CIT v. Sitaldas Tirathdas

41 ITR 367Supreme Court of India1961#691 most cited

What is CIT v. Sitaldas Tirathdas authority for?

Income is diverted by an overriding charge, and thus not taxable, when it never truly accrues to the assessee due to a prior obligation. Conversely, income that first accrues to the assessee and is then applied to discharge an obligation out of that income is taxable.

146

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Sitaldas Tirathdas · 41 ITR 367 SC · diversion of income by overriding charge · application of income · income never reached assessee · assessable income test · obligation to apply income · right to receive income · taxability of income · overriding obligation principle

Sections most often in play

Section 143(3)Section 144BSection 142(1)Section 14ASection 199Section 80IASection 263Section 90(1)

Issues it is cited on

section 80ia(4)(i)section 90(1)section 80ia(4)infrastructure facilitydeduction under section 80iasection 199right to receiveapplication of incomededuction u/s 80iasection 80iasection 90section 45

Judgments citing CIT v. Sitaldas Tirathdas

THE MADHAVPURA MERCANTILE CO. OP. BANK LIMITED (UNDER LIQUIDATION),AHMEDABAD vs. THE ACIT, CIRCLE-1(2), AHMEDABAD

The appeal of the assessee is partly allowed

ITA 2242/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Apr 2026AY 2017-18

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3)Section 154Section 50Section 72(1)

…e by reason of an overriding title is quite inapposite. The doctrine applies when, by reason of an overriding title or obligation, income is diverted and never reaches the person in whose hands it is sought to be assessed [See CIT v. Sitaldas Tirathdas [1961] 41 ITR 367 (SC)] In the present case, the statute requires the electricity company to create certain reserves if its clear profit, exceeds a reasonable return (clause II, Sixth Schedule). Again, the contingencies reserve is to be created from existing reserves or from 'the revenues of the undertaking'. This clearly indicates that the monies which have to be…

THE MADHAVPURA MERCANTILE CO. OP. BANK LIMITED (UNDER LIQUIDATION),AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is partly allowed

ITA 2241/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Apr 2026AY 2016-17

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3)Section 154Section 50Section 72(1)

…e by reason of an overriding title is quite inapposite. The doctrine applies when, by reason of an overriding title or obligation, income is diverted and never reaches the person in whose hands it is sought to be assessed [See CIT v. Sitaldas Tirathdas [1961] 41 ITR 367 (SC)] In the present case, the statute requires the electricity company to create certain reserves if its clear profit, exceeds a reasonable return (clause II, Sixth Schedule). Again, the contingencies reserve is to be created from existing reserves or from 'the revenues of the undertaking'. This clearly indicates that the monies which have to be…

DELOITTE HASKINS AND SELLS LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 16(2), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 351/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

…us, the outstanding fees paid to the retiring partners as per the terms of the deed of retirement were held not assessable as income of the firm. The Hon'ble Court by relying on the decision of Hon'ble Supreme Court in the case of Sital Das Thirath Das [1961] 41 ITR 367 (SC) noted that the true teat for the application of the rule of diversion of income by overriding charge was whether the amount deducted in truth never reached the assessee as income. According to it, there is a difference between the amount which a person is obliged to apply out of his income and amount which by the nature of the obligation cann…

DELOITTE HASKINS AND SELLS LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 16(2), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 350/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

…us, the outstanding fees paid to the retiring partners as per the terms of the deed of retirement were held not assessable as income of the firm. The Hon'ble Court by relying on the decision of Hon'ble Supreme Court in the case of Sital Das Thirath Das [1961] 41 ITR 367 (SC) noted that the true teat for the application of the rule of diversion of income by overriding charge was whether the amount deducted in truth never reached the assessee as income. According to it, there is a difference between the amount which a person is obliged to apply out of his income and amount which by the nature of the obligation cann…

DELOITTE HASKINS AND SELLS LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 320/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

