CIT v. Soorajmull Nagarmull

129 ITR 169High Court1981#2087 most cited

What is CIT v. Soorajmull Nagarmull authority for?

Losses from foreign exchange forward contracts, when incidental to an assessee's regular business and undertaken to safeguard business interests, are treated as business losses and not speculative losses under section 43(5).

55

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Soorajmull Nagarmull · 129 ITR 169 · section 43(5) · foreign exchange loss · forward contracts · speculation loss · business loss · incidental to business · hedging contracts · currency fluctuation loss · non-speculative transaction · deductibility of loss

Sections most often in play

Section 43(5)Section 115JBSection 143(3)Section 147Section 148Section 37(1)Section 80IC

Issues it is cited on

section 43(5)speculation lossspeculative transactionsection 14a(1)section 40(a)(ii)corporate guaranteebusiness expediencybusiness connectionsection 40(a)(i)interest u/s 234bsection 43section 2(24)(x)

Judgments citing CIT v. Soorajmull Nagarmull

HCL TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5465/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

….); affirmed in PCIT vs Emmsons International Ltd: [2022] ITA 318/2022 (Del); Revenue's SLP dismissed in PCIT vs Emmsons International Ltd: SLP (Civil) Diary No.49827/2023 (SC)  Pankaj Oil Mills vs CIT: [1978] 115 ITR 824 (Guj)  CIT vs Soorajmull Nagarmull: 129 ITR 169 (Cal)  CIT vs Badridas Gauridu (P) Ltd: 261 ITR 256 (Bom) 157 ITA Nos.- 5624/del/2010 & 5465/Del/2011 HCL Technologies Ltd.  CIT vs Friends and Friends Shipping (P) Ltd: [2013] 217 Taxman 267 (Guj)  CIT vs Panchmahal Steel Ltd: (2013] 215 Taxman 140 (Guj)  CIT vs D Chetan & Co: [2017] 390 ITR 36 (Bom)  DCIT vs Bank of Bahrain and Kuwait: 13…

HCL TECHNOLOGIES LTD,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5624/DEL/2010[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

….); affirmed in PCIT vs Emmsons International Ltd: [2022] ITA 318/2022 (Del); Revenue's SLP dismissed in PCIT vs Emmsons International Ltd: SLP (Civil) Diary No.49827/2023 (SC)  Pankaj Oil Mills vs CIT: [1978] 115 ITR 824 (Guj)  CIT vs Soorajmull Nagarmull: 129 ITR 169 (Cal)  CIT vs Badridas Gauridu (P) Ltd: 261 ITR 256 (Bom) 157 ITA Nos.- 5624/del/2010 & 5465/Del/2011 HCL Technologies Ltd.  CIT vs Friends and Friends Shipping (P) Ltd: [2013] 217 Taxman 267 (Guj)  CIT vs Panchmahal Steel Ltd: (2013] 215 Taxman 140 (Guj)  CIT vs D Chetan & Co: [2017] 390 ITR 36 (Bom)  DCIT vs Bank of Bahrain and Kuwait: 13…

DY COMMISSIONER OF INCOME TAX- 2(1)(1) MUMBAI, MUMBAI vs. FOODS AND INNS LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 5657/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18
For Appellant: \nMs. N.V.Kulkarni,ARFor Respondent: \nMs. Kavitha Kaushik,(Sr. DR)
Section 115JSection 143(3)Section 43(5)

…sessee was entitled to\nclaim deduction in respect of Rs.13.50 lakhs as a business loss. This\nmatter is squarely covered by the judgment of the Calcutta High Court.\nwith which we agree, in the case of CIT v. Soorajmull\nNagarmull (1981)22 CTR Cal) 8: (1981) 129 ITR 169 (Cal)”.\n\n5.3.5 Taking into account the facts and circumstances of the case as\ndiscussed above and the judicial pronouncement referred to (supra),\nwe are of the considered view that the orders of the learned CIT (A) for\n assessment years 2009-10 and 2010-11 holding that foreign exchange\nlosses of 16,72,65,011/- and 6,53,06,057/- for assessme…

DCIT, NEW DELHI vs. M/S FIEM INDUSTRIES LTD.,, NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 3696/DEL/2015[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganeshdcit, Vs. M/S. Fiem Industries Ltd, Circle-9(1), D-34, Dsidc Packaging New Delhi Complex, Kirti Nagr, New Delhi-110015 (Appellant) (Respondent) Pan: Aaacf1034E Assessee By : Shri Shailesh Gupta, Ca Revenue By: Ms. Namita Khurana, Cit-Dr (On Rotational Duty) Date Of Hearing 13/07/2025 Date Of Pronouncement 08/10/2025

