CIT v. Shri Ram Pistons and Rings Ltd.

220 CTR 404High Court2008#1521 most cited

What is CIT v. Shri Ram Pistons and Rings Ltd. authority for?

When the year of taxability of income is in dispute for a company, the Revenue does not suffer any loss if the corporate tax rate remains the same across the relevant assessment years, as the tax will ultimately be received.

75

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2025.

Also referred to as

CIT v. Shri Ram Pistons and Rings Ltd. · 220 CTR 404 · income taxability year · timing of income recognition · no loss to revenue · same corporate tax rate · inter-year income shifting · assessment procedure · business income · Section 143(3) · Section 142(1)

Also reported as

174 Taxmann 147

Sections most often in play

Section 143(3)Section 142(1)Section 143(2)Section 127Section 132(4)Section 132(4A)Section 133(6)Section 133A

Issues it is cited on

section 36(i)(va)true and full disclosuresection 153(a)retraction of statementsection 145(2)retracted statementproject completion methodcorporate guaranteestatement under section 132(4)written down valuepercentage completion methodput to use

Judgments citing CIT v. Shri Ram Pistons and Rings Ltd.

JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-20, DELHI vs. M B POWER (MADHYA PRADESH) LTD., DELHI

In the result, appeal of the Revenue is dismissed

ITA 267/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

MB POWER (MADHYA PRADESH) LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI

In the result, appeal of the Revenue is dismissed

ITA 211/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. MB POWER (MADHYA PRADESH) LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3923/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. M. B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3874/DEL/2023[2016-17]Status: DisposedITAT Delhi19 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 20, DELHI vs. M.B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3870/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Dec 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

MB POWER (MADHYA PRADESH) LIMITED ,SOUTH EAST DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

DY.COMMISSIONER OF INCOME TAX,CC-2,, KANPUR vs. SHRI.MOHAMMAD ASFAND AKHTAR, KANPUR

In the result, the appeal of Revenue in ITA

ITA 144/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER Assessment Year: 2018-19 DCIT, CC-2 v. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. TAN/PAN: AEMPA0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar v. DCIT, Central Circle-II Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. TAN/PAN: AEMPA0823R (Appel…

MOHD. ASFAND AKHTAR,KANPUR vs. DEPUTI COMMISSIONER OF INCOME TAX CC-2, KANPUR

In the result, the appeal of Revenue in ITA

ITA 139/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER Assessment Year: 2018-19 DCIT, CC-2 v. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. TAN/PAN: AEMPA0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar v. DCIT, Central Circle-II Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. TAN/PAN: AEMPA0823R (Appel…

INVOLUTE ENGINEERING PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 12(2), NEW DELHI

The appeals is allowed

ITA 6884/DEL/2019[2013-14]Status: DisposedITAT Delhi29 May 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2013-14 Involute Engineering Pvt. Ltd., Vs Dcit, E-30, Anand Niketan, Circle-12(2), Basement, New Delhi. New Delhi – 110 001. Pan: Aaacs2041N (Appellant) (Respondent) Assessee By : Shri Sanjay Arora, Ca; Ms Pallavi Sharma, Ca & Shri Jeetan Nagpal, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 29.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 31.05.2019 Of The Commissioner Of Income-Tax (Appeals)-22, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.208/18-19/Cit(A)-22, New Delhi Arising Out Of The Appeal Before It Against The Order Dated 18.03.2016, Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Circle- 12(2), New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Sanjay Arora, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 36(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: C : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year: 2013-14 Involute Engineering Pvt. Ltd., Vs DCIT, E-30, Anand Niketan, Circle-12(2), Basement, New Delhi. New Delhi – 110 001. PAN: AAACS2041N (Appellant) (Respondent) Assessee by : Shri Sanjay Arora, CA; Ms Pallavi Sharma, CA & Shri Jeetan Nagpal, CA Revenue by : Shri Om Prakash, Sr. DR Date of Hearing : 01.05.2025 Date of Pronouncement : 29.05.2025 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the order da…

SKM EGG PRODUCTS EXPORT LTD,ERODE vs. DCIT, CENTRAL CIRCLE SALEM, SALEM

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

ITA 2933/CHNY/2024[2013-14]Status: DisposedITAT Chennai07 Apr 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 2933/Chny/2024 िनधा"रण वष" / Assessment Year: 2013-14 Skm Egg Products Export The Deputy Commissioner (India) Ltd., V. Of Income Tax, No.133/1, Gandhiji Street, Central Circle, Erode – 638 001. Salem. [Pan:Aaccs 7106G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri Shivanand K Kalakeri, Cit सुनवाई क" तार"ख/Date Of Hearing : 12.03.2025 घोषणा क" तार"ख/Date Of Pronouncement : 07.04.2025 आदेश /O R D E R

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri Shivanand K Kalakeri, CIT
Section 143(2)Section 143(3)Section 37

