CIT v. Rasoi Ltd.

335 ITR 438High Court2011#1012 most cited

What is CIT v. Rasoi Ltd. authority for?

Sales tax subsidies and Industrial Promotion Assistance received under the West Bengal Incentive Scheme are capital receipts and therefore not liable to tax. The ruling clarifies the inapplicability of the Sahney Steel judgment to such subsidies.

107

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2025.

Also referred to as

Rasoi Ltd. · CIT v. Rasoi Ltd. · capital receipt · sales tax subsidy · Industrial Promotion Assistance · West Bengal Incentive Scheme · subsidy taxability · not liable to tax · Sahney Steel judgment · Section 2(24)

Also reported as

46 Taxmann.com 214

Sections most often in play

Section 115JBSection 143(2)Section 143(3)Section 14ASection 2(24)Section 250

Issues it is cited on

section 62section 80ia(8)section 43abook profitsspecified domestic transactionsection 139(5)transfer of capital assetsection 21section 115jdeduction u/s 80iaintangible assetssection 40a(2)

Judgments citing CIT v. Rasoi Ltd.

M/S Pepsico India Holdings Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4516/DEL/2016[2010-11]Status: DisposedITAT Delhi03 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…ceived from the Government of West Bengal was given as assistance to the assessee for business promotion and was not specifically related to any capital expenditure. He held that the reliance placed by the assessee on the decision of CIT vs. Rasoi Ltd: [2011] 335 ITR 438 (Calcutta), was misplaced Rasoi Ltd. (supra) pertained to the West Bengal Incentive Scheme of 2000 whereas in the instant case, the scheme of 2004 was involved. The AO held that both the schemes had different objectives and therefore, the decision in the case of Rasoi Ltd. (supra) did not, in any which way, support the case of the assessee. In th…

M/S. Pepsi Foods Limited, Gurgaon vs. ACIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 1044/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Dec 2018AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…ceived from the Government of West Bengal was given as assistance to the assessee for business promotion and was not specifically related to any capital expenditure. He held that the reliance placed by the assessee on the decision of CIT vs. Rasoi Ltd: [2011] 335 ITR 438 (Calcutta), was misplaced Rasoi Ltd. (supra) pertained to the West Bengal Incentive Scheme of 2000 whereas in the instant case, the scheme of 2004 was involved. The AO held that both the schemes had different objectives and therefore, the decision in the case of Rasoi Ltd. (supra) did not, in any which way, support the case of the assessee. In th…

Pepsi Foods Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result, all the appeals of the assessee are treated as partly allowed

ITA 2511/DEL/2013[2008-09]Status: DisposedITAT Delhi03 Dec 2018AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

…ceived from the Government of West Bengal was given as assistance to the assessee for business promotion and was not specifically related to any capital expenditure. He held that the reliance placed by the assessee on the decision of CIT vs. Rasoi Ltd: [2011] 335 ITR 438 (Calcutta), was misplaced Rasoi Ltd. (supra) pertained to the West Bengal Incentive Scheme of 2000 whereas in the instant case, the scheme of 2004 was involved. The AO held that both the schemes had different objectives and therefore, the decision in the case of Rasoi Ltd. (supra) did not, in any which way, support the case of the assessee. In th…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 467/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Oct 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…79 (SC) • Sunbeam Auto Pvt. Ltd. v. PCIT : 402 ITR 309 (Del.) • Bougainvillea Multiplex Entertainment Centre (P.) Ltd.: 373 ITR 14 (Del) • CIT vs. Siya Ram Garg (HUF): 237 CTR 21 (P&H) • CIT vs. Talbros Engineering Ltd.: 386 ITR 154 (P&H) • CIT vs Rasoi Ltd.: 335 ITR 438 (Cal.) • DCIT vs. Inox Leisure Ltd.: 351 ITR 314 (Guj) • Garden Silk Mills Ltd. v. CIT and Anr. : 394 ITR 192 (Guj.) • CIT vs. Birla VXL Ltd.: 215 Taxman 117 (Guj.) • DCIT vs. Munjal Auto Industries Ltd.: 218 Taxman 135 (Guj.) • CIT vs. Samta Chavigarh: ITA No. 144 of 2007 (Raj)/ 222 Taxman 205 (Mag.) • Shiv Shakti Flour Mills (P) Ltd. v. CIT: IT…

