CIT v. Reliance Industries Ltd.

339 ITR 632High Court2011#411 most cited

What is CIT v. Reliance Industries Ltd. authority for?

No substantial question of law arises regarding a subsidy granted for setting up a new industrial unit in a backward area for employment generation, as held by the Bombay High Court. This decision was subsequently set aside by the Supreme Court.

218

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2014 to 2026.

Also referred to as

CIT v. Reliance Industries Ltd. · 339 ITR 632 · Bombay High Court · subsidy for new industrial unit · backward area development · employment generation · section 80IA · tax treatment of subsidy · no substantial question of law · Supreme Court remand

Also reported as

102 Taxmann.com 372228 Taxmann 184

Sections most often in play

Section 115JBSection 80IASection 14ASection 143(3)Section 80IA(8)Section 80IBSection 92CA(3)Section 234D

Issues it is cited on

section 80hhc(3)section 92f(ii)section 80ia(8)section 28(iv)section 92fcorporate guaranteesection 80hhcdeduction under section 80iasection 80hhsection 115jb(2)deduction u/s 80iasection 10(34)

Judgments citing CIT v. Reliance Industries Ltd.

M/S. Laxmi Organic Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

ITA 4782/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Percy Pardiwala, Sr. Advocate andFor Respondent: Ms. Neena Jeph, CIT DR
Section 144C(5)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 4782/MUM/2024 Assessment Year: 2020-21 Laxmi Organic Industries Limited Basement, Chandramukhi, Ramnath Goenka Marg, Nariman Point, Mumbai, Maharashtra, 400021 (PAN: AAACL2435R) (Appellant) Deputy Commissioner of Income Tax, Circle 3(2)(1), Mumbai Vs. (Respondent) Present for: Assessee : Shri Percy Pardiwala, Sr. Advocate and Shri Anil Lohia, Shri Sanjeev Gupta and Shri S. S Tomar Revenue : Ms. Neena Jeph, CIT DR Date of Hearing : 28.04.2025 Date of Pronouncement…

Principal Commissioner of Income Tax Central 1 Kolkata vs. Rungta Mines Ltd

In the result, these appeals are dismissed and the substantial

ITAT/216/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

…is, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1 (223 Taxman 234) (Chattisgarh HC) 2 (421 ITR 686 ) (Bom HC) ITAT NOS. 215, 216 AND 217 OF 2024 REPORTABLE Page 8 of 22 manufacturing units besides obtaining power from CPPs also bought power from the State Electricity Boards (SEB) at tariff at which such power was available to industry in their states. The CIT(A) took note of the assertion of the assessee that the CPP…

Principal Commissioner of Income Tax Central 1 Kolkata vs. Rungta Mines Ltd

In the result, these appeals are dismissed and the substantial

ITAT/215/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

…is, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1 (223 Taxman 234) (Chattisgarh HC) 2 (421 ITR 686 ) (Bom HC) ITAT NOS. 215, 216 AND 217 OF 2024 REPORTABLE Page 8 of 22 manufacturing units besides obtaining power from CPPs also bought power from the State Electricity Boards (SEB) at tariff at which such power was available to industry in their states. The CIT(A) took note of the assertion of the assessee that the CPP…

Principal Commissioner of Income Tax Central 1 Kolkata vs. Rungta Mines Ltd

In the result, these appeals are dismissed and the substantial

ITAT/217/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

…is, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1 (223 Taxman 234) (Chattisgarh HC) 2 (421 ITR 686 ) (Bom HC) ITAT NOS. 215, 216 AND 217 OF 2024 REPORTABLE Page 8 of 22 manufacturing units besides obtaining power from CPPs also bought power from the State Electricity Boards (SEB) at tariff at which such power was available to industry in their states. The CIT(A) took note of the assertion of the assessee that the CPP…

United Phosphorus Ltd, Mumbai vs. DCIT Cen Cir 38, Mumbai

ITA 6950/MUM/2013[2004-05]Status: DisposedITAT Mumbai27 Jun 2025AY 2004-05

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, Advocate and Ms. Saisudha Multani, CAFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 | Deputy Commissioner of Income-tax, Central Circle – 38, Mumbai. | (Appellant) Vs. | UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos House, C.D. Marg, 11th Road, Madhu Park, Khar(West), Mumbai – 400052 (PAN : AABCS1698G) | (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 | UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos Hous…

