CIT v. Shri Ram Pistons and Rings Ltd.

220 CTR 404High Court2008#1520 most cited

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

The Income Tax Department should not expend significant time and energy on tax-neutral issues that do not affect the overall tax collection, particularly when determining the year of taxability of income where tax rates remain constant.

75

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2009 to 2025.

Also referred to as

CIT v. Shri Ram Pistons and Rings Ltd. · tax neutral issues · year of taxability · departmental energy · section 143(3) · section 142(1) · section 132(4) · CIT v. Nagri Mills Co. Ltd. · CIT v. Triveni Engg. & Industries Ltd.

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.

ACIT, Chennai vs. East Coast Construction & Industries Limited, Chennai

In the result, the Revenue’s appeal in ITA No

ITA 1433/CHNY/2016[2012-13]Status: DisposedITAT Chennai14 Feb 2018AY 2012-13

Bench: Shri George Mathan & Shri S. Jayaraman

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. D. PrabhuMukunthArun Kumar
Section 263bSection 80Section 801ASection 80I

…of the assessee or the tax that the Department is likely to collect from him whether in one 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 vsShri 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…

ACIT, Chennai vs. East Coast Construction & Industries Limited, Chennai

In the result, the Revenue’s appeal in ITA No

ITA 1432/CHNY/2016[2011-12]Status: DisposedITAT Chennai14 Feb 2018AY 2011-12

Bench: Shri George Mathan & Shri S. Jayaraman

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. D. PrabhuMukunthArun Kumar
Section 263bSection 80Section 801ASection 80I

…of the assessee or the tax that the Department is likely to collect from him whether in one 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 vsShri 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…

ACIT, Chennai vs. East Coast Construction & Industries Limited, Chennai

In the result, the Revenue’s appeal in ITA No

ITA 1431/CHNY/2016[2009-10]Status: DisposedITAT Chennai14 Feb 2018AY 2009-10

Bench: Shri George Mathan & Shri S. Jayaraman

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. D. PrabhuMukunthArun Kumar
Section 263bSection 80Section 801ASection 80I

…of the assessee or the tax that the Department is likely to collect from him whether in one 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 vsShri 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…

East Coast Constructions and Industries Limited, Chennai vs. DCIT, Chennai

In the result, the Revenue’s appeal in ITA No

ITA 864/CHNY/2015[2010-2011]Status: DisposedITAT Chennai14 Feb 2018AY 2010-2011

Bench: Shri George Mathan & Shri S. Jayaraman

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. D. PrabhuMukunthArun Kumar
Section 263bSection 80Section 801ASection 80I

…of the assessee or the tax that the Department is likely to collect from him whether in one 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 vsShri 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…

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

…business expenditure is, in any case, revenue neutral as such in view of the decisions in 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.), and CIT vs. M/s Vishnu Industrial Gases: ITA No. 229/1988 (Del.) Revenue should not agitate issues or make adjustment on issues which are revenue neutral and do not affect overall taxes likely to be collected by the Government. Ld.…

DCIT, New Delhi vs. M/S Dlf Ltd., New Delhi

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

ITA 4342/DEL/2012[2007-08]Status: DisposedITAT Delhi01 Nov 2017AY 2007-08

Bench: Shri B.P. Jain & Shri K.N. Chary.

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Ms. Renu Amitabh, CIT-DR
Section 142Section 143(3)Section 14ASection 250Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘B’ BENCH, NEW DELHI BEFORE SHRI B.P. JAIN, ACCOUNTANT MEMBER AND SHRI K.N. CHARY, JUDICIAL MEMBER. ITA No. 3846/DEL/2012 [A.Y. 2007-08] DLF Limited Vs. The Additional C.I.T DLF Centre (9th Floor) Range - 10 Sansad Marg, New Delhi New Delhi PAN : AAACD 3494 N ITA No. 4342/DEL/2012 [A.Y. 2007-08] The Additional C.I.T Vs. DLF Limited DLF Centre (9th Floor) Range – 10 New Delhi Sansad Marg, New Delhi PAN : AAACD 3494 N [Appellant] [Respondent] Date of Hearing : 03.08.2017 Date of Pronouncement : 01.11.2017 Assessee by : Shri R.S. Singhvi, CA Revenue by : Ms. Re…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

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

ITA 3846/DEL/2012[2007-08]Status: DisposedITAT Delhi01 Nov 2017AY 2007-08

Bench: Shri B.P. Jain & Shri K.N. Chary.

