CIT v. Sahara India Savings and Investment Corporation Ltd.

321 ITR 371Reported decision2010#6982 most cited

What is CIT v. Sahara India Savings and Investment Corporation Ltd. authority for?

When a definition section states that a word 'means' something, it provides an exclusive definition. If additional categories are included, only those explicitly added are considered part of the definition.

16

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2011 to 2024.

Also referred to as

CIT v. Sahara India Savings and Investment Corporation Ltd. · section 2(7) · definition of interest · exclusive definition · inclusive definition · interpretation of statutes

Issues it is cited on

section 2(7)section 36(1)(viii)section 18tax benefitsection 36(1)(vii)section 80p(4)section 22amalgamationsection 80p(2)(a)section 80p(2)(a)(i)section 32section 80p(2)

Judgments citing CIT v. Sahara India Savings and Investment Corporation Ltd.

Vidharbha Konkan Gramin Bank, Nagpur vs. Income Tax Officer Ward 1(5), Nagpur

In the result, appeal filed by the assessee for A

ITA 8/NAG/2019[2015-2016]Status: DisposedITAT Nagpur28 Nov 2024AY 2015-2016

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation Ltd. reported in [2010] 321 ITR 371 an exclusive definition vide P. Kasilingam v. P.S. G. College of Technology (1995/supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. v. Presiding Officer, Labour Court/1990] 77 FJR 17: 11990) 3 SCC 682. However, when…

Vidharbha Konkan Gramin Bank, Nagpur vs. Income Tax Officer Ward 1(5), Nagpur

In the result, appeal filed by the assessee for A

ITA 7/NAG/2019[2014-15]Status: DisposedITAT Nagpur28 Nov 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation Ltd. reported in [2010] 321 ITR 371 an exclusive definition vide P. Kasilingam v. P.S. G. College of Technology (1995/supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. v. Presiding Officer, Labour Court/1990] 77 FJR 17: 11990) 3 SCC 682. However, when…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U.P. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 56/VNS/2023[2019-2020]Status: DisposedITAT Varanasi26 Sept 2023AY 2019-2020

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U.P. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 55/VNS/2023[2018-2019]Status: DisposedITAT Varanasi26 Sept 2023AY 2018-2019

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U. P.. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 54/VNS/2023[2017-2018]Status: DisposedITAT Varanasi26 Sept 2023AY 2017-2018

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U.P. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 53/VNS/2023[2011-2012]Status: DisposedITAT Varanasi26 Sept 2023AY 2011-2012

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U.P. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 52/VNS/2023[2010-2011]Status: DisposedITAT Varanasi26 Sept 2023AY 2010-2011

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Dy. C. I. T., Circle - 1, Gorakhpur vs. Baroda Uttar Pradesh Gramin Bank Now Amalgamated With Baroda U.P. Bank, Gorakhpur

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessee are allowed

ITA 51/VNS/2023[2009-2010]Status: DisposedITAT Varanasi26 Sept 2023AY 2009-2010

Bench: Shri. B. R. Baskaran & Shri Amit Shukla

For Appellant: Shri S. K. Garg, AdvocateFor Respondent: Shri Robin Chaudhary, CIT
Section 143(3)Section 2(19)Section 22Section 254Section 271Section 3Section 80PSection 80P(2)(a)

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of Section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT Vs. Sahara India Savings and Investment Corporation Ltd reported in (2010) 321 ITR 371 an exclusive definition vide P. :-16-: Kasilingam V. P.S. G. College of Technology (1995/ supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. V Presiding Officer, Labour Court /1990] 77 FJR 17; \1990) 3 SCC 682. Howe…

Deputy Commissioner of Income Tax, Circle-1(1), Hubballi vs. M/S. Karnataka Vikas Grameen Bank Limited, Dharwad

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

ITA 720/BANG/2020[2016-17]Status: DisposedITAT Bangalore05 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.AFor Respondent: Ms. Susan D George, CIT (DR)
Section 143Section 234BSection 250Section 36

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation Ltd. reported in [2010] 321 ITR 371 an exclusive definition vide P. Kasilingam v. P.S. G. College of Technology (1995/supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. v. Presiding Officer, Labour Court/1990] 77 FJR 17; |1990) 3 SCC 682. However, when…

M/S Karnataka Vikas Grameena Bank, Dharwad vs. Assistant Commissioner of Income Tax, Circle-2(1), Hubballi

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

ITA 611/BANG/2020[2016-17]Status: DisposedITAT Bangalore02 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.A, S.V Ravishankar, AdvocateFor Respondent: Ms. Susan D George, CIT (DR)
Section 143Section 234BSection 250Section 36