For Appellant: Shri Shailesh Gupta, CAFor Respondent: Ms. Namita Khurana, CIT-DR
Section 143(3)Section 43(5)Section 80I

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER DCIT, Vs. M/s. Fiem Industries Ltd, Circle-9(1), D-34, DSIDC Packaging New Delhi Complex, Kirti Nagr, New Delhi-110015 (Appellant) (Respondent) PAN: AAACF1034E Assessee by : Shri Shailesh Gupta, CA Revenue by: Ms. Namita Khurana, CIT-DR (on rotational duty) Date of Hearing 13/07/2025 Date of pronouncement 08/10/2025 O R D E R PER M. BALAGANESH, A. M.: The appeal in ITA No.3696/Del/2015 for AY 2011-12, arises out of the ld. 1. Commissioner of Income Tax (Appeals)-3, New Del…

DCIT, NEW DELHI vs. M/S. J.K. TECHNOSOFT LTD., NEW DELHI

In the result, the Appeal of the Revenue in ITA No

ITA 6160/DEL/2016[2009-10]Status: DisposedITAT Delhi30 Apr 2024AY 2009-10

Bench: Sh. Pradip Kumar Kedia & Sh. Yogesh Kumar U.S.Dcit Vs. J. K. Techno Soft Ltd. Circle 13(2) A-2, Shopping Complex, C. R. Building Masjid Moth, Greater New Delhi Kailsah Part-Ii New Delhi Pan: Aaacj0381L Appellant Respondent Assessee By Shri Neeraj Jain, Adv & Sh. Himanshu Goel, Ca Revenue By Shri Rajesh Mahajan, Sr. Dr Date Of Hearing 18/04/2024 Date Of Pronouncement 30/04/2024 Order

Section 115J

…Delhi, cannot be treated as "commodity." Therefore, respectfully following the decision of Hon'ble ITAT Delhi in the case of Munjal Showa Ltd. vs. DCIT 94 TTJ 227 and also the decision of Hon'ble Calcutta High Court in the case of CIT vs. Soorajmull Nagarmull 129 ITR 169 and other case laws as mentioned therein, which is applicable in the case of appellant, the addition so made by the appellant treating the same as speculative in nature is not tenable and deserves to be deleted accordingly. The assessee gets a relief of Rs. 4,18,22,913/-. This Ground of appeal is allowed accordingly.” 13. The assessee is not a d…

M/S GIMPEX PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

Appeals stands dismissed

ITA 77/CHNY/2022[2012-13]Status: DisposedITAT Chennai09 Aug 2023AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri D. Anand (Advocate)-Ld. ARFor Respondent: Dr. R. Mohan Reddy,(CIT) –Ld. DR
Section 143Section 43(5)Section 43(5)(a)

…The assessee therein booked foreign exchange contracts, which were held to be only incidental to the assessee's regular course of business.” The Bombay High Court relied on the decision of the Calcutta High Court in the case of CIT Vs.Sooraj Mull Nagarmull ( 129 ITR 169). 7.1.5 The facts in the assessee's case are similar as decided by the jurisdictional Madras High court, Bombay and Calcutta High courts referred supra. Respectfully following the above decisions, I hold that the loss on forward contracts of Rs.10,83,04.811/ - cannot be considered as speculation loss within the meaning of section 43(5) but a busi…

DCIT,CENTRAL CIRCLE 1(2), CHENNAI vs. M/S.GIMPEX LIMITED , CHENNAI

Appeals stands dismissed

ITA 176/CHNY/2022[2012-13]Status: DisposedITAT Chennai09 Aug 2023AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri D. Anand (Advocate)-Ld. ARFor Respondent: Dr. R. Mohan Reddy,(CIT) –Ld. DR
Section 143Section 43(5)Section 43(5)(a)

…The assessee therein booked foreign exchange contracts, which were held to be only incidental to the assessee's regular course of business.” The Bombay High Court relied on the decision of the Calcutta High Court in the case of CIT Vs.Sooraj Mull Nagarmull ( 129 ITR 169). 7.1.5 The facts in the assessee's case are similar as decided by the jurisdictional Madras High court, Bombay and Calcutta High courts referred supra. Respectfully following the above decisions, I hold that the loss on forward contracts of Rs.10,83,04.811/ - cannot be considered as speculation loss within the meaning of section 43(5) but a busi…

