CIT v. Ranjit Projects Private Limited

408 ITR 274Reported decision2018#10874 most cited

What is CIT v. Ranjit Projects Private Limited authority for?

An entity is eligible for deduction under Section 80-IA(4) if it enters into an agreement with a government agency for infrastructure development, even if that agency is a statutory body or a government-owned company.

10

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2022 to 2025.

Also referred to as

CIT v. Ranjit Projects Private Limited · 408 ITR 274 · Section 80IA · Section 80IA(4) · eligible business · government agency · infrastructure development · statutory body · deduction u/s 80IA

Sections most often in play

Section 37Section 80IA

Issues it is cited on

section 80ia(4)deduction u/s 80iaeligible businesssection 80iafees for technical servicessection 80irevenue expenditurecapital expenditurecross objectionsection 37scrutiny assessmentsection 80

Judgments citing CIT v. Ranjit Projects Private Limited

Dy. Commissioner of Income -Tax Ershtwhile 26(1), Now DCIT-41(1)(1), Mumbai vs. Gulermak Tpl Joint Venture, Mumbai

In the result, appeals of the assessee and the revenue are dismissed

ITA 3020/MUM/2022[2018-2019]Status: FixedITAT Mumbai29 Jan 2025AY 2018-2019

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J.D. Mistry, Sr. Advocate & Hiten ThakkarFor Respondent: Shri Kishor Dule, CIT D/R
Section 80I

…orail is concerned. It is not a case where the assessee will receive revenue from the Metrorail for a certain period. This fact is in contradiction to the facts considered by the Hon’ble Gujarat High Court in the case of Ranjit Projects Private Limited [2018] 408 ITR 274, which has been heavily relied upon by the ld. Counsel in as much as in that case, the assessee entered into an agreement for road development project with GSRDC and GSRDC was treated as a statutory body since it was a government agency as defined u/s 2(e) of Gujarat Infrastructure Development Act, 1999 whereas LMRCL, is a body corporate, though…

Dy. Commissioner of Income Tax -Erstwhile 26(1) Now DCIT41(1)(1), Mumbai vs. Gulemark Tpl Joint Venture, Mumbai

In the result, appeals of the assessee and the revenue are dismissed

ITA 3019/MUM/2022[2017-18]Status: FixedITAT Mumbai29 Jan 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J.D. Mistry, Sr. Advocate & Hiten ThakkarFor Respondent: Shri Kishor Dule, CIT D/R
Section 80I

…orail is concerned. It is not a case where the assessee will receive revenue from the Metrorail for a certain period. This fact is in contradiction to the facts considered by the Hon’ble Gujarat High Court in the case of Ranjit Projects Private Limited [2018] 408 ITR 274, which has been heavily relied upon by the ld. Counsel in as much as in that case, the assessee entered into an agreement for road development project with GSRDC and GSRDC was treated as a statutory body since it was a government agency as defined u/s 2(e) of Gujarat Infrastructure Development Act, 1999 whereas LMRCL, is a body corporate, though…

Gulermak Tpl Joint Venture, Mumbai vs. The National Faceless Appeal Centre (Commissioner of Income Tax-Appeals), Mumbai

In the result, appeals of the assessee and the revenue are dismissed

ITA 2876/MUM/2022[2017-18]Status: FixedITAT Mumbai29 Jan 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J.D. Mistry, Sr. Advocate & Hiten ThakkarFor Respondent: Shri Kishor Dule, CIT D/R
Section 80I

…orail is concerned. It is not a case where the assessee will receive revenue from the Metrorail for a certain period. This fact is in contradiction to the facts considered by the Hon’ble Gujarat High Court in the case of Ranjit Projects Private Limited [2018] 408 ITR 274, which has been heavily relied upon by the ld. Counsel in as much as in that case, the assessee entered into an agreement for road development project with GSRDC and GSRDC was treated as a statutory body since it was a government agency as defined u/s 2(e) of Gujarat Infrastructure Development Act, 1999 whereas LMRCL, is a body corporate, though…

Gulermak Tpl Joint Ventre, Mumbai vs. The National Faceless Appeal Centre (Commissioner of Income Tax-Appeals), Mumbai

In the result, appeals of the assessee and the revenue are dismissed

ITA 2875/MUM/2022[2018-19]Status: FixedITAT Mumbai29 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J.D. Mistry, Sr. Advocate & Hiten ThakkarFor Respondent: Shri Kishor Dule, CIT D/R
Section 80I

…orail is concerned. It is not a case where the assessee will receive revenue from the Metrorail for a certain period. This fact is in contradiction to the facts considered by the Hon’ble Gujarat High Court in the case of Ranjit Projects Private Limited [2018] 408 ITR 274, which has been heavily relied upon by the ld. Counsel in as much as in that case, the assessee entered into an agreement for road development project with GSRDC and GSRDC was treated as a statutory body since it was a government agency as defined u/s 2(e) of Gujarat Infrastructure Development Act, 1999 whereas LMRCL, is a body corporate, though…

T and T Infra Limited, Pune vs. Asst.Commissioner of Income-Tax, Circle-7, Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 291/PUN/2020[2016-17]Status: DisposedITAT Pune01 Oct 2024AY 2016-17

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2016-17 T & T Infra Limited Acit, Circle – 7, Pune A-1, Vishnu Vihar, Bibwewadi Vs. Kondhwa Road, Market Yard, Pune – 411037 Pan: Aaect3902H (Appellant) (Respondent) Assessee By : Shri Tarun Ghia Department By : S/Shri Ajay Kumar Keshari & Sourabh Nayak Date Of Hearing : 10-07-2024 Date Of Pronouncement : 01-10-2024 O R D E R Per Astha Chandra, Jm :

