CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd.

336 ITR 374High Court2011#2787 most cited

What is CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd. authority for?

No penalty can be imposed when there is no loss of revenue, and the only issue concerns the year of taxability of income.

42

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Shri Ram Pistons and Rings Ltd. · CIT v. Triveni Engineering and Industries Ltd. · penalty · year of taxability · no loss of revenue · section 143(3) · section 153A · section 153C · section 132(4) · section 132(4A)

Sections most often in play

Section 143(3)Section 127Section 132(4)Section 132(4A)Section 143(2)Section 153ASection 153CSection 2(24)(x)

Issues it is cited on

section 36(i)(va)true and full disclosuresection 153(a)retraction of statementcorporate guaranteesection 145(2)statement under section 132(4)retracted statementwritten down valuepercentage completion methodput to usesection 132(4a)

Judgments citing CIT v. Shri Ram Pistons and Rings Ltd. (2008) 220 CTR 404, CIT v. Triveni Engineering and Industries Ltd.

ACIT, Bangalore vs. M/S. Abb Limited, Bangalore

In the result, the revenue’s appeal is dismissed

ITA 755/BANG/2007[2001-02]Status: DisposedITAT Bangalore04 Mar 2021AY 2001-02

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2001-02

For Appellant: Shri Percy Pardiwalla, Sr. CounselFor Respondent: Shri Dilip, Sr. Standing Counsel for the Dept
Section 80Section 80H

…ethod was contrary to mercantile system of Accounting. The Tribunal held that since the POC method was consistently and regularly employed and was a recognized method, the AO was not justified in departing from it. (3) CIT Vs. Triveni Engg. & Industries Ltd. 336 ITR 374 (Delhi) for AY 2000-01, in which it was held that when the Assessee followed Completed contract method of accounting income from projects, provision for expenses to be incurred up to the stage of completion of contract was to be allowed as deduction as it was not disputed that it was not a contingent liability but the dispute was only in the year…

M/S. Abb Limited(Formerly Asea Brown Boveri Limited), Bangalore vs. ACIT, Bangalore

In the result, the revenue’s appeal is dismissed

ITA 562/BANG/2007[2001-02]Status: DisposedITAT Bangalore04 Mar 2021AY 2001-02

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2001-02

For Appellant: Shri Percy Pardiwalla, Sr. CounselFor Respondent: Shri Dilip, Sr. Standing Counsel for the Dept
Section 80Section 80H

…ethod was contrary to mercantile system of Accounting. The Tribunal held that since the POC method was consistently and regularly employed and was a recognized method, the AO was not justified in departing from it. (3) CIT Vs. Triveni Engg. & Industries Ltd. 336 ITR 374 (Delhi) for AY 2000-01, in which it was held that when the Assessee followed Completed contract method of accounting income from projects, provision for expenses to be incurred up to the stage of completion of contract was to be allowed as deduction as it was not disputed that it was not a contingent liability but the dispute was only in the year…

M/S Fastway Transmission (P) Ltd., Chandigarh vs. DCIT, CC-II, Chandigarh

In the result the captioned appeals of the assessee are

ITA 140/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh28 Apr 2020AY 2015-16

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Chandrajit Singh, CIT (DR) on 4.12.2019
Section 250(6)

…t would be a revenue neutral exercise. Either the assessee would be entitled to lease charges or to depreciation. He is this respect has relied upon the decision of the Delhi High Court in the case of “CIT v. Triveni Engineering and Industries Ltd.” [2011] 336 ITR 374 (Delhi). 13. The Department has also filed various documents and written submissions in support of its contention. The main thrust of the Ld. DR has been that the impugned agreement was a loan/finance agreement, with the assessee being the owner of the asset for all practical purposes and CISCO being the financer. The arguments of the Ld. DR…

M/S Fastway Transmission (P) Ltd., Chandigarh vs. DCIT, CC-II, Chandigarh

In the result the captioned appeals of the assessee are

ITA 139/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh28 Apr 2020AY 2012-13

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Chandrajit Singh, CIT (DR) on 4.12.2019
Section 250(6)

…t would be a revenue neutral exercise. Either the assessee would be entitled to lease charges or to depreciation. He is this respect has relied upon the decision of the Delhi High Court in the case of “CIT v. Triveni Engineering and Industries Ltd.” [2011] 336 ITR 374 (Delhi). 13. The Department has also filed various documents and written submissions in support of its contention. The main thrust of the Ld. DR has been that the impugned agreement was a loan/finance agreement, with the assessee being the owner of the asset for all practical purposes and CISCO being the financer. The arguments of the Ld. DR…