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Ms. Renu Amitabh, CIT-DR
Section 142Section 143(3)Section 14ASection 250Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘B’ BENCH, NEW DELHI BEFORE SHRI B.P. JAIN, ACCOUNTANT MEMBER AND SHRI K.N. CHARY, JUDICIAL MEMBER. ITA No. 3846/DEL/2012 [A.Y. 2007-08] DLF Limited Vs. The Additional C.I.T DLF Centre (9th Floor) Range - 10 Sansad Marg, New Delhi New Delhi PAN : AAACD 3494 N ITA No. 4342/DEL/2012 [A.Y. 2007-08] The Additional C.I.T Vs. DLF Limited DLF Centre (9th Floor) Range – 10 New Delhi Sansad Marg, New Delhi PAN : AAACD 3494 N [Appellant] [Respondent] Date of Hearing : 03.08.2017 Date of Pronouncement : 01.11.2017 Assessee by : Shri R.S. Singhvi, CA Revenue by : Ms. Re…

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

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ―I-2‖: NEW DELHI BEFORE SH. I. C. SUDHIR, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER Hero 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 Page 2 of 484 New Delhi Vs. Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) M/s. Hero Moto Corp. D…

DCIT, New Delhi vs. M/S. Landbase India Ltd., New Delhi

In the result, cross objections of the

ITA 4847/DEL/2009[2003-04]Status: DisposedITAT Delhi15 Jun 2016AY 2003-04

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Rohit Jain, AdvFor Respondent: Smt. Sulekha Verma, CIT-DR
Section 143(3)Section 147Section 148

…e same was allowable in the year under consideration. The ld. Counsel pointed out that the ld. CIT(A) was right in granting relief to the assessee by placing on the decision of the Hon’ble High Court of Delhi in the case of Shri Ram Pistons Ltd reported at 220 CTR 404 [Del]. The ld. AR also pointed out that the ld. CIT(A) rightly considered this fact that the entire amount of 1.28 crore was paid to Gilt Facilities P. Ltd Facilities after deducting TDS which was also deposited on 17.5.2001 and the recipient Gilt Facilities P. Ltd offered this amount to in its return of income in A.Y 2001-02 only. 40. On car…

DCIT, New Delhi vs. M/S. Landbase India Ltd, New Delhi

In the result, cross objections of the

ITA 3549/DEL/2009[2001-02]Status: DisposedITAT Delhi15 Jun 2016AY 2001-02

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Rohit Jain, AdvFor Respondent: Smt. Sulekha Verma, CIT-DR
Section 143(3)Section 147Section 148

…e same was allowable in the year under consideration. The ld. Counsel pointed out that the ld. CIT(A) was right in granting relief to the assessee by placing on the decision of the Hon’ble High Court of Delhi in the case of Shri Ram Pistons Ltd reported at 220 CTR 404 [Del]. The ld. AR also pointed out that the ld. CIT(A) rightly considered this fact that the entire amount of 1.28 crore was paid to Gilt Facilities P. Ltd Facilities after deducting TDS which was also deposited on 17.5.2001 and the recipient Gilt Facilities P. Ltd offered this amount to in its return of income in A.Y 2001-02 only. 40. On car…

