4. Whether in facts and on circumstances of the case, the Ld. CIT(A) is legally justified in deleting disallowance of interest expenditure of Rs. 54,339/- relatable to interest free advances u/s 36(1)(iii) of the Act even when the assessee was making huge payment of interest on loan and the assessee had not proved test of commercial expediency w…

M/S. National Fertilizers Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 3367/DEL/2017[2012-13]Status: DisposedITAT Delhi17 Aug 2021AY 2012-13

Bench: Shri O.P. Kant & Shri K. Narasimha Charyassessment Year: 2012-13

For Appellant: Sh. Ved Jain, AdvocateFor Respondent: Sh. Gaurav Pundir, Sr. DR
Section 143(3)Section 145Section 14ASection 37

…8/- u/s 14A of the Act without considering a legal principle that allowability or disallowability 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? 9. Whether in facts and circumstances of the case, Ld. CIT(A) is legally justified in deleting disallowance of Rs. 15,688/- u/s 14A of the Act without considering ratio decidendi as upheld in cases of CIT Vs. Walfort Share and Stock Brokers P. Ltd [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT [2012) 347 ITR 272 (Delhi) on application of pr…

National Building Construction Corporation Ltd., New Delhi vs. DCIT, Circle- 18(1), New Delhi

Appeals are disposed of by this common order

ITA 4287/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Jul 2021AY 2012-13

Bench: Ms. Suchitra Kamblea N D Shri Prashant Maharishi

For Appellant: Shri Sachin Kumar, C.AFor Respondent: Shri Gaurav Pundir, Sr. D. R
Section 140ASection 143(3)Section 14ASection 244ASection 37(1)Section 40

…13/- u/s 14A of the Act without considering a legal principle that allowability or disallowability of expenditure under the Act is not conditional upon th6 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 infacts and circumstances of the case, Ld.CIT(A) is legally Justified in deletingdisallowance u/s 14A of the Act without considering ratio decidendi as upheld in cases of CIT Vs. Walfort Share and Stock Brokers P. Ltdd [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT [2012] 347 ITR 272 (Delhi) onapplication of provision of section…

Addlcit, Special Range-6, Neww Delhi vs. National Building Construction Corporation Ltd., New Delhi

Appeals are disposed of by this common order

ITA 4165/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Jul 2021AY 2012-13

Bench: Ms. Suchitra Kamblea N D Shri Prashant Maharishi

For Appellant: Shri Sachin Kumar, C.AFor Respondent: Shri Gaurav Pundir, Sr. D. R
Section 140ASection 143(3)Section 14ASection 244ASection 37(1)Section 40

…13/- u/s 14A of the Act without considering a legal principle that allowability or disallowability of expenditure under the Act is not conditional upon th6 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 infacts and circumstances of the case, Ld.CIT(A) is legally Justified in deletingdisallowance u/s 14A of the Act without considering ratio decidendi as upheld in cases of CIT Vs. Walfort Share and Stock Brokers P. Ltdd [2010] 326 ITR 1 (SC) and Maxopp Investment Vs CIT [2012] 347 ITR 272 (Delhi) onapplication of provision of section…

Dhanuka Labs Ltd., New Delhi vs. DCIT, New Delhi

In the result, miscellaneous application as well as the appeal of the assessee is allowed

ITA 3898/DEL/2014[2009-10]Status: DisposedITAT Delhi23 Jul 2021AY 2009-10

Bench: Shri R.K. Panda & Shri K. Narasimha Chary

For Respondent: Ms. Aman Preet, Sr. DR
Section 14ASection 14A(2)Section 14A(3)

…ion in Taikisha Engineering India Pvt. Ltd. (supra) does not specifically deal with this issue. 22. It was suggested by Mr. Hossain that, in the context of Section 57(iii), the Supreme Court in Commissioner Of Income Tax, West v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC) explained that deduction is allowable even where income was not actually earned in the AY in question. This aspect of the matter was dealt with by this Court in M/s Cheminvest Ltd. (supra) where it reversed the decision of the Special Bench of the ITAT by observing as under: “20. Since the Special Bench has relied upon the decision of the Su…