Asst CIT (Ltu) 2, Mumbai vs. Reliance Industries Ltd, Mumbai

ITA 1547/MUM/2016[2010-11]Status: DisposedITAT Mumbai28 Sept 2018AY 2010-11

Bench: S/Shri B.R.Baskaran (Am) & Amarjit Singh (Jm)

Section 43B

…ital in nature. Before us, the assessee placed reliance on the following case laws also to support the decision rendered by the co-ordinate bench in the earlier years on this issue:- (a) Shree Balaji Alloys Ltd vs. CIT (138 DTR 36)(SC) (b) CIT Vs. Rasoi Ltd (335 ITR 438)(Cal) (c) CIT vs. Bougainvillea Multipled Entertainment Centre P Ltd (373 ITR 014)(Delhi) (d) CIT vs. Kirloskar Oil Engines Ltd (364 ITR 88)(Mum) (e) Associated Cement Cos. Ltd vs. CIT (ITA No.7594 & 7644/M/04) 4 M/s. Reliance Industries limited 8. We notice that the Ld CIT(A) has followed by the decision rendered by Special Bench in holding…

Assistant Commissioner of Income-Tax vs. M/S. Abhay Cotex Pvt. Ltd., Jalna

In the result, the appeal of the Revenue is dismissed

ITA 1423/PUN/2016[2011-12]Status: DisposedITAT Pune18 Jul 2018AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita No. 1423/Pun/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12 िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Rahul Kaul & Shri Anand PartaniFor Respondent: Shri Mukesh Jha
Section 115JSection 32

…आयकर अपीलीय अिधकरण “बी बी” "यायपीठ पुणे म" । आयकर अपीलीय अिधकरण बी बी आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण "यायपीठ पुणे म" । "यायपीठ पुणे म" । "यायपीठ पुणे म" । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, PUNE "ी डी डी डी. क"णाकरा राव डी लेखा सद"य, एवं "ी िवकास अव"थी एवं "ी िवकास अव"थी, "याियक सद"य के सम" "ी क"णाकरा राव,लेखा सद"य "याियक सद"य के सम" "ी "ी क"णाकरा राव क"णाकरा राव लेखा सद"य लेखा सद"य एवं "ी िवकास अव"थी एवं "ी िवकास अव"थी "याियक सद"य के सम" "याियक सद"य के सम" BEFORE SHRI D. KARUNAKARA RAO, AM AND SHRI VIKAS AWASTHY, JM आयकर अपील सं आयकर अपील सं. / ITA No. 1423/PUN/2016 आयकर अपील सं आयकर अपील सं…

DCIT, Cir-11(1), Kolkata vs. M/S Haldia Petrochemicals Ltd., Kolkata

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

ITA 168/KOL/2016[2004-05]Status: DisposedITAT Kolkata06 Jul 2018AY 2004-05

Bench: Hon’Ble Shri P.M.Jagtap, Am & Shri S.S.Viswanethra Ravi, Jm ] Assessment Year : 2004-05

For Appellant: Shri Harakamal Chakravorty, ARFor Respondent: Shr P.K.Srihari, CIT
Section 115J

…he manufacture of "Bottle Grade Polyester Chips with a capacity of 140000 tonnes". Therefore the subsidy was given to assessee for the establishment of new industrial unit. The Hon'ble jurisdictional High Court in the case of CIT Vs. Rasoi Limited reported in 335 ITR 438 (Cal) has held that the Sales Tax Incentive granted by the West Bengal Government to the assessee with the object to a provide incentive to set up new industrial undertaking or substantial expansion of the existing undertakings was capital receipt and not revenue in nature. The relevant extract of the judgment is extracted below:- "From the obje…

Haldia Petrochemicals Ltd., Kolkata vs. ACIT, Cir-8, Kolkata

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

ITA 1533/KOL/2015[2003-2004]Status: DisposedITAT Kolkata06 Jul 2018AY 2003-2004

Bench: Hon’Ble Shri P.M.Jagtap, Am & Shri S.S.Viswanethra Ravi, Jm ] Assessment Year : 2004-05

For Appellant: Shri Harakamal Chakravorty, ARFor Respondent: Shr P.K.Srihari, CIT
Section 115J

…he manufacture of "Bottle Grade Polyester Chips with a capacity of 140000 tonnes". Therefore the subsidy was given to assessee for the establishment of new industrial unit. The Hon'ble jurisdictional High Court in the case of CIT Vs. Rasoi Limited reported in 335 ITR 438 (Cal) has held that the Sales Tax Incentive granted by the West Bengal Government to the assessee with the object to a provide incentive to set up new industrial undertaking or substantial expansion of the existing undertakings was capital receipt and not revenue in nature. The relevant extract of the judgment is extracted below:- "From the obje…