United Phosphorus Ltd ( Formelry Known As Search Chem Industries Ltd), Mumbai vs. DCIT Cen Cir 38, Mumbai

ITA 5344/MUM/2013[2007-08]Status: DisposedITAT Mumbai27 Jun 2025AY 2007-08

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, AdvocateFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 | Deputy Commissioner of Income-tax, Central Circle – 38, Mumbai. (Appellant) UPL Limited (Formerly known as United Phosphorus Ltd.) Vs. Uniphos House, C.D. Marg, 11th Road, Madhu Park, Khar(West), Mumbai – 400052 (PAN : AABCS1698G) (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos House, C.D.…

United Phosphorus Ltd ( Formerly Known As Search Chem Industries Ltd), Mumbai vs. DCIT Cen Cir 38, Mumbai

ITA 7028/MUM/2010[2005-06]Status: DisposedITAT Mumbai27 Jun 2025AY 2005-06

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, AdvocateFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 | Deputy Commissioner of | Income-tax, | Central Circle – 38, Mumbai. | (Appellant) | Vs. | UPL Limited | (Formerly known as United | Phosphorus Ltd.) | Uniphos House, C.D. Marg, 11th | Road, Madhu Park, Khar(West), | Mumbai – 400052 | (PAN : AABCS1698G) | (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 | UPL Limited | (Formerly known as United | Phosphor…

United Phosphorus Ltd ( Formerly Known As Search Chem Industries Ltd), Mumbai vs. DCIT Cen Cir 38, Mumbai

ITA 7027/MUM/2010[2004-05]Status: DisposedITAT Mumbai27 Jun 2025AY 2004-05

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, AdvocateFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 Deputy Commissioner of Income-tax, Central Circle – 38, Mumbai. (Appellant) UPL Limited (Formerly known as United Phosphorus Ltd.) Vs. Uniphos House, C.D. Marg, 11th Road, Madhu Park, Khar(West), Mumbai – 400052 (PAN : AABCS1698G) (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos House, C.D. Mar…

DCIT CC-38, Mumbai vs. United Phophourus Ltd ( Formerly Knwon As Search Chem Indl. Ltd), Mumbai

ITA 6807/MUM/2010[2004-05]Status: DisposedITAT Mumbai27 Jun 2025AY 2004-05

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, AdvocateFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 | Deputy Commissioner of Income-tax, Central Circle – 38, Mumbai. (Appellant) | UPL Limited (Formerly known as United Phosphorus Ltd.) Vs. Uniphos House, C.D. Marg, 11th Road, Madhu Park, Khar(West), Mumbai – 400052 (PAN : AABCS1698G) (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 | UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos House, C.…

DCIT CC-38, Mumbai vs. United Phosphorus Ltd ( Formerly Known As Search Chem Indl.L Td), Mumbai

ITA 6709/MUM/2010[2005-06]Status: DisposedITAT Mumbai27 Jun 2025AY 2005-06

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, AdvocateFor Respondent: Shri Abhishek Tharwal, Sr. DR
Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.6807 and 6709/MUM/2010 Assessment Years: 2004-05 and 2005-06 | Deputy Commissioner of Income-tax, Central Circle – 38, Mumbai. (Appellant) | UPL Limited (Formerly known as United Phosphorus Ltd.) Vs. Uniphos House, C.D. Marg, 11th Road, Madhu Park, Khar(West), Mumbai – 400052 (PAN : AABCS1698G) (Respondent) C.O. No. 188/MUM/2011 (Arising out of ITA No.6709/MUM/2010) Assessment Year – 2005-06 | UPL Limited (Formerly known as United Phosphorus Ltd.) Uniphos House,…

Uniphos Enterprises Ltd, Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 3878/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04
For Appellant: "I. TAXABILITY OF ADVANCE LICENCE BENEFIT RECEIVABLE: Rs.9,79
Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, 'K' BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. Vs. ACIT, CC-38, Room no. Uniphos House, Madhu Park, 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4000…

Asst CIT CC 38, Mumbai vs. Uniphos Enterprises Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 3534/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. ACIT, CC-38, Room no. Uniphos House, Madhu Park, Vs. 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4…

Addl CIT Cen RG IX, Mumbai vs. Uniphos Enterprises Ltd ( Formlery Known As United Phosphorus Ltd), Mumbai