ACIT, Circle- 13(2), New Delhi vs. Jindal Petroleum Ltd., New Delhi

In the result, appeal of the ld

ITA 4313/DEL/2017[2013-14]Status: DisposedITAT Delhi14 Jul 2021AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing) Acit, M/S. Jindal Petroleum Ltd., Vs. Jindal Centre, Circle : 13 (2), 12 – Bhikaji Cama Place, New Delhi – 110 066. New Delhi. Pan : Aaccj0610J (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Ms. Shivani Basal, Sr. D.R
Section 143(3)Section 14A

…/- u/s 14A of the Act without considering legal principles that allowability / disallowability of expenditure under the Act is not conditional upon the earning of the income as upheld by Hon’ble Supreme Court in the case of CIT vs Rajendra Prasad Moody [1978] 115 ITR 519? 3. Whether in facts in circumstances of the case and in law, the CIT (A) is justified in not upholding disallowance of Rs.55,06,261 u/s 14A of the Act ITA 4313 (Del) of 2017 without considering ratio decidendi as upheld in case of Maxopp Investment vs. CIT [2012 347 ITR 272 (Delhi)] on application of provisions of section 14A of the Act? 4. That…

ACIT, Circle- 11(2), New Delhi vs. Hind Industries Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 2302/DEL/2018[2012-13]Status: DisposedITAT Delhi08 Jul 2021AY 2012-13

Bench: Sh. Anil Chaturvedi & Sh. Sudhanshu Srivastava(Through Video Conferencing) Acit Vs. Hind Industries Ltd., Circle – 11(2), A-1, Phase – 1, New Delhi Okhla Industrial Area, New Delhi Pan No. Aaach 0870 N (Appellant) (Respondent) Assessee By --None-- Revenue By Ms. Sunita Singh, Cit (Dr) Date Of Hearing: 08/07/2021 Date Of Pronouncement: 08/07/2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 04.01.2018 Passed By The Commissioner Of Income Tax (Appeals)-42, New Delhi Relating To Assessment Year 2012-13. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

Section 143(3)Section 14ASection 14A(1)

…ance u/s 14A of the Act without considering a legal principle that allowability/disallowability of expenditure under 3 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? 6. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing.” 4. On the date of hearing none appeared on behalf of the assessee nor any adjournment application was filed on its behalf though the notice of hearing was issued to the assessee. In such a situation, we proceed to decide the matt…

M/S. Ganpati Global Private Ltd., Jaipur vs. ITO, Ward1(4), Jaipur

In the result, the appeal of the assessee is dismissed

ITA 302/JPR/2020[2013-14]Status: DisposedITAT Jaipur30 Jun 2021AY 2013-14
For Appellant: Shri Anoop Bhatia (CA)For Respondent: Smt. Monisha Choudhary (JCIT) a

…by the Income- 21 M/s Ganpati Global (P) Ltd. vs. ITO tax authorities. However, the Tribunal allowed the claim of the assessee. On a reference to the Madras High Court, after referring to the judgment of the Apex Court in CIT v. Rajendra Prasad Moody [1978] 115 ITR 519 and various other judgments of the High Courts, found that the borrowing has not been exclusively and solely for the purpose of earning interest in which case alone it should be taken as income which should be deducted from the interest receipt. This judgment of the Madras High Court in Seshasayee Paper and Boards Ltd. (supra) was specifically ta…

Sh. Ravinandan Kumar, Ludhiana vs. ACIT, C-7, Ludhiana

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

ITA 21/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh14 Jun 2021AY 2014-15
For Appellant: Shri Parikshit Aggarwal, CAFor Respondent: Shri Ashok Khanna, Addl.CIT
Section 143(3)Section 250(6)Section 57