DCIT Cir 4(3)(2), Mumbai vs. Svg Fashions Ltd, Mumbai

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

ITA 175/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Jun 2018AY 2013-14

Bench: Shri G.S. Pannu & Shri Pawan Singhdcit Circle-4(3)(2) M/S Svg Fashions Ltd. R.No. 649, 6Th Floor, 235, Shree Venkateshwar Bhavan, 3Rd Floor, Kalabadevi Road, Aayakar Bhavan, Vs. Mumbai-400020. Mumbai-400002 Pan: Aaacd1621K Appellant Respondent Appellant By : Ms. Arju Garodia (Dr) Respondent By : Shri Rahul Bagaria (Ar) Date Of Hearing : 20.06.2018 Date Of Pronouncement : 20.06.2018 Order Under Section 254(1)Of Income Tax Act Per Pawan Singh; 1. This Appeal By Revenue Is Directed Against The Order Of Ld. Commissioner

For Appellant: Ms. Arju Garodia (DR)For Respondent: Shri Rahul Bagaria (AR)
Section 143(3)Section 254(1)

…as been held that it is the purpose of the incentive which decides its nature and not the modality or the source thereof. That thisissue is also favourably covered by the decision of Hon‟ble jurisdictional High Court in the case of CIT –vs.- Rasoi Ltd. (2011) 335 ITR 438 (Cal.), wherein it has held that subsidy received for expansion of capacities, modernization and improving the marketing capabilities to tide over the crises for promotion of industry in the state is to be treated as capital in nature. That similarly, the issue is covered in the case of Shree Balaji Alloys & 6 ITA No. 175 Mum 17 - Ms SVG Fashio…

DCIT, Circle-10(1), Kolkata vs. M/S Indian Oil Petronas Pvt. Ltd., Kolkata

In the result the appeal of the revenue is dismissed

ITA 157/KOL/2017[2008-09]Status: DisposedITAT Kolkata31 May 2018AY 2008-09

Bench: Hon’Ble Shri P.M.Jagtap, Am & Smt. Madhumita Roy, Jm ]

For Appellant: Shri P.K.Srihari, CITFor Respondent: Shri D.S.Damle, FCA
Section 115JSection 143(3)

…of the Act under the West Bengal Incentive Scheme 1999 is in the nature of capital receipt and the same is not chargeable to tax. In support of his arguments he has relied upon the judgement of the Hon’ble Calcutta High Court in the case of CIT vs Rasoi Ltd. (335 ITR 438) wherein the Hon’ble High Court pleased to hold that the sales tax subsidy granted by the West Bengal Government was capital receipt and not revenue. The court in the said judgment observed that the scheme was put to grant the subsidy by way of financial assistance for promotion and expansion of manufacturing units and not taxable under the compu…

Saf Yeast Company P.Ltd, Mumbai vs. Asst CIT Cen Cir 40, Mumbai

In the result the appeal of the assessee for AY 2009-10 is partly allowed

ITA 1875/MUM/2014[2009-10]Status: DisposedITAT Mumbai16 May 2018AY 2009-10

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 80I

…achineries. Accordingly the Ld A.R contended that Explanation 10 to sec.43(1) is not applicable to the instant case. The Ld A.R placed reliance on the following case law in this regard:- (a) CIT Vs. P J Chemicals (210 ITR 830)(SC) (b) CIT Vs. Rasoi Ltd (2011)(335 ITR 438)(Cal) (c) ACIT Vs. Harinagar Sugar Mills Ltd (ITA No.772/Mum/2012) (d) M/s Sasisri Extractions Ltd (122 ITD 428)(Visakha) and other decisions. 36. The Ld D.R submitted that the scheme itself has been framed to provide financial assistance for setting up of projects for recovery of energy from industrial wastes and incentives. Further it is speci…

Sova Ispat Ltd., Kolkata vs. PCIT, -I, Kolkata

In the result, the appeal of the assessee is dismissed with aforesaid observations

ITA 564/KOL/2015[2010-2011]Status: DisposedITAT Kolkata04 May 2018AY 2010-2011

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.564/Kol/2015 ("नधा"रणवष" / Assessment Year: 2010-11) Sova Ispat Ltd. Vs. Principal C.I.T, Kolkata