…lso included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation Ltd. reported in [2010] 321 ITR 371 an exclusive definition vide P. Kasilingam v. P.S. G. College of Technology (1995/supp 2 SCC 348. When we say that a word has a certain meaning then by implication we mean that it has no other meaning vde a Punjab Land Development and Reclamation Corporation Ltd. v. Presiding Officer, Labour Court/1990] 77 FJR 17; |1990) 3 SCC 682. However, when…

National Cooperative Development Corporation vs. Assistant Commissioner of Income Tax

In the result, question No

ITA/227/2012HC Delhi10 Apr 2012

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

Section 260ASection 3Section 36Section 36(1)(viii)

…nger footing and such shareholders can never be held to be a creditor of the company. 9. The issue had also arisen under the Interest Tax Act, 19 7 4 before the Supreme Court in CIT, [(anpur vs Sahara India Savings and Investment Corporatian Ltd. (2010) 321 ITR 371. The question before ITA Nos.512/2011, 513/2011, 810/2011, 811/2011, 1139/2011, 1140/2011 & 1141/2011 Page 8 of 17 the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word "interest". in sec.2(7) of the said Act. Under this definition, intere…

National Cooperative Development Corporation vs. Assistant Commissioner of Income Tax

In the result, question No

ITA - 228 / 2012HC Delhi10 Apr 2012
Section 260ASection 3Section 36Section 36(1)(viii)

…nger footing and such shareholders can never be held to be a creditor of the company. 9. The issue had also arisen under the Interest Tax Act, 19 7 4 before the Supreme Court in CIT, [(anpur vs Sahara India Savings and Investment Corporatian Ltd. (2010) 321 ITR 371. The question before ITA Nos.512/2011, 513/2011, 810/2011, 811/2011, 1139/2011, 1140/2011 & 1141/2011 Page 8 of 17 2012:DHC:9825-DB the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word "interest". in sec.2(7) of the said Act. Under this de…

National Cooperative Development Corporation vs. Assistant Commissioner of Income Tax

In the result, question No

ITA - 227 / 2012HC Delhi10 Apr 2012
Section 260ASection 3Section 36Section 36(1)(viii)

…nger footing and such shareholders can never be held to be a creditor of the company. 9. The issue had also arisen under the Interest Tax Act, 19 7 4 before the Supreme Court in CIT, [(anpur vs Sahara India Savings and Investment Corporatian Ltd. (2010) 321 ITR 371. The question before ITA Nos.512/2011, 513/2011, 810/2011, 811/2011, 1139/2011, 1140/2011 & 1141/2011 Page 8 of 17 2012:DHC:9825-DB the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word "interest". in sec.2(7) of the said Act. Under this de…

National Cooperative Development Corporation vs. Assistant Commissioner of Income Tax

In the result, question No

ITA/811/2011HC Delhi28 Nov 2011

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

Section 260ASection 36(1)(viii)

…tronger r). footing and assuch shareholders can never be held to be a creditor of the company g. The issue had also arisen under the Interest Tax Act, 1974 before the Supreme Court in CIT, Kanpur vs Sahara India Savings and Investment Corporatiott Ltd. (2010) 321 ITR 371- The question before ITANos.512l20Il, s1i/201 1, ll39l20rl, 5t3120r1, 810/2011, tl40l20l1 & rl4rl201r Paee B of 17 the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word "interest" in sec.2(7) of the said Act. Under this definition, interest means i…

National Cooperative Development Corp

In the result, question No

ITA - 512 / 2011HC Delhi28 Nov 2011
Section 148Section 260ASection 36(1)(viii)

…ronger footing and such shareholders can never be held to be a creditor of the company. 9. The issue had also arisen under the Interest Tax Act, 1974 before the Supreme Court in CIT, Kanpur vs Sahara India Savings and Investment Corporation Ltd. (2010) 321 ITR 371. The question before 2011:DHC:6034-DB ITA Nos.512/2011, 513/2011, 810/2011, 811/2011, 1139/2011, 1140/2011 & 1141/2011 Page 9 of 17 the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word “interest” in sec.2(7) of the said Act. Un…

Corporation

In the result, question No

ITA/512/2011HC Delhi28 Nov 2011
Section 148Section 260ASection 36(1)(viii)

…ronger footing and such shareholders can never be held to be a creditor of the company. 9. The issue had also arisen under the Interest Tax Act, 1974 before the Supreme Court in CIT, Kanpur vs Sahara India Savings and Investment Corporation Ltd. (2010) 321 ITR 371. The question before 2011:DHC:6034-DB ITA Nos.512/2011, 513/2011, 810/2011, 811/2011, 1139/2011, 1140/2011 & 1141/2011 Page 9 of 17 the court was whether interest earned on bonds and debentures was chargeable to tax under the aforesaid Act having regard to the definition of the word “interest” in sec.2(7) of the said Act. Un…

CIT v. Sahara India Savings and Investment Corporation Ltd. (321 ITR 371) — Cited in 16 Judgments | BharatTax