…आयकर अपील"य अ"धकरण, च"डीगढ़ "यायपीठ “बी” च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH ‘B’, CHANDIGARH BEFORE: SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI R.L. NEGI, JUDICIAL MEMBER आयकर अपील सं./ ITA No.21/Chd/2019 "नधा"रण वष" / Assessment Year : 2014-15 Sh.Ravinandan Kumar, बनाम The D.C.I.T. , #606/2916, C/o M/s Rahul Sales, Circle – 7, Ludhiana. Krishna Nagar, Ferozpur Road, Ludhiana. "थायी लेखा सं./PAN NO: AGQPK5052L ""यथ"/Respondent अपीलाथ"/Appellant "नधा"रती क" ओर से/Assessee by : Shri Parikshit Aggarwal, CA राज"व क" ओर से/ Revenue by : Shri Ashok Khanna, Addl.CIT सुनवाई क" तार"ख/Dat…

The ACIT 2(3), Mumbai vs. M/S. Tata Sonsltd, Mumbai

Appeal stand allowed to that extent

ITA 4041/MUM/2007[2003-2004]Status: DisposedITAT Mumbai05 May 2021AY 2003-2004

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील िं./ I.T.A. No.4041/Mum/2007 (धििाारण वर्ा / Assessment Year: 2003-04) Acit-2(3) M/S. Tata Sons Ltd. बिाम/ Room No.555 Bombay House Aaykar Bhavan 24, Homi Modi Street Vs. Mumbai – 400 020. Fort, Mumbai – 400 001. स्थायीलेखा िं./ जीआइआर िं./ Pan/Gir No. Aaact-4060-A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : & आयकरअपील िं./ I.T.A. No.3664/Mum/2007 (धििाारण वर्ा / Assessment Year: 2003-04) M/S. Tata Sons Ltd. Acit-2(3) बिाम/ Bombay House Room No.555 24, Homi Modi Street Aaykar Bhavan Vs. Fort, Mumbai – 400 001. Mumbai – 400 020. स्थायीलेखा िं./ जीआइआर िं./ Pan/Gir No. Aaact-4060-A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Assessee By : Ms. Aarti Vissanji -Ld.Ar Revenue By : Shri Sanjay Singh-Ld.Cit-Dr ुनवाई की तारीख/ : 23/03/2021 Date Of Hearing घोषणा की तारीख / : 05/05/2021 Date Of Pronouncement Assessment Year 2003-04

For Appellant: Ms. Aarti Vissanji -Ld.ARFor Respondent: Shri Sanjay Singh-Ld.CIT-DR
Section 10ASection 10BSection 14ASection 36(1)(iii)Section 80MSection 90

…1 ITA Nos. 3664 & 4041/Mum/2007 M/s Tata Sons Limited Assessment Year 2003-04 आयकर अपीलीय अधिकरण “जे” न्यायपीठ म ुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI माननीय श्री महावीर स िंह, उपाध्यक्ष एवुं माननीय श्री मनोज कुमार अग्रवाल ,लेखा दस्य के मक्ष। BEFORE HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपील िं./ I.T.A. No.4041/Mum/2007 (धििाारण वर्ा / Assessment Year: 2003-04) ACIT-2(3) M/s. Tata Sons Ltd. बिाम/ Room No.555 Bombay House Aaykar Bhavan 24, Homi Modi Street Vs. Mumbai – 400 020. Fort, Mumbai – 400 001. स्थायीलेखा िं./ जीआइआर िं./ PAN/GIR No. AAACT-4…

M/S. the Karnataka State Co-Operative Apex Bank Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(2)(1), Bangalore

Accordingly, Ground No.3 raised by revenue for assessment years 2011-12 stands dismissed

ITA 1761/BANG/2019[2008-09]Status: DisposedITAT Bangalore08 Apr 2021AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Neera Malhotra, CIT(DR)(ITAT)For Respondent: Shri. S. Ramasubramanyan, CA
Section 147