DEPUTY COMMISSSIONER OF INCOME TAX, CIRCLE -1,, AURANGABAD vs. ENDURANCE TECHNOLOGIES PVT. LTD,, AURANGABAD

Appeals are dismissed in above terms

ITA 1694/PUN/2017[2012-13]Status: DisposedITAT Pune15 Jul 2022AY 2012-13

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

For Appellant: Shri Nikhil Pathak & Abhay A. AvchatFor Respondent: Shri S. P. Walimbe
Section 143(3)Section 14ASection 154Section 43(5)Section 73(4)

…s failed. In the circumstances, the assessee was entitled to claim deduction in respect of payment made on account of cancellation of forward booking of foreign exchange with banks as a business loss. - CIT vs. Soorjmui Nagarmull (1981) 22 CTR (Cal) 8 : 1981) 129 ITR 169 (Cal concurred with." In view of the above facts and discussion and respectfully following the ratio laid down by the above mentioned decisions, I am of the considered view that the A.O. is not justified in making addition of Rs.9,38,05,174/- on account of disallowance of loss in respect of settlement of derivative trade contracts relating to imp…

DEPUTU COMMISSIONER OF INCOME-TAX vs. ENDURANCE TECHNOLOGIES PVT. LTD.,, AURANGABAD

Appeals are dismissed in above terms

ITA 958/PUN/2016[2011-12]Status: DisposedITAT Pune15 Jul 2022AY 2011-12

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

For Appellant: Shri Nikhil Pathak & Abhay A. AvchatFor Respondent: Shri S. P. Walimbe
Section 143(3)Section 14ASection 154Section 43(5)Section 73(4)

…s failed. In the circumstances, the assessee was entitled to claim deduction in respect of payment made on account of cancellation of forward booking of foreign exchange with banks as a business loss. - CIT vs. Soorjmui Nagarmull (1981) 22 CTR (Cal) 8 : 1981) 129 ITR 169 (Cal concurred with." In view of the above facts and discussion and respectfully following the ratio laid down by the above mentioned decisions, I am of the considered view that the A.O. is not justified in making addition of Rs.9,38,05,174/- on account of disallowance of loss in respect of settlement of derivative trade contracts relating to imp…

ASSISTANT COMMISSIONER OF INCOME-TAX vs. ENDURANCE TECHNOLOGIES PVT. LTD.,, AURANGABAD

Appeals are dismissed in above terms

ITA 989/PUN/2015[2010-11]Status: DisposedITAT Pune15 Jul 2022AY 2010-11

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

For Appellant: Shri Nikhil Pathak & Abhay A. AvchatFor Respondent: Shri S. P. Walimbe
Section 143(3)Section 14ASection 154Section 43(5)Section 73(4)

…s failed. In the circumstances, the assessee was entitled to claim deduction in respect of payment made on account of cancellation of forward booking of foreign exchange with banks as a business loss. - CIT vs. Soorjmui Nagarmull (1981) 22 CTR (Cal) 8 : 1981) 129 ITR 169 (Cal concurred with." In view of the above facts and discussion and respectfully following the ratio laid down by the above mentioned decisions, I am of the considered view that the A.O. is not justified in making addition of Rs.9,38,05,174/- on account of disallowance of loss in respect of settlement of derivative trade contracts relating to imp…

DCIT CIRCLE-2 (1)(2), MUMBAI vs. M/S FOODS AND INNS LTD., MUMBAI

In the result, appeals filed by the Revenue are dismissed and cross objections filed by the assessee is allowed for statistical purpose

ITA 6862/MUM/2019[2015-16]Status: DisposedITAT Mumbai21 Feb 2022AY 2015-16

Bench: Shri Laliet Kumar, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nitin KulkarniFor Respondent: Shri Achal Sharma
Section 14ASection 40Section 43(5)

…e assessee was entitled to claim deduction in respect of Rs. 13.50 lakhs as a business loss. This matter is squarely covered by the judgment of the Calcutta High Court. with which we agree, in the case of CIT v. SoorajmullNagarmull (1981)22 CTR Cal) 8: (1981) 129 ITR 169 (Cal)". 5.3.5 Taking into account the facts and circumstances of the case as discussed above and the judicial pronouncement referred to (supra), we are of the considered view that the orders of the learned CIT (A) for assessment years 2009-10 and 2010-11 holding that foreign exchange losses of 16,72,65,011/- and 6,53,06,057/- for assessment year'…