For Appellant: Shri Tarun GhiaFor Respondent: S/Shri Ajay Kumar Keshari and Sourabh Nayak
Section 143(2)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA CHANDRA, JUDICIAL MEMBER Assessment Year : 2016-17 T and T Infra Limited ACIT, Circle – 7, Pune A-1, Vishnu Vihar, Bibwewadi Vs. Kondhwa Road, Market Yard, Pune – 411037 PAN: AAECT3902H (Appellant) (Respondent) Assessee by : Shri Tarun Ghia Department by : S/Shri Ajay Kumar Keshari and Sourabh Nayak Date of hearing : 10-07-2024 Date of pronouncement : 01-10-2024 O R D E R PER ASTHA CHANDRA, JM : This appeal filed by the assessee is directed against the order dated 26.12.2019 of the CIT(A), Pune-5, Pun…

Principal Commissioner of Income Tax 1 Kolkata vs. Bothra Shipping Services Pvt Ltd

In the result, the appeals are dismissed and the substantial

ITAT/85/2024HC Calcutta25 Sept 2024

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 80I

…le for such deduction. B. Whether the order of the Ld. ITAT, Kolkata Bench is perverse to the extent in observing that the instant case is covered under Hon’ble High Court of Gujarat’s order in the case of CIT Vs. Ranjit Projects Private Limited [2018] 408 ITR 274 despite the fact that the circumstances of both the cases are entirely different as in the instant case the assesse never had an agreement either with the Government or even with the entity having such an agreement with the Government wherein in the case of Ranjit Projects Private Limited, the assesse had an agreement directly with a whol…

Principal Commissioner of Income Tax 1 Kolkata vs. Bothra Shipping Services Pvt Ltd

In the result, the appeals are dismissed and the substantial

ITAT/86/2024HC Calcutta25 Sept 2024

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 80I

…le for such deduction. B. Whether the order of the Ld. ITAT, Kolkata Bench is perverse to the extent in observing that the instant case is covered under Hon’ble High Court of Gujarat’s order in the case of CIT Vs. Ranjit Projects Private Limited [2018] 408 ITR 274 despite the fact that the circumstances of both the cases are entirely different as in the instant case the assesse never had an agreement either with the Government or even with the entity having such an agreement with the Government wherein in the case of Ranjit Projects Private Limited, the assesse had an agreement directly with a whol…

Bsc C&C Joint Venture, New Delhi vs. DCIT, Circle-61(1), New Delhi

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

ITA 2284/DEL/2022[2018-19]Status: DisposedITAT Delhi06 Feb 2024AY 2018-19

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Vivek Kumar Upadhyay, Sr. DR
Section 143(3)Section 234BSection 40Section 801A(4)(i)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘FRIDAY-I’’ : NEW DELHI) BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Asstt. Year : 2018-19 M/s BSC C&C Joint Venture, VS. DCIT, Circle-61(1), 74, Hemkunt Colony, New Delhi New Delhi - 48 E-2 Block, Civic Centre New Delhi - 2 (PAN: AADFB8115G) (Appellant) (Respondent) Appellant by : Sh. Tarandeep Singh, Adv. Respondent by : Sh. Vivek Kumar Upadhyay, Sr. DR. Date of Hearing 10.11.2023 Date of Pronouncement 06.02.2024 ORDER PER G.S. PANNU, VP The appeal by the assessee is directed against the order of the Dy. Commissioner/ACIT(T…

Bsc C&C Joint Venture, New Delhi vs. DCIT Circle-61(1), New Delhi

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

ITA 2283/DEL/2022[2017-18]Status: DisposedITAT Delhi03 Nov 2023AY 2017-18

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(1)Section 143(3)Section 40Section 801A(4)(i)Section 80I

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI M BALAGANESH, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year: 2017-18 BSC C&C Joint Venture, Vs. DCIT, 74, Hemkunt Colony, Circle-61(1), New Delhi-110 048 New Delhi. PAN AADFB8115G (Appellant) (Respondent) Assessee by: Shri Tarandeep Singh, CA Shri Sandeep Yadav, Advocate Department by: Shri Rajesh Kumar, CIT(DR) Shri Manu Chaurasia, Sr. DR Date of Hearing: 20.07.2013 20.10.2023 Date of 03.11.2023 pronouncement: O R D E R PER ASTHA CHANDRA, JM The appeal filed by the assessee is directed against the order of the Ld. D…

Bsc C&C Jv, New Delhi vs. Neac, New Delhi

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

ITA 705/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Nov 2022AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.705/Del/2021 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Bsc C&C Jv Assessing Officer, 74, Hemkunt Colony, Vs. National E-Assessment New Delhi. Centre, Delhi. Pan No. Aadfb8115G अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80I

…ted that the literal/strict interpretation of Section 80IA(4)(i)(b) as done by the AO will yield manifestly absured results and this kind of interpretation has not been approved by the High Courts in the following cases: 1. CIT Vs. Ranjit Projects Pvt. Ltd. 408 ITR 274 SLP filed by the Revenue dismissed by the Hon’ble Supreme Court reported in 263 Taxman 363; 2. CIT Vs. Chettinad Lignite Transport Services Pvt. Ltd. 413 ITR 162 and 3. CIT Vs. Chettinad Lignite Transport Services Pvt. Ltd. 415 ITR 107. I.T.A.No.705/Del/2021 12. The Ld. Counsel further placing reliance on the following decisions submits that de…

CIT v. Ranjit Projects Private Limited (408 ITR 274) — Cited in 10 Judgments | BharatTax