M/S Fastway Transmission (P) Ltd., Chandigarh vs. ACIT, Chandigarh

In the result the captioned appeals of the assessee are

ITA 547/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh28 Apr 2020AY 2013-14

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Chandrajit Singh, CIT (DR) on 4.12.2019
Section 250(6)

…t would be a revenue neutral exercise. Either the assessee would be entitled to lease charges or to depreciation. He is this respect has relied upon the decision of the Delhi High Court in the case of “CIT v. Triveni Engineering and Industries Ltd.” [2011] 336 ITR 374 (Delhi). 13. The Department has also filed various documents and written submissions in support of its contention. The main thrust of the Ld. DR has been that the impugned agreement was a loan/finance agreement, with the assessee being the owner of the asset for all practical purposes and CISCO being the financer. The arguments of the Ld. DR…

Cavalcade Properties P. Ltd, Mumbai vs. ITO WD 12(1)(4), Mumbai

Accordingly, grounds raised by the assessee are allowed

ITA 4030/MUM/2017[2011-12]Status: DisposedITAT Mumbai30 Oct 2019AY 2011-12

Bench: Shri S. Rifaur Rahman, Am& Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 4030/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13)

For Appellant: Shri Madhur Agarwal, AR byFor Respondent: Shri Awangshi Gimson, DR
Section 115JSection 143(1)Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, AM& SHRI RAM LAL NEGI, JM आयकरअपीलसं./ I.T.A. No. 4030/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13) ITO Ward 12(1)(4), M/s Cavalcade Properties Aayakar Bhavan, Pvt. Ltd. Churchgate, बिधम/ Plot No. C-30, G-Block, Mumbai-400 020 Opp-SIDBI, Bandra Kurla Vs. Complex, Bandra (east), Mumbai 400 051 स्थायीलेखासं./जीआइआरसं./PAN No. AACCC6226B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : आयकरअपीलसं./ I.T.A. No. 4273/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13) ITO Ward 12(1)(4), M/s Cavalcade Properties Aayakar Bhavan, Pvt…

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

…cted by the Government. • CIT v. Excel Industries Ltd and Mafatlal Industries (P) Ltd.: 358 ITR 295 (SC) CIT v. Bilahari Investment P. Ltd.: 299 ITR 1 (SC) • • CIT v. Shri Ram Pistons & Rings Ltd.: 220 CTR 404 (Del.) • CIT v. Triveni Engg. & Industries Ltd.: 336 ITR 374 (Del.) • CIT v. Nagri Mills Co. Ltd.: 33 ITR 681 (Bom.) • CIT vs. M/s Vishnu Industrial Gases: ITA No. 229/1988 (Del.) In view of the aforesaid, the Ld. AR submitted that the assessing officer may be directed to delete the arbitrary disallowance based on an adhoc percentage of the turnover made in the impugned assessment order. The aforesaid iss…

DCIT, New Delhi vs. M/S G4S It Services India Pvt. Ltd., Gurgaon

In the result appeal of the revenue is dismissed

ITA 3897/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Oct 2018AY 2010-11

Bench: Shri Bhavnesh Saini & Shri L.P. Sahuasstt. Year: 2010-11

For Appellant: Shri Arvind Rajan, AdvFor Respondent: Shri Surender Pal, Sr.DR
Section 4Section 4(7)

…e while in AY 2010-11, loss has been claimed by the appellant. Therefore, no fruitful purpose will be served if such exercise is done in the appellant's case. The Hon'ble Jurisdictional High Court in the case of CIT vs. M/s Triveni Engineering Industries Ltd. 336 ITR 374 (Del) has time and again upheld that if the rates of taxation are uniform, it does not make a difference if a portion of income is taxed in either of the years as such exercise becomes revenue neutral. In appellant's case, the position is even in the favour of the appellant if such exercise of bifurcation of income is made. In my considered view,…

M/S Karnataka Vidyuth Kharkane Ltd vs. DCIT

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

ITA 1581/BANG/2013[2010-11]Status: DisposedITAT Bangalore11 Apr 2018AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Arun Kumar Garodiaassessment Year :2010-11

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Shri B.R. Ramesh, JCIT (DR)
Section 234BSection 37