ACIT, New Delhi vs. M/S Dlf Ltd., New Delhi

ITA 3061/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…Page 1 of 144 IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘B’: NEW DELHI) BEFORE SHRI A.T. VARKEY, JUDICIAL MEMBER and SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ITA No.2677/Del./2011 (ASSESSMENT YEAR: 2006-07) M/s. DLF Limited vs. Addl.CIT, DLF Centre, 9th Floor, Sansad Range 10, New Delhi Marg, New Delhi – 110 001. (PAN AAACD3494N) Appellant Respondent ITA No.3061/Del./2011 (ASSESSMENT YEAR: 2006-07) Addl.CIT, vs. M/s. DLF Limited Range 10, DLF Centre, 9th Floor, New Delhi Sansad Marg, New Delhi – 110 001. (PAN AACD3494N Appellant Respondent Assesse by Shri R.S. Singhvi, Advocate Page 2 of 144 Revenue b…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 2677/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…Page 1 of 144 IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘B’: NEW DELHI) BEFORE SHRI A.T. VARKEY, JUDICIAL MEMBER and SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ITA No.2677/Del./2011 (ASSESSMENT YEAR: 2006-07) M/s. DLF Limited vs. Addl.CIT, DLF Centre, 9th Floor, Sansad Range 10, New Delhi Marg, New Delhi – 110 001. (PAN AAACD3494N) Appellant Respondent ITA No.3061/Del./2011 (ASSESSMENT YEAR: 2006-07) Addl.CIT, vs. M/s. DLF Limited Range 10, DLF Centre, 9th Floor, New Delhi Sansad Marg, New Delhi – 110 001. (PAN AACD3494N Appellant Respondent Assesse by Shri R.S. Singhvi, Advocate Page 2 of 144 Revenue b…

Commissioner of Income Tax vs. Triveni Engineering & Industries Ltd

ITA - 346 / 2009HC Delhi29 Nov 2010
Section 37(1)

…ax that the Department is likely to collect from him whether in one year or the other.” 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, Rajastha and Madhya Pradesh vs. Nagri Mills Co. Ltd. [1958] 33 ITR 681 as follows: … …. …. …. 2010:DHC:5743-DB In the reference that is before us there is no doubt that the Assessee had incurred…

Commissioner of Income Tax vs. Shriram Pistons & Rings Limited

Appeal is partly allowed, as aforesaid

ITA-815/2007HC Delhi23 Dec 2009
Section 5Section 80Section 80H

…red in favour of the assessee by two judgments of jurisdictional case in the case of assessee itself, viz., Shriram Pistons and Rings Ltd. vs. Commissioner of Income Tax [307 ITR 363(Del) and Commissioner of Income Tax vs. Shriram Pistons and Rings Ltd. [220 CTR 404 (Del)]. The view taken therein finds support from the judgment of this Court in the case of Commissioner of Income Tax vs. J.K. Synthetics [309 ITR 371 (Del)]. Insofar as the second question is concerned, this again is covered in favour of the assessee in ITA No. 170-71 of 1994 decided on 05.05.2008 entitled Shriram Pistons and Rings Ltd.…

Commissioner of Income Tax vs. Shriram Pistons & Rings Limited

Appeal is partly allowed, as aforesaid

ITA - 815 / 2007HC Delhi23 Dec 2009
Section 5Section 80Section 80H

…red in favour of the assessee by two judgments of jurisdictional case in the case of assessee itself, viz., Shriram Pistons and Rings Ltd. vs. Commissioner of Income Tax [307 ITR 363(Del) and Commissioner of Income Tax vs. Shriram Pistons and Rings Ltd. [220 CTR 404 (Del)]. The view taken therein finds support from the judgment of this Court in the case of Commissioner of Income Tax vs. J.K. Synthetics [309 ITR 371 (Del)]. Insofar as the second question is concerned, this again is covered in favour of the assessee in ITA No. 170-71 of 1994 decided on 05.05.2008 entitled Shriram Pistons and Rings Ltd.…