What is CIT v. Shoorji Vallabhdas & Co. authority for?

Income tax is levied only on real income that actually materializes, not on hypothetical or notional income, even if accounting entries suggest otherwise. If no income results, there is no tax liability.

How many judgments cite CIT v. Shoorji Vallabhdas & Co.?

551 judgments on BharatTax cite CIT v. Shoorji Vallabhdas & Co. (46 ITR 144), spanning 2010 to 2026.

Which sections of the Income Tax Act does CIT v. Shoorji Vallabhdas & Co. come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 148, Section 37(1), Section 115JB, Section 153A.

CIT v. Shoorji Vallabhdas & Co. (46 ITR 144)

Indiabullas Housing Finance Limited, Mumbai vs. DCIT, Central Circle-6(4), Mumbai

ITA 821/MUM/2023[2018-2019]Status: DisposedITAT Mumbai18 Dec 2023AY 2018-2019

For Appellant: Shri K. Gopal &For Respondent: Shri Rakesh Garg

Section 143(1)Section 143(3)Section 14ASection 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 822/MUM/2023 (Assessment Year: 2018-19) (Assessment Year: 2019-20) Indiabulls Housing Finance Limited, 5th Floor, Building No. 27, K G Marg, Connaught Place, New Delhi - 110001 [PAN: AABCI3612A] …………… Appellant Deputy Commissioner of Income Tax, Circle 6(4), Mumbai, Vs Room No. 1925, 19th Floor, Air India Building, Nariman Point, Mumbai - 400021 ……………. Respondent & ITA No. 1033/MUM/2023 (Assessment Year: 2018-19) (Assessment Year: 2019-20) Deputy Commissioner of Income Tax…

Ranjan Dagar, New Delhi vs. ACIT, Int. Tax. Circle-1(2)(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 761/DEL/2023[2016-17]Status: DisposedITAT Delhi21 Nov 2023AY 2016-17

Bench: Us:-

Section 147Section 148

…as accrued which can be brought to tax and not any notional income as per following propositions settled by Supreme Court:- (i) Income tax is not payable on any income which could have been earned but has not been earned. Vide—CIT Vs. Shoorji Vallabhdas & Co. 46 ITR 144 (SC) Godhra Electricity Co. Ltd. Vs. CIT 225 ITR 746 (SC) (ii) Income accrues when the assessee acquires a right to receive the income. Vide—E.D. Sassoon & Co. Ltd. Vs. CIT 26 ITR 27 (SC) 4. The on the facts and circumstances of the case and in law the CIT(A) failed to consider the following:- (i) that the interest income of Rs.39,70,120/- from O…

DCIT 2(3), Mumbai vs. Zensar Technologies Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 8389/MUM/2010[2005-06]Status: DisposedITAT Mumbai13 Nov 2023AY 2005-06

Bench: Shri Vikas Awasthy& Shri S. Rifaur Rahmanआअसं.8389/मुं/2010 (िन.व. 2005-06) Dcit-2(3), Room No.555, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ...... अपीलाथ"/Appellant बनाम Vs. M/S. Zensar Technologies Ltd., Magnet House, 2Nd Floor, N.M.Marg, Ballard Estate, Mumbai – 400 001 Pan: Aaacz 0742 K ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Manoj Kumar, Cit - Dr "ितवादी"ारा/Respondent By : Shri Nitesh Joshi, Advocate सुनवाई की ितिथ/ Date Of Hearing : 22/08/2023 घोषणा की ितिथ/ Date Of Pronouncement : 13/11/2023 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Manoj Kumar, CIT - DRFor Respondent: Shri Nitesh Joshi, Advocate

Section 10ASection 244ASection 92C

…03/2007. It is a well settled principle that only the real income of assessee can be taxed. The Department cannot tax the income that has never accrued to or received by the assessee. The Hon'ble Apex Court in the case of CIT vs. Shoorji Vallabhdas & Company, 46 ITR 144 held, “Income-tax is a levy on income. No doubt, the Income-tax Act takes into account two points of time at which liability to tax is attracted, viz. the accrual of its income or its receipt; but the substance of the matter is income, if income does not result, there cannot be a tax, even though in book-keeping an entry is made about a hypothetic…