…g this year as the expenses can no longer be capitalized and amortized owing to the failure to set- up a unit in Russia. 5.4 The Ld.AR placed reliance on the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Shri Ram Pistons & Rings Ltd. [2008] 220 CTR 404 (Delhi) wherein it was held as under: “18. In the reference that is before us there is no doubt that the assessee had incurred an expenditure. The only dispute is regarding the date on which the liability had crystallized. It appears that there was no change in the rate of tax for the assessment year 1983-84 with which we are concerned. The quest…

DCIT, GHAZIABAD vs. M/S. DEVIDAYAL ALUMINIUM INDUSTRIES PVT. LTD., GHAZIABAD

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2016[2007-08]Status: DisposedITAT Delhi08 Jan 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…spect of companies remains the same in all these years. Therefore, the Revenue does not lose anything, as it would receive the tax on this income in the succeeding year...." To the same effect are the judgments in CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. (2011) 336 ITR 374 and CIT v. Modipon Ltd. (No.1) (2011) 334 ITR 102 (Del).” ITA No.3850/Del/2023 & Others 52. Heard the contentions of both the parties and perused the material available on record. Admittedly, due to fire, the extra income offered by the assessee in AYs 2017-18 & 2018-19 on accoun…

SECURITY PRINTING AND MINTING CORPORATION OF INDIA LTD,NEW DELHI vs. ACIT, CIRCLE 22(2), NEW DELHI

The appeal of the assessee is dismissed

ITA 1824/DEL/2023[2006-07]Status: DisposedITAT Delhi28 Jun 2024AY 2006-07

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 147Section 154Section 234ASection 244A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.1824/Del/2023, A.Y. 2006-07 Security Printing and ACIT, Minting Corporation of Circle 22(2), India limited Vs. New Delhi 16th Floor, Jawahar Vyapar Bhawan, janpath, Connaught Place, New Delhi PAN: AAJCS6111J (Appellant) (Respondent) Appellant by Shri Y.K.Maghan, CA Respondent by Sh. Anuj Garg, Sr. DR Date of Hearing 24/04/2024 Date of Pronouncement /06/2024 ORDER PER AVDHESH KUMAR MISHRA, AM The appeal filed by the assessee is directed against the…

ITO WARD - 7(1), NEW DELHI vs. DEVIKA GOLD HOMZ PVT LTD, NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 563/DEL/2020[2014-15]Status: DisposedITAT Delhi12 Mar 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usito, Vs. Devika Gold Homz Pvt. Ltd, Ward-7(1), Stilt Floor, Devika Tower, New Delhi New Delhi (Appellant) (Respondent) Pan:Aalcs4525J Assessee By : Shri Somil Agarwal, Adv Shri Deepesh Garg, Adv Revenue By: Shri Vivek Kumar Upadhyay, Sr. Dr Date Of Hearing 18/12/2023 Date Of Pronouncement 12/03/2024

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143Section 143(3)

…then the addition made by the ld AO deserves to be deleted as the entire adjudication of the issue becomes academic in nature. The assessee also placed reliance on the decision Hon‟ble Jurisdictional High Court in the case CIT Vs. Shri Ram Piston reported in 220 CTR 404 (Del) in support of its contentions and another decision in the case of CIT Vs. Vishnu Industrial Pvt. Ltd in ITA No. 229/1998 dated 06.05.2008 of Hon‟ble Jurisdictional High Court. The assessee also pointed out calculation error in the percentage of completion arrived by the ld AO @58.49% as against the correct percentage of 43.26% even if the t…

ADDL. CIT-(08), NEW DELHI vs. SOPRA INDIA PVT. LTD.,, NEW DELHI

In the result, appeal of the Revenue thus is dismissed

ITA 1175/DEL/2019[2012-13]Status: DisposedITAT Delhi16 Oct 2023AY 2012-13
Section 143(3)Section 145

…should be a matter of no consequence to the Department...... ACIT vs. Sopra India Pvt. Ltd. 9 13. The aforesaid observations of the Bombay High Court were reiterated by this Court in the case of Commissioner of Income Tax Vs. Shri Ram Pistons and Rings Ltd. [220 CTR 404], as under: "Finally, we may only mention what has been articulated by the Bombay High Court in Commissioner of Income Tax, Delhi, Ajmer, Rajasthan and Madhya Pradesh vs, Nagri Mills Co. Ltd. [1958] 33 ITR 681 as follows: In the reference that is before us there is no doubt that the Assessee had incurred an expenditure. The only dispute is rega…

DCIT CORPORATE CIRCLE 1(2), CHENNAI vs. CONSOLIDATED CONSTRUCTION CONSORTIUM LTD., CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 845/CHNY/2019[2010-11]Status: DisposedITAT Chennai30 Aug 2023AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri T. Vasanthan, CIT
Section 143(3)

…matters of this kind. But, obviously, judging from the references that come up to us every year or the other." 12.1 The aforesaid observation of the Bombay High Court was reiterated by the Delhi High Court in the case of CIT vs Shri Ram Pistos and Rings Ltd, 220 CTR 404, as under: "Finally, we may only mention what has been articulated by the Bombay High Court in CIT v. Nagri Mills Co. Ltd. [1958] 33 ITR 681 (Bom) as follows : . . . In the reference that is before us there is no doubt that the assessee had incurred an expenditure. The only dispute is regarding the date on which the liability had crystallized. I…