For Appellant: Shri A. K. Tulsian, FCAFor Respondent: Shri G. Hangshing, CIT(DR)
Section 143(3)Section 263

…the outset itself, the ld. counsel for the assessee drew our attention towards Para No.5 of the order of the ld. Principal CIT u/s 263 of the Act wherein the assessee stated the judgment of Jurisdictional High Court, Calcutta in the case of CIT vs. Rasoi Ltd. 335 ITR 438 (Cal), which should be followed. The judgment of the Jurisdictional High Court, clearly Sova Ispat Ltd. ITA Nos.564/Kol/2015 Assessment Year: 2010-11 spells out that a subsidy received under “Industrial Promotional Assistance” (IPA) is a capital receipt. The ld. counsel for the assessee therefore requested the Bench that the judgment of Jurisdict…

DCIT, Cir-3(1), Kolkata vs. M/S Tata Metaliks Ltd., Kolkata

In the result, Revenue’s appeal is dismissed

ITA 478/KOL/2016[2010-2011]Status: DisposedITAT Kolkata27 Apr 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 115JSection 139(1)Section 143(3)Section 234C

…s under:- “1.0 The findings of the AO and written submissions of the appellant and the documents in records have been carefully considered. The issue is found to be covered by the order of the jurisdictional High Court in the case of CIT vs. Rasoj Ltd. (2011) 335 ITR 438 (Cal), wherein it was held that sales tax incentives received under West Bengal Incentive Scheme for expansion of capacities, modernization and improving the marketing capabilities to tide over the crises for promotion of industry in the state was capital in nature. Moreover, it is found that identical issue was decided favourably by the CIT(Appe…

Tata Metaliks Ltd., Kolkata vs. ITO, WD-3(2), Kolkata

In the result, Revenue’s appeal is dismissed

ITA 439/KOL/2016[2010-11]Status: DisposedITAT Kolkata27 Apr 2018AY 2010-11

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 115JSection 139(1)Section 143(3)Section 234C

…s under:- “1.0 The findings of the AO and written submissions of the appellant and the documents in records have been carefully considered. The issue is found to be covered by the order of the jurisdictional High Court in the case of CIT vs. Rasoj Ltd. (2011) 335 ITR 438 (Cal), wherein it was held that sales tax incentives received under West Bengal Incentive Scheme for expansion of capacities, modernization and improving the marketing capabilities to tide over the crises for promotion of industry in the state was capital in nature. Moreover, it is found that identical issue was decided favourably by the CIT(Appe…

M/S. Delhi International Airport Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, appealsof the assessee are partly allowed

ITA 636/BANG/2017[2011-12]Status: DisposedITAT Bangalore19 Apr 2018AY 2011-12

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

For Appellant: Shri. Sunil Jain, CAFor Respondent: Smt. Vandana Sagar
Section 143(3)Section 14ASection 153ASection 194HSection 32Section 40

…ive subsidy. The form of the mechanism through which the subsidy is given is irrelevant. 14. It would also be of immense merit to refer to another judgement of the Hon'ble Calcutta High Court in the case of Commissioner of Income Tax vs. Rasoi Limited [2011] 335 ITR 438, wherein it has been settled by the Hon'ble Court by making a due reference to the judgement of the Hon'ble Apex Court in the case titled Commissioner of Income Tax vs. Ponni Sugars & Chemicals Ltd [2008] 174 Taxman 87 (SC) that one time subsidy received as a percentage of sales tax paid for modernization and expansion purposes would constitute a…

M/S. Delhi International Airport Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, appealsof the assessee are partly allowed

ITA 622/BANG/2017[2012-13]Status: DisposedITAT Bangalore19 Apr 2018AY 2012-13

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

For Appellant: Shri. Sunil Jain, CAFor Respondent: Smt. Vandana Sagar
Section 143(3)Section 14ASection 153ASection 194HSection 32Section 40

…ive subsidy. The form of the mechanism through which the subsidy is given is irrelevant. 14. It would also be of immense merit to refer to another judgement of the Hon'ble Calcutta High Court in the case of Commissioner of Income Tax vs. Rasoi Limited [2011] 335 ITR 438, wherein it has been settled by the Hon'ble Court by making a due reference to the judgement of the Hon'ble Apex Court in the case titled Commissioner of Income Tax vs. Ponni Sugars & Chemicals Ltd [2008] 174 Taxman 87 (SC) that one time subsidy received as a percentage of sales tax paid for modernization and expansion purposes would constitute a…