…upport of its claim as below :- (a) M/s Bharat Earth Movers Vs CIT (2000) 245 ITR 428 (SC) (b) OIL & Natural Gas Corpn. Ltd. Vs. CIT (2010) 322 ITR 180(SC) (c) CIT Vs Dinesh Kumar Goel (2011) 331 ITR 10 (Delhi) (d) CIT Vs Triveni Engg. & Industries Ltd (2011) 336 ITR 374 (Delhi) (e) CIT Vs. Ansal Properties & Industries Ltd.(2013 352 ITR 637 (Delhi) (f) Prakash Leasing Ltd Vs. Dy. CIT (2012) Contents of the decisions are discussed in succeeding para. 8.0 The facts narrated above it is implicitly clear that, no amount was credited in the ledger accounts of the consumers towards negative price variation except Rs…

The Asst. CIT, Guntur vs. Sri Grandhi Subba Rao, Guntur

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

ITA 239/VIZ/2017[2011-2012]Status: DisposedITAT Visakhapatnam16 Mar 2018AY 2011-2012

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri G.V.N. Hari, ARFor Respondent: Shri P.S. Murthy, DR
Section 143(1)Section 143(3)Section 263Section 41(1)

…mbay High Court with regard to the 12 ITA No.223/Vizag/2015 & ITA No.239/Vizag/2017 Grandhi Venkata Satya Lakshmi Kantha Rao, L/R of Grandhi Subba Rao, Guntur year of allowability of expenditure in the case of Triveni Industries Engineering Limited (2011) 336 ITR 374 (Bom) relied upon by the assessee held as under: "11. After considering the submissions of the counsel on the either side, in the given facts, we are prima fade of the view that arguments of the learned counsel for the assessee to prevail. The learned counsel for the Revenue may be correct in stating the proposition of law, generally. No doubt,…

Grandhi Subbarao, Guntur vs. The Addl. CIT, Guntur

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

ITA 223/VIZ/2015[2011-12]Status: DisposedITAT Visakhapatnam16 Mar 2018AY 2011-12

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri G.V.N. Hari, ARFor Respondent: Shri P.S. Murthy, DR
Section 143(1)Section 143(3)Section 263Section 41(1)

…mbay High Court with regard to the 12 ITA No.223/Vizag/2015 & ITA No.239/Vizag/2017 Grandhi Venkata Satya Lakshmi Kantha Rao, L/R of Grandhi Subba Rao, Guntur year of allowability of expenditure in the case of Triveni Industries Engineering Limited (2011) 336 ITR 374 (Bom) relied upon by the assessee held as under: "11. After considering the submissions of the counsel on the either side, in the given facts, we are prima fade of the view that arguments of the learned counsel for the assessee to prevail. The learned counsel for the Revenue may be correct in stating the proposition of law, generally. No doubt,…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I’ NEW DELHI BEFORE SHRI N.K. SAINI, ACCOUNTANT MEMBER & SHRI K.N. CHARRY, JUDICIAL MEMBER ITA No.-6021/Del/2012 (Assessment Year: 2008-09) Maruti Suzuki India Ltd. vs Addl. CIT Plot No. 1, Nelson Mandela Road, Range-6, Vasant Kunj, New Delhi. C.R. Building, PAN-AAACM0829Q New Delhi. (APPELLANT) (RESPONDENT) Assessee by Sh. Ajay Vohra Revenue by Sh. Aprender Kumar Date of Hearing 21.08.2017 Date of Pronouncement 09.11.2017 ORDER PER SHRI K.N. CHARY, JUDICIAL MEMBER This is an appeal challenging the order dated 29.10.2012 passed by the Assessing Officer u/…

DCIT, Circle - 1, Kolkata vs. M/S. Mcnally Bharat Engineering Company Limited, Kolkata

