CIT v. Ranbaxy Laboratories Ltd.

334 ITR 341High Court2011#8031 most cited
14

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2026.

Sections most often in play

Section 14ASection 244ASection 36(1)(vii)Section 36(1)(viia)Section 40(a)(ia)Section 43BSection 80-IA
Read the full judgment

Issues it is cited on

section 40a(9)right to receivedirections of the drpmercantile system of accountingsection 43bdisallowance under section 14asection 40adispute resolution panelsection 145revenue expendituresection 36(1)section 43

Judgments citing CIT v. Ranbaxy Laboratories Ltd.

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…l provisions of AS-15. The aforesaid provision does not represent contribution to any pension fund, and hence, the provisions of sections 36(1)(iv)/36(1)(v) or 40A(7)/40A(9) or 43B of the Act are not applicable. 22. In CIT vs. Ranbaxy Laboratories Ltd. [2011] 334 ITR 341 (Delhi), the Delhi High Court was concerned with a case where the assessee had introduced a pension scheme for its managerial employees which was over and above the benefits available under the superannuation scheme of the company. The Delhi High Court held that the pension scheme of the assessee does not envisage any regular contribution to any…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…l provisions of AS-15. The aforesaid provision does not represent contribution to any pension fund, and hence, the provisions of sections 36(1)(iv)/36(1)(v) or 40A(7)/40A(9) or 43B of the Act are not applicable. 22. In CIT vs. Ranbaxy Laboratories Ltd. [2011] 334 ITR 341 (Delhi), the Delhi High Court was concerned with a case where the assessee had introduced a pension scheme for its managerial employees which was over and above the benefits available under the superannuation scheme of the company. The Delhi High Court held that the pension scheme of the assessee does not envisage any regular contribution to any…

TATA CHEMICALS LTD,MUMBAI vs. ADDL CIAT 2(3), MUMBAI

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

ITA 120/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Nov 2023AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 144C(5)Section 14ASection 43BSection 80

…ies (India) Ltd. 98 taxmann.com 90 (2018) (Calcutta-H.C.) (para 10- 11) (Refer C.1.-26, pgs 292-295) 2. Mahindra & Mahindra Ltd. 117 taxmann.com 518 (Mum. ITAT) [2020] (para 14 Pg22- 23) (Refer C.L-27, pgs 296-330) 3. Delhi High Court in Ranbaxy Laboratories (334 ITR 341) (para 4-9) (Refer C.L.-28. Pgs331-334) 4. Nalco ITA No.27 of 2006 (2022) (Orissa-H.C.) (para 18-24; Pg 6-7) (Refer C.L. 29. pgs 335-341) ITA.NO. 120/MUM/2013 (A.Y: 2008-09) Tata Chemicals Ltd 5. GlaxoSmithKline Consumer Healthcare Ltd. 64 taxmann.com 84 [2015] (Chandigarh- ITAT) (pg12-18 para 29-35) (Refer C.L. 30, pgs 342-368) 6. Rural Electrif…

ASST CIT CIR 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 4564/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…l provisions of AS-15. The aforesaid provision does not represent contribution to any pension fund, and hence, the provisions of sections 36(1)(iv)/36(1)(v) or 40A(7)/40A(9) or 43B of the Act are not applicable. 22. In CIT vs. Ranbaxy Laboratories Ltd. [2011] 334 ITR 341 (Delhi), the Delhi High Court was concerned with a case where the assessee had introduced a pension scheme for its managerial employees which was over and above the benefits available under the superannuation scheme of the company. The Delhi High Court held that the pension scheme of the assessee does not envisage any regular contribution to any…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 3645/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…l provisions of AS-15. The aforesaid provision does not represent contribution to any pension fund, and hence, the provisions of sections 36(1)(iv)/36(1)(v) or 40A(7)/40A(9) or 43B of the Act are not applicable. 22. In CIT vs. Ranbaxy Laboratories Ltd. [2011] 334 ITR 341 (Delhi), the Delhi High Court was concerned with a case where the assessee had introduced a pension scheme for its managerial employees which was over and above the benefits available under the superannuation scheme of the company. The Delhi High Court held that the pension scheme of the assessee does not envisage any regular contribution to any…

NATIONAL FERTILIZERS LTD.,NEW DELHI vs. ADDL. CIT, RANGE- 18, NEW DELHI

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

ITA 1148/DEL/2018[2011-12]Status: DisposedITAT Delhi02 Nov 2022AY 2011-12

Bench: Shri Anil Chaturvedia N D Shri Challa Nagendra Prasad

For Appellant: Shri Aman Garg, C. AFor Respondent: [CIT] – D. R
Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order of the CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behind by the Assessing Officer (AO) unless it is shown to be not basec jn any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…

ACIT, CIRCLE- 17(2), , NEW DELHI vs. NATIONAL FERTILIZERS LTD., NEW DELHI

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

ITA 1041/DEL/2018[2011-12]Status: DisposedITAT Delhi02 Nov 2022AY 2011-12

Bench: Shri Anil Chaturvedia N D Shri Challa Nagendra Prasad

For Appellant: Shri Aman Garg, C. AFor Respondent: [CIT] – D. R
Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order of the CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behind by the Assessing Officer (AO) unless it is shown to be not basec jn any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…