M/S. Delhi International Airport Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, appealsof the assessee are partly allowed

ITA 596/BANG/2017[2013-14]Status: DisposedITAT Bangalore19 Apr 2018AY 2013-14

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

For Appellant: Shri. Sunil Jain, CAFor Respondent: Smt. Vandana Sagar
Section 143(3)Section 14ASection 153ASection 194HSection 32Section 40

…ive subsidy. The form of the mechanism through which the subsidy is given is irrelevant. 14. It would also be of immense merit to refer to another judgement of the Hon'ble Calcutta High Court in the case of Commissioner of Income Tax vs. Rasoi Limited [2011] 335 ITR 438, wherein it has been settled by the Hon'ble Court by making a due reference to the judgement of the Hon'ble Apex Court in the case titled Commissioner of Income Tax vs. Ponni Sugars & Chemicals Ltd [2008] 174 Taxman 87 (SC) that one time subsidy received as a percentage of sales tax paid for modernization and expansion purposes would constitute a…

M/S Delhi International Airport Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, appealsof the assessee are partly allowed

ITA 581/BANG/2017[2007-08]Status: DisposedITAT Bangalore19 Apr 2018AY 2007-08

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

For Appellant: Shri. Sunil Jain, CAFor Respondent: Smt. Vandana Sagar
Section 143(3)Section 14ASection 153ASection 194HSection 32Section 40

…ive subsidy. The form of the mechanism through which the subsidy is given is irrelevant. 14. It would also be of immense merit to refer to another judgement of the Hon'ble Calcutta High Court in the case of Commissioner of Income Tax vs. Rasoi Limited [2011] 335 ITR 438, wherein it has been settled by the Hon'ble Court by making a due reference to the judgement of the Hon'ble Apex Court in the case titled Commissioner of Income Tax vs. Ponni Sugars & Chemicals Ltd [2008] 174 Taxman 87 (SC) that one time subsidy received as a percentage of sales tax paid for modernization and expansion purposes would constitute a…

DCIT, CC-4(2), Kolkata vs. M/S Lux Industries Ltd., Kolkata

In the result, appeal of revenue is allowed for statistical purposes

ITA 1016/KOL/2016[2010-2011]Status: DisposedITAT Kolkata04 Apr 2018AY 2010-2011

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M.Balaganesh, Am]

Section 139(5)

…ed by the assessee from Govt. of West Bengal. 3. Briefly stated facts are that the assessee company being a beneficiary of the incentive scheme of the Govt. of West Bengal, taking note of the Hon’ble Calcutta High Court’s decision in CIT Vs. Rasoi Ltd. (2011) 335 ITR 438 (Cal) revised its return in time and claimed the incentive as capital, which was not acceptable to AO, who relied on the order of Hon’ble Supreme Court in Sahney Steel & Press Works Ltd. Vs. CIT -1997-TMI- 5620 (SC) and CIT Vs. Abhishek Industries Ltd. – 2006 – TMI – 9839 (P&H) to disallow the claim. The AO also noted that since the assessee in t…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

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

ITA 6021/DEL/2012[2008-09]Status: DisposedITAT Delhi09 Nov 2017AY 2008-09

Bench: Shri N.K. Saini & Shri K.N. Charry

Section 143(3)Section 144CSection 144C(5)Section 14ASection 35DSection 43BSection 92C

…al in ITA: 472 of 2010 (P&H), CIT vs. Siya Ram Garg ITA No.-6021/Del/2012 (HUF): 237 CTR 21 (P&H), CIT vs. Talbros Engineering Ltd. : 386 ITR 154 (P&H), Chaphalkar Brothers: 351 ITR 309 (Bom.), Sadichha Chitra vs. CIT: 189 ITR 774 (Bom.), CIT vs Rasoi Ltd.: 335 ITR 438 (Cal.), CIT vs. Balarampur Chini Mills Ltd.: 238 ITR 445 (Cal.), CIT vs. Madurantakam Co-operative Sugar Mills Ltd.: 263 ITR 388 (Mad), Garden Silk Mills Ltd. v. CIT and Anr. : 394 ITR 192 (Guj.), DCIT vs. Inox Leisure Ltd.: 351 ITR 314 (Guj), CIT vs. Birla VXL Ltd.: 215 Taxman 117 (Guj.), DCIT vs. Munjal Auto Industries Ltd.: 218 Taxman 135 (Guj…