In the result, appeal of revenue stands dismissed

ITA 99/KOL/2011[2003-04]Status: DisposedITAT Kolkata11 Jan 2017AY 2003-04

Bench: Shri Waseem Ahmed, Am & Shri S.S.Viswanethra Ravi, Jm आयकर अपील सं./Ita No.99/Kol/2011 ("नधा"रण वष" / Assessment Year :2003-2004) Dcit, Circle-1, Vs. M/S Mcnally Bharat 7Th Floor, Aayakar Bhawan, Engineering Company Ltd, Kolkata-700069 4, Mangoe Lane,Kolkata-1 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcm 9443 R .. (अपीलाथ" /Appellant) (""यथ" / Respondent) राज"व क" ओर से /Revenue By : Shri Ram Bilas Meena, Cit "नधा"रती क" ओर से /Assessee By : Shri Vijay Shah Ca सुनवाई क" तार"ख / Date Of Hearing : 21/12/2016 घोषणा क" तार"ख/Date Of Pronouncement 11/01/2017 आदेश / O R D E R Per Shri Waseem Ahmed, Am: The Above Appeal Is Directed By The Revenue Against The Order Dated 20.09.2010, Passed By The Ld. Commissioner Of Income Tax (Appeals)-I, Kolkata In Appeal No.605/Cit(A)-1/Cir.1/.09-10, Pertaining To Assessment Year 2003-04, Arising Out Of Assessment Order Dated 31.12.2009, Passed By The Cit-1 Kolkata U/S.143(3)/254 Of The Income Tax Act, 1961. The Revenue Has Raised The Following Grounds Of Appeal :-

For Appellant: Shri Vijay Shah CAFor Respondent: Shri Ram Bilas Meena, CIT
Section 143(3)Section 37

…आयकर अपील"य अ"धकरण, कोलकाता "यायपीठ ‘ए’, कोलकाता। IN THE INCOME TAX APPELLATE TRIBUNAL “A”, BENCH KOLKATA BEFORE SHRI WASEEM AHMED, AM & SHRI S.S.VISWANETHRA RAVI, JM आयकर अपील सं./ITA No.99/Kol/2011 ("नधा"रण वष" / Assessment Year :2003-2004) DCIT, Circle-1, Vs. M/s McNally Bharat 7th Floor, Aayakar Bhawan, Engineering Company Ltd, Kolkata-700069 4, Mangoe Lane,Kolkata-1 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AABCM 9443 R .. (अपीलाथ" /Appellant) (""यथ" / Respondent) राज"व क" ओर से /Revenue by : Shri Ram Bilas Meena, CIT "नधा"रती क" ओर से /Assessee by : Shri Vijay Shah CA सुनवाई क" तार"ख / Date of Hearing : 21/1…

Hero Motocorp Limited, New Delhi vs. JCIT, New Delhi

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR
Section 143Section 143(3)Section 144CSection 92C

…e addition, if any, is revenue neutral, if seen in a macro perspective and, therefore, no adjustment is called for. [Refer: CIT v. Excel Industries Ltd.:358 ITR 295 (SC); CIT v. Nagri Mills Company Ltd.: 33 ITR 681 (Bom.); Triveni Engineering Industries Ltd.: 336 ITR 374 (Del.)] d. He further argued that The contention of the assessing officer that the revenue aspect will keep on changing from year to year, as there might be chances when in one year Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12)…

M/S Bairavi Properties & Construction Pvt. Ltd vs. DCIT

In the result, the appeal of the assessee is dismissed

ITA 203/BANG/2014[2007-08]Status: DisposedITAT Bangalore30 Sept 2016AY 2007-08

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Shri S . Sundar Rajan, JCIT (D.R)
Section 143(3)Section 263

…ching concept. In support of his contention he has relied upon the following decisions : a) Rotork Controls India (P.) Ltd. Vs. CIT (2009) 180 Taxman 422 (SC) b) Calcutta Co. LTd. Vs. CIT (1959) 37 ITR 1 (SC) c) CIT Vs. Triveni Engg. & Industries Ltd. (2011) 336 ITR 374 (Del) d) ACIT Vs. Krishna Grameena Bank 2016-TIOL-945-ITAT-BANG. He has further contended that the deduction is also permissible under the Income Tax Act even if the actual payment is not made but if the liability is incurred. Therefore when the assessee is following the Mercantile System of Accounting then the expenditure which is already 8 in…

ACIT 10(1), Mumbai vs. Shivshahi Punarvasan Prakalp Ltd, Mumbai

In the result, the Revenue’s appeals for A

ITA 8458/MUM/2010[2006-07]Status: DisposedITAT Mumbai23 Sept 2016AY 2006-07
For Respondent: Shri P. R. Ghosh

…order of CIT(A) on this issue in all the years under consideration. 2.11.5 to 2.11.6 …..……’ The decisions relied upon by the assessee, viz. CIT vs. Woodward Governor India (P) Ltd. [2009] 312 ITR 254 (SC); CIT vs. Triveni Engineering & Industries ltd. [2011] 336 ITR 374 (Del), as well as by the tribunal in the case of Mazagon Dock Ltd. vs. CIT [2009] 29 SOT 356 (Mum) and Jacob Engineering vs. Asst. CIT (in ITA Nos. 335 and 336/Mum/2007 dated 26.5.2009) were explained and (A.Ys. 2006-07 to 2009-10) Shivshahi Punarvasan Prakalp Ltd. distinguished. The working of the profit/loss on the different projects on a propo…