…us, the outstanding fees paid to the retiring partners as per the terms of the deed of retirement were held not assessable as income of the firm. The Hon'ble Court by relying on the decision of Hon'ble Supreme Court in the case of Sital Das Thirath Das [1961] 41 ITR 367 (SC) noted that the true teat for the application of the rule of diversion of income by overriding charge was whether the amount deducted in truth never reached the assessee as income. According to it, there is a difference between the amount which a person is obliged to apply out of his income and amount which by the nature of the obligation cann…

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

ITA 744/CHNY/2005[2000-01]Status: DisposedITAT Chennai26 Dec 2025AY 2000-01

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T
Section 132Section 148Section 15Section 158BSection 17(1)(iv)

…me is required to be applied to discharge an obligation after such income reaches the Appellant, the same consequences, in law, does not follow: :-8-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 CIT, Bombay v. Sitaldas Tirathdas (1961) 41 ITR 367 (SC) CIT, W.B. v. Imperial Chemical Industries Pvt. Ltd. (1969) 74 ITR 17 (SC) M.K. Brother Pvt. Ltd. v. CIT, Kanpur (1972) 86 ITR 38 (SC) Addl. CIT v. Rani Preetam Kunwar (1980) 125 ITR 102 (All) Tuticorin Alikali Chemicals & Fertilizers Ltd. 227 ITR 172 (SC) As already observed, M/s PPL was liable to pay interest on the loans taken from various…

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

ITA 2197/CHNY/2005[1999-2000]Status: DisposedITAT Chennai26 Dec 2025AY 1999-2000

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T
Section 132Section 148Section 15Section 158BSection 17(1)(iv)

…me is required to be applied to discharge an obligation after such income reaches the Appellant, the same consequences, in law, does not follow: :-8-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 CIT, Bombay v. Sitaldas Tirathdas (1961) 41 ITR 367 (SC) CIT, W.B. v. Imperial Chemical Industries Pvt. Ltd. (1969) 74 ITR 17 (SC) M.K. Brother Pvt. Ltd. v. CIT, Kanpur (1972) 86 ITR 38 (SC) Addl. CIT v. Rani Preetam Kunwar (1980) 125 ITR 102 (All) Tuticorin Alikali Chemicals & Fertilizers Ltd. 227 ITR 172 (SC) As already observed, M/s PPL was liable to pay interest on the loans taken from various…

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

ITA 482/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam10 Oct 2025AY 2020-21

Bench: Us:

Section 143(3)Section 144BSection 48

…s (supra) paid by the purchasers of the subject property, i.e., M/s APSN Properties LLP & Ors. could not have been assessed in the hands of the assessee is supported by the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Sitaldas Tirathdas (1961) 41 ITR 367 (SC). Also, as there was a binding contract between the assessee and the banks, viz. (i). SBI; and (ii). Axis Bank Ltd., wherein by mortgaging the subject property for the loans raised by the third parties, the said banks based on the contractual obligation as 38 ITA No.482/Viz/2024 & CO No.03/Viz/2025 Surendra Nath Gubbala per their superior tit…

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 746/JPR/2025[2019-20]Status: DisposedITAT Jaipur02 Sept 2025AY 2019-20

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…the person to whom it is payable. It is a diversion of income by over-riding title on which there is no obligation on the assessee to deduct tax at source. The assessee has relied on the decision of Hon'ble Supreme Court in case of CIT Vs. Sitaldas Tirathdas 41 ITR 367, Damlia Cement Ltd. Vs. CIT 237 ITR 617 and decision of Hon'ble Kerala High Court in case of Sarla Devi Vs. CIT 222 ITR 211 on this issue which is correctly appreciated by the appellate authority. Hence only because the entire amount collected in the donation box is deposited in the bank account of assessee and from their amount is paid to the tru…