M/S CONSOLIDATED CONSTRUCTION CONSORTIUM LTD,CHENNAI vs. DCIT CORPORATE CIRCLE 1 (2), CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 399/CHNY/2019[2010-11]Status: DisposedITAT Chennai30 Aug 2023AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri T. Vasanthan, CIT
Section 143(3)

…matters of this kind. But, obviously, judging from the references that come up to us every year or the other." 12.1 The aforesaid observation of the Bombay High Court was reiterated by the Delhi High Court in the case of CIT vs Shri Ram Pistos and Rings Ltd, 220 CTR 404, as under: "Finally, we may only mention what has been articulated by the Bombay High Court in CIT v. Nagri Mills Co. Ltd. [1958] 33 ITR 681 (Bom) as follows : . . . In the reference that is before us there is no doubt that the assessee had incurred an expenditure. The only dispute is regarding the date on which the liability had crystallized. I…

DCIT, NEW DELHI vs. M/S. SAHARA INDIA POWER CORPORATION LTD., PUNE

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 5067/DEL/2013[2005-06]Status: PendingITAT Delhi28 Apr 2023AY 2005-06

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…venue neutral and do not affect the tax liability of the assessee likely to be collected by the Revenue as a whole: • CIT vs Glaxo Smithkline Asia (P) Ltd: 195 Taxman 35 (SC) • CIT vs Nagri Mills Company Ltd: 33 ITR 681 (Born) • Shri Ram Pistons & Rings Ltd: 220 CTR 404 (Del) • CIT vs Triveni Engineering Industries Ltd: 239 CTR 216 (Del) 40. For the reasons stated above, the ld. A.R. submitted that the addition made by the assessing officer and sustained by the ld. CIT(A) deserves to be deleted. Re: Ground No. 4 to 6 41. The ld. A.R. submitted that the Assessee, during the previous year, had made payment of Rs…

SAHARA INDIA POWER CORPORATION LTD,PUNE vs. DCIT, NEW DELHI

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 1155/DEL/2009[2004-05]Status: DisposedITAT Delhi28 Apr 2023AY 2004-05

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…venue neutral and do not affect the tax liability of the assessee likely to be collected by the Revenue as a whole: • CIT vs Glaxo Smithkline Asia (P) Ltd: 195 Taxman 35 (SC) • CIT vs Nagri Mills Company Ltd: 33 ITR 681 (Born) • Shri Ram Pistons & Rings Ltd: 220 CTR 404 (Del) • CIT vs Triveni Engineering Industries Ltd: 239 CTR 216 (Del) 40. For the reasons stated above, the ld. A.R. submitted that the addition made by the assessing officer and sustained by the ld. CIT(A) deserves to be deleted. Re: Ground No. 4 to 6 41. The ld. A.R. submitted that the Assessee, during the previous year, had made payment of Rs…

SAHARA INDIA POWER CORPORATION LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 109/PUN/2007[2003-04]Status: DisposedITAT Delhi28 Apr 2023AY 2003-04

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…venue neutral and do not affect the tax liability of the assessee likely to be collected by the Revenue as a whole: • CIT vs Glaxo Smithkline Asia (P) Ltd: 195 Taxman 35 (SC) • CIT vs Nagri Mills Company Ltd: 33 ITR 681 (Born) • Shri Ram Pistons & Rings Ltd: 220 CTR 404 (Del) • CIT vs Triveni Engineering Industries Ltd: 239 CTR 216 (Del) 40. For the reasons stated above, the ld. A.R. submitted that the addition made by the assessing officer and sustained by the ld. CIT(A) deserves to be deleted. Re: Ground No. 4 to 6 41. The ld. A.R. submitted that the Assessee, during the previous year, had made payment of Rs…

DCIT,C-11(1), NEW DELHI vs. HERO MOTOCORP LTD.,, NEW DELHI

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

…ngine Valves Ltd. : 138 ITR 217 (Del) - CIT vs. Bhai Sunder Dass & Sons P. Ltd. : 158 ITR 195 (Del) - CIT vs. Lumax Industries Ltd. : 173 Taxman 390 (Del) - Shriram Pistons & Rings Ltd. vs. CIT : 171 Taxman 81 (Del) - CIT vs. Shri Ram Pistons and Rings Ltd. : 220 CTR 404 (Del) Goodyear India Ltd. vs. ITO : 73 ITD 189 (Del)(TM) - ITO vs. Shivani Locks : 118 TTJ 467 (Del) - Climate Systems India Ltd. vs. CIT: 319 ITR 113 (Del-HC) - CIT vs. Sharda Motor Industries Ltd: 319 ITR 109 (Del-HC) - CIT vs. Essel Propack 325 ITR 185 (Bom) - CIT v. Modi Revlon (P) Ltd: (2012) 9 TMI 48 (Del.) - Mafatlal Denim Ltd. V. DCIT: 20…

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CIT v. Shri Ram Pistons and Rings Ltd. (220 CTR 404) — Cited in 75 Judgments | BharatTax