SHI vs. Hahi Punarvasan Prakalp Ltd, Mumbai

In the result, the Revenue’s appeals for A

ITA 8251/MUM/2010[2007-08]Status: DisposedITAT Mumbai23 Sept 2016AY 2007-08
For Respondent: Shri P. R. Ghosh

…order of CIT(A) on this issue in all the years under consideration. 2.11.5 to 2.11.6 …..……’ The decisions relied upon by the assessee, viz. CIT vs. Woodward Governor India (P) Ltd. [2009] 312 ITR 254 (SC); CIT vs. Triveni Engineering & Industries ltd. [2011] 336 ITR 374 (Del), as well as by the tribunal in the case of Mazagon Dock Ltd. vs. CIT [2009] 29 SOT 356 (Mum) and Jacob Engineering vs. Asst. CIT (in ITA Nos. 335 and 336/Mum/2007 dated 26.5.2009) were explained and (A.Ys. 2006-07 to 2009-10) Shivshahi Punarvasan Prakalp Ltd. distinguished. The working of the profit/loss on the different projects on a propo…

ADIT, New Delhi vs. M/S. Rolls Royce Singapore Pte Ltd., New Delhi

In the result all the four appeals of the Revenue are dismissed

ITA 862/DEL/2012[2001-02]Status: DisposedITAT Delhi24 Aug 2016AY 2001-02

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: Sh. V.R. Sonbhadra, Sr. DRFor Respondent: Sh Gaurav Gupta, Advocate &
Section 115ASection 143(3)Section 148Section 271(1)Section 271(1)(c)

…osition that where there is no loss of revenue but only issue is year of taxability, no penalty can be imposed : 9 ITA No.862 to 865/Del./2014 i). CIT vs. Nagri Mills Co. Ltd. (1958) 33 ITR 681 (Bom). (ii). CIT v Triveni Engineering & Industries Ltd. (2011) 336 ITR 374, (ii(i). CIT v Shriram Pistons & Rings Ltd., judgement dated 5.5.2008 in appeal number: ITR 133 / 1991 (iv). CIT v Vishnu Industrial Gases P. Ltd.: judgement date 06/05/2008 in appeal number: ITR No. 229/1988 (v). In the case of CIT v. Excel Industries Ltd. [2013] 358 ITR 295 (SC) 6.3 It was also submitted that mere making mere making an incorre…

ACIT, Chennai vs. V.S.L.India Private Limited, Chennai

In the result, the appeal of the Department in ITA

ITA 1703/CHNY/2013[2008-09]Status: DisposedITAT Chennai01 Feb 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. V. Vivekanandan, CIT. DRFor Respondent: Shri. R. Vijayaraghavan, Advocate
Section 143(1)Section 143(2)Section 143(3)Section 195Section 40

…tive has substantiated his arguments with the submission on disallowance by giving details of working of the project of the company alongwith work status and also foreseeable losses and relied on the decisions of CIT vs. Triveni Engineering Industries Ltd.: 336 ITR 374 and CIT vs Bilahari Investments P. Ltd. [2008] 299 ITR 1 (SC). 8.6 We have heard the rival submissions of both the parties and perused the material on record and also judicial decisions cited. The assessee has claimed foreseeable loss of "18,49,199/- based on Accounting Standard 7 applicable to construction contracts and evaluated projects a…

ACIT, Chennai vs. V.S.L.India Private Limited, Chennai

In the result, the appeal of the Department in ITA

ITA 1702/CHNY/2013[2007-08]Status: DisposedITAT Chennai01 Feb 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. V. Vivekanandan, CIT. DRFor Respondent: Shri. R. Vijayaraghavan, Advocate
Section 143(1)Section 143(2)Section 143(3)Section 195Section 40

…tive has substantiated his arguments with the submission on disallowance by giving details of working of the project of the company alongwith work status and also foreseeable losses and relied on the decisions of CIT vs. Triveni Engineering Industries Ltd.: 336 ITR 374 and CIT vs Bilahari Investments P. Ltd. [2008] 299 ITR 1 (SC). 8.6 We have heard the rival submissions of both the parties and perused the material on record and also judicial decisions cited. The assessee has claimed foreseeable loss of "18,49,199/- based on Accounting Standard 7 applicable to construction contracts and evaluated projects a…