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 745/JPR/2025[2018-19]Status: DisposedITAT Jaipur02 Sept 2025AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…the person to whom it is payable. It is a diversion of income by over-riding title on which there is no obligation on the assessee to deduct tax at source. The assessee has relied on the decision of Hon'ble Supreme Court in case of CIT Vs. Sitaldas Tirathdas 41 ITR 367, Damlia Cement Ltd. Vs. CIT 237 ITR 617 and decision of Hon'ble Kerala High Court in case of Sarla Devi Vs. CIT 222 ITR 211 on this issue which is correctly appreciated by the appellate authority. Hence only because the entire amount collected in the donation box is deposited in the bank account of assessee and from their amount is paid to the tru…

ITO (TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 744/JPR/2025[2016-17]Status: DisposedITAT Jaipur02 Sept 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…the person to whom it is payable. It is a diversion of income by over-riding title on which there is no obligation on the assessee to deduct tax at source. The assessee has relied on the decision of Hon'ble Supreme Court in case of CIT Vs. Sitaldas Tirathdas 41 ITR 367, Damlia Cement Ltd. Vs. CIT 237 ITR 617 and decision of Hon'ble Kerala High Court in case of Sarla Devi Vs. CIT 222 ITR 211 on this issue which is correctly appreciated by the appellate authority. Hence only because the entire amount collected in the donation box is deposited in the bank account of assessee and from their amount is paid to the tru…

ITO(TDS) ALWAR, ALWAR vs. SHRI BABA MOHAN RAMJI KALIKHOLI WALAMILKPUR GURJAR, ALWAR

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 739/JPR/2025[2017-18]Status: DisposedITAT Jaipur02 Sept 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…the person to whom it is payable. It is a diversion of income by over-riding title on which there is no obligation on the assessee to deduct tax at source. The assessee has relied on the decision of Hon'ble Supreme Court in case of CIT Vs. Sitaldas Tirathdas 41 ITR 367, Damlia Cement Ltd. Vs. CIT 237 ITR 617 and decision of Hon'ble Kerala High Court in case of Sarla Devi Vs. CIT 222 ITR 211 on this issue which is correctly appreciated by the appellate authority. Hence only because the entire amount collected in the donation box is deposited in the bank account of assessee and from their amount is paid to the tru…

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 727/BANG/2025[2022-23]Status: DisposedITAT Bangalore23 Jul 2025AY 2022-23

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 726/BANG/2025[2018-19]Status: DisposedITAT Bangalore23 Jul 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 725/BANG/2025[2017-18]Status: DisposedITAT Bangalore23 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 724/BANG/2025[201617]Status: DisposedITAT Bangalore23 Jul 2025

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 723/BANG/2025[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 486/BANG/2025[2022-23]Status: DisposedITAT Bangalore23 Jul 2025AY 2022-23

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 485/BANG/2025[2018-19]Status: DisposedITAT Bangalore23 Jul 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

DEPUTY COMMISSIONER OF INCOME TAX, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

ITA 484/BANG/2025[2017-18]Status: DisposedITAT Bangalore23 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Smt. Priyanka Jain and Shri. Pankaj Soni, AdvocatesFor Respondent: Shri. Kiran D, CIT(DR)(ITAT), Bangalore
Section 142(1)Section 14ASection 80I

…not showing the interest income in its P & L Account and taking it directly to the balance sheet. The vie‘‘ taken by the CIT (A) has been affirmed by the ITAT and is consistent with the decision of the Supreme Court of India in CIT v. SitaldasTirathdas (1961) 41 ITR 367 (SC) and several decisions of the High Courts including DCM Ltd. v. CIT (2004) 192 CTR (Del.) 408 and Somaiya Orgeno-Chemicals Ltd., v. CIT (1995) 216 ITR 291 (Bom.). Consequently, the Court declines to frame a question on this issue as well.” ITA Nos.723 to 727/Bang/2025 482 to 486/Bang/2025 Page 8 of 14 10. She further relied on the judgment of…

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CIT v. Sitaldas Tirathdas (41 ITR 367) — Cited in 146 Judgments | BharatTax