…sult in profit. In this connection, reference may be made to the decision of the Hon'ble Apex Court in the case of CIT vs. ITA Nos.2082, 2150/Bang/2017 ITA Nos.1761,1327, 2159, 2160/Bang/2019 C.O. Nos.55 and 56/Bang/2019 Page 17 of 27 Rajendra Prasad Moody (115 ITR 519). It may be further stated that one of the objects of the assessee-co-onrative bank is to develop or assist and co-operative the member district central co-operative banks and other co-operative societies and therefore the contribution was only made in further pursuance of the objects of the bank for which it was established and therefore it cann…

Joint Commissioner of Income Tax, Special Range - 5, Bangalore vs. M/S. the Karnataka State Co-Operative Apex Bank Limited, Bangalore

Accordingly, Ground No.3 raised by revenue for assessment years 2011-12 stands dismissed

ITA 1327/BANG/2019[2011-12]Status: DisposedITAT Bangalore08 Apr 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Neera Malhotra, CIT(DR)(ITAT)For Respondent: Shri. S. Ramasubramanyan, CA
Section 147

…sult in profit. In this connection, reference may be made to the decision of the Hon'ble Apex Court in the case of CIT vs. ITA Nos.2082, 2150/Bang/2017 ITA Nos.1761,1327, 2159, 2160/Bang/2019 C.O. Nos.55 and 56/Bang/2019 Page 17 of 27 Rajendra Prasad Moody (115 ITR 519). It may be further stated that one of the objects of the assessee-co-onrative bank is to develop or assist and co-operative the member district central co-operative banks and other co-operative societies and therefore the contribution was only made in further pursuance of the objects of the bank for which it was established and therefore it cann…

Deputy Commissioner of Income Tax Circle-5(2)(1), Bangalore vs. M/S the Karnataka State Co-Operative Apex Bank Ltd, Bangalore

Accordingly, Ground No.3 raised by revenue for assessment years 2011-12 stands dismissed

ITA 2160/BANG/2017[2014-15]Status: DisposedITAT Bangalore08 Apr 2021AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Neera Malhotra, CIT(DR)(ITAT)For Respondent: Shri. S. Ramasubramanyan, CA
Section 147

…sult in profit. In this connection, reference may be made to the decision of the Hon'ble Apex Court in the case of CIT vs. ITA Nos.2082, 2150/Bang/2017 ITA Nos.1761,1327, 2159, 2160/Bang/2019 C.O. Nos.55 and 56/Bang/2019 Page 17 of 27 Rajendra Prasad Moody (115 ITR 519). It may be further stated that one of the objects of the assessee-co-onrative bank is to develop or assist and co-operative the member district central co-operative banks and other co-operative societies and therefore the contribution was only made in further pursuance of the objects of the bank for which it was established and therefore it cann…

Deputy Commissioner of Income Tax Circle-5(2)(1), Bangalore vs. M/S the Karnataka State Co-Operative Apex Bank Ltd, Bangalore

Accordingly, Ground No.3 raised by revenue for assessment years 2011-12 stands dismissed

ITA 2150/BANG/2017[2008-09]Status: DisposedITAT Bangalore08 Apr 2021AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Neera Malhotra, CIT(DR)(ITAT)For Respondent: Shri. S. Ramasubramanyan, CA
Section 147

…sult in profit. In this connection, reference may be made to the decision of the Hon'ble Apex Court in the case of CIT vs. ITA Nos.2082, 2150/Bang/2017 ITA Nos.1761,1327, 2159, 2160/Bang/2019 C.O. Nos.55 and 56/Bang/2019 Page 17 of 27 Rajendra Prasad Moody (115 ITR 519). It may be further stated that one of the objects of the assessee-co-onrative bank is to develop or assist and co-operative the member district central co-operative banks and other co-operative societies and therefore the contribution was only made in further pursuance of the objects of the bank for which it was established and therefore it cann…