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

…rder dated 28.07.2017 passed by a coordinate Bench of this Tribunal. He drew our attention to paragraph No. 7 of the Tribunal order, wherein while following the decision of the Hon’ble jurisdictional High Court in the case of CIT vs. Ranbaxy Laboratories Ltd. 334 ITR 341 (Del), the Coordinate Bench of this Tribunal allowed relief to the assessee. Having gone through the order dated 28.07.2017 in ITA No. 5122/Del/2014 in assessee’s own case for the assessment year 2010-11, we are satisfied that the ground of appeal of the assessee is squarely covered by the findings of the Co-ordinate Bench of Tribunal and since t…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

ITA 3644/MUM/2016[2008-09]Status: DisposedITAT Mumbai03 Feb 2020AY 2008-09

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

For Appellant: Shri P.J. Pardiwalla &For Respondent: Shri Anadi Varma, CIT-DR&
Section 143(3)Section 147

…in ITA NO. 4949/Mum/2013 dated 23.12.2016 for A.Y. 2009-10, which has since merged with assessee bank and referred to Para 18.1 of the order. He then took us through the decision of the Hon'ble Delhi High Court in the case of CIT vs. Ranbaxi Laboratories Ltd 334 ITR 341 (Del) and stated that the issue is covered by the decision of the Hon'ble Delhi High Court because wherein a superannuation claim of its employees was under litigation and the Hon'ble Delhi High Court has noted that this claim was non funded and applicable to the managerial employees and hence the liability on account of superannuation of its emp…

DCIT 1(3), MUMBAI vs. TATA MOTORS FINANCE LTD, MUMBAI

In the result, appeal for A

ITA 3476/MUM/2013[2008-09]Status: DisposedITAT Mumbai19 Sept 2018AY 2008-09

Bench: Shri R.C.Sharma, Am & Shri Amarjit Singh, Jm

Section 143(3)

…ming the disallowance made by the AO in respect of post retirement benefit scheme under section 43B (b) of the Act. In claiming the said deduction, we have relied upon the decision of Honourable Delhi high Court in the case of CIT vs Ranbaxy Laboratories Ltd. 334 ITR 341 (Del.) 3. Disallowance of Expenses of Rs. 14,98,5947- under provisions of section 4Q(ia) of the Income Tax Act due to non deduction of TDS M/s. Tata Motors Finance Ltd., The CIT (A) has erred in law and on facts in confirming the disallowance of Rs. 14,98,5947- made by the AO in respect of expenses under provisions of section 40(ia) of the Act. T…

AJAY KUMAR GOYAL,HAPUR vs. ITO, WARD- 3(4), HAPUR

In the result, appeal of the assessee is allowed

ITA 557/DEL/2018[2011-12]Status: DisposedITAT Delhi22 Jun 2018AY 2011-12

Bench: Shri O.P. Kant & Shri Kuldip Singh

For Appellant: Sh. Sanjay Malik (Adv .)For Respondent: Sh. B.R. Mishra (Sr. DR)
Section 147Section 148Section 234A

…reopened. He has drawn our attention to the copy of reasons recorded available on page 3 of the Paper Book. In support of his contention, he relied on the decision of the Hon’ble Delhi High Court in the case of Ranbaxy laboratories Ltd. vs. CIT reported in 334 ITR 341 [2011], Wherein it is held that if the addition based on the reasons recorded does not survive, the proceedings under section 147 cannot withstand. 6. On the contrary, the Ld. DR relied on the order of the lower authorities. 7. We have heard the rival submissions and perused the relevant material on record. In the case of Ranbaxy laboratories…

PR. COMMISSSIONER OF INCOME TAX-06 vs. NATIONAL FERTILIZER LIMITED

ITA/551/2016HC Delhi24 Apr 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 260Section 37(1)Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order ofthe CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behindby the Assessing Officer (AO) unless it is shown to be not based on any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…

PR. COMMISSIONER OF INCOME TAX-6 vs. NATIONAL FERTILIZERS LTD .

ITA/784/2016HC Delhi24 Apr 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 260Section 37(1)Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order ofthe CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behindby the Assessing Officer (AO) unless it is shown to be not based on any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…

PR. COMMISSIONER OF INCOME TAX-6 vs. NATIONAL FERTILIZERS LTD.

ITA/782/2016HC Delhi24 Apr 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 260Section 37(1)Section 43B

…and the decision of this Court in CIT vs. Bharat Heavy Electrical Ltd. [2013] 352 ITR 88 (Del) and upheld the order ofthe CIT (A). 7. The Court's attention is drawn by learned counsel for the Assessee to the decision in CIT v Ranbaxy Laboratories Ltd. (2011) 334 ITR 341 (Del). The ratio of the above decision is that where there are actuarial reports supporting the provision to meet a contingent liability, it cannot be gone behindby the Assessing Officer (AO) unless it is shown to be not based on any scientific or know financial principles. 8. It is sought to be urged by learned counsel for the Revenue that only…