In the result, the appeal of assessee is allowed

ITA 6236/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. ACIT, CC-38, Room no. Uniphos House, Madhu Park, Vs. 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4…

Uniphos Enterprises Ltd ( Formerly Known As United Phosphorus Ltd), Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 6224/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. ACIT, CC-38, Room no. Uniphos House, Madhu Park, Vs. 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4…

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. ACIT, CC-38, Room no. Uniphos House, Madhu Park, Vs. 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4…

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1787/Mum/2006 (AY: 2002-03)(Appeal in quantum assessment) CO No. 257/MUM/2006(AY: 2002-03) (Arising out of ITA NO 1822/MUM/2006) ITA No. 6224/Mum/2010 (AY: 2003-04) (Appeal in quantum assessment) ITA No. 3878/Mum/14 (AY: 2003-04) (Appeal in penalty levied u/s 271(1)(c)) (Physical hearing) M/s. United Phosphorous Ltd. ACIT, CC-38, Room no. Uniphos House, Madhu Park, Vs. 32(1), Ayakar Bhavan, 11th Road, Khar (W), Mumbai. Maharishi Karve Road, PAN: AAACU 3440 P Mumbai-4…

Deputy Commissioner of Income Tax, Circle-5(1), Kolkata vs. Dhunseri Ventures Limited, Kolkata

In the result, the appeal filed by the revenue is dismissed

ITA 968/KOL/2024[2016-17]Status: DisposedITAT Kolkata15 May 2025AY 2016-17

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 80ISection 92C

…आयकर अपील"य अ"धकरण, कोलकाता पीठ “सी’’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH: KOLKATA "ी "द"प कुमार चौबे, "या"यक सद"य एवं "ी संजय अव"थी, लेखा सट"य के सम" [Before Shri Pradip Kumar Choubey, Judicial Member &Shri Sanjay Awasthi,Accountant Member] I.T.A. No. 968/Kol/2024 Assessment Year: 2016-17 DCIT,Circle-5(1), Kolkata Vs. Dhunseri Ventures Ltd. (PAN: AABCD 1597 K) ( अपीलाथ" ) Respondent / ""यथ" Appellant / Date of Hearing / सुनवाई 30.04.2025 क" "त"थ Date of Pronouncement/ 15.05.2025 आदेश उ"घोषणा क" "त"थ For the assessee / Shri Akkal Dudhwewala, A.R "नधा"रती क" ओर से For the revenue / राज"व Shr…

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 267/CHNY/2025[2016]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…Ispat Ltd. [2014] 42 taxmann.com 551] and PCIT v. Gujarat Alkalies & Chemicals Limited [2017] 88 taxmann.com 722] respectively. Further, he also referred to the decision of the Hon’ble High Court of Bombay in the case of CIT v. Reliance Industries Ltd. [2020] 421 ITR 686 and held that the rate at which the state electricity board or power generation and distribution companies sell power to industrial and consumers should be adopted as open market value so as to determine the market value of electricity transferred. The ld. AR placed on record the recent decision of the Hon’ble Supreme Court in the case of CIT v.…

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 266/CHNY/2025[2015]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…Ispat Ltd. [2014] 42 taxmann.com 551] and PCIT v. Gujarat Alkalies & Chemicals Limited [2017] 88 taxmann.com 722] respectively. Further, he also referred to the decision of the Hon’ble High Court of Bombay in the case of CIT v. Reliance Industries Ltd. [2020] 421 ITR 686 and held that the rate at which the state electricity board or power generation and distribution companies sell power to industrial and consumers should be adopted as open market value so as to determine the market value of electricity transferred. The ld. AR placed on record the recent decision of the Hon’ble Supreme Court in the case of CIT v.…

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 265/CHNY/2025[2014]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…Ispat Ltd. [2014] 42 taxmann.com 551] and PCIT v. Gujarat Alkalies & Chemicals Limited [2017] 88 taxmann.com 722] respectively. Further, he also referred to the decision of the Hon’ble High Court of Bombay in the case of CIT v. Reliance Industries Ltd. [2020] 421 ITR 686 and held that the rate at which the state electricity board or power generation and distribution companies sell power to industrial and consumers should be adopted as open market value so as to determine the market value of electricity transferred. The ld. AR placed on record the recent decision of the Hon’ble Supreme Court in the case of CIT v.…