DY CIT CIRCLE-2 (1)(2), MUMBAI vs. M/S FOODS AND INNS LTD., MUMBAI

In the result, appeals filed by the Revenue are dismissed and cross objections filed by the assessee is allowed for statistical purpose

ITA 6860/MUM/2019[2014-15]Status: DisposedITAT Mumbai21 Feb 2022AY 2014-15

Bench: Shri Laliet Kumar, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nitin KulkarniFor Respondent: Shri Achal Sharma
Section 14ASection 40Section 43(5)

…e assessee was entitled to claim deduction in respect of Rs. 13.50 lakhs as a business loss. This matter is squarely covered by the judgment of the Calcutta High Court. with which we agree, in the case of CIT v. SoorajmullNagarmull (1981)22 CTR Cal) 8: (1981) 129 ITR 169 (Cal)". 5.3.5 Taking into account the facts and circumstances of the case as discussed above and the judicial pronouncement referred to (supra), we are of the considered view that the orders of the learned CIT (A) for assessment years 2009-10 and 2010-11 holding that foreign exchange losses of 16,72,65,011/- and 6,53,06,057/- for assessment year'…

DY CIT CIRCLE-2 (1)(2), MUMBAI vs. M/S FOODS AND INNS LTD., MUMBAI

In the result, appeals filed by the Revenue are dismissed and cross objections filed by the assessee is allowed for statistical purpose

ITA 6859/MUM/2019[2013-14]Status: DisposedITAT Mumbai21 Feb 2022AY 2013-14

Bench: Shri Laliet Kumar, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nitin KulkarniFor Respondent: Shri Achal Sharma
Section 14ASection 40Section 43(5)

…e assessee was entitled to claim deduction in respect of Rs. 13.50 lakhs as a business loss. This matter is squarely covered by the judgment of the Calcutta High Court. with which we agree, in the case of CIT v. SoorajmullNagarmull (1981)22 CTR Cal) 8: (1981) 129 ITR 169 (Cal)". 5.3.5 Taking into account the facts and circumstances of the case as discussed above and the judicial pronouncement referred to (supra), we are of the considered view that the orders of the learned CIT (A) for assessment years 2009-10 and 2010-11 holding that foreign exchange losses of 16,72,65,011/- and 6,53,06,057/- for assessment year'…

DY CIT, CC--1(2), MUMBAI vs. M/S MAHENDRA BROTHERS EXPORTS P. LTD., MUMBAI

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

ITA 127/MUM/2021[2010-11]Status: DisposedITAT Mumbai29 Nov 2021AY 2010-11
Section 143(3)

…ntal to the assessee's regular course of the business. While M/s. Mahendra Brothers Exports Pvt. Ltd., coming to this conclusion, the Hon'ble High Court relied upon the decision of Hon'ble Calcutta High Court in the case of CIT v. Soorajmull Nagarmull [1981] 129 ITR 169/5 Taxman 289. That apart, Hon'ble Gujarat High Court in the case of Friends and Friends Shipping (P.) Ltd. (supra) came to the same conclusion and finding. ITAT Mumbai Bench in the case of London Star Diamond Co. (I) (P.) Ltd. (supra) had also held and relied upon aforesaid decisions and held that, if the assessee is not a dealer in foreign excha…

DCIT CENTRAL CIRCLE -II, GURGAON vs. ORIENT CRAFT LTD., NEW DELHI

ITA 5037/DEL/2019[2013-14]Status: DisposedITAT Delhi24 Sept 2021AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Ms. Pramita M. Biswas, CIT-D.R
Section 14ASection 14A(1)Section 43(5)

…ection 43(5) of the Income Tax Act in this regard. Turnover the assessee is to the tune of Rs. 1157.57 crores which comprises mainly the exports turnover. We have seen the case laws relied upon by Learned counsel for the assessee- CIT vs. Soorajmull Nagarmull 129 ITR 169(Cal), CIT vs. Badridas Gauridu 261 ITR 256 (Bom), Friends and Friends Shipping P Ltd 217 Taxman 267 (Guj) in which it has been held that foreign exchange loss which is incidental to business of export/import is not speculative loss to which we too respectfully rely upon. Therefore, it is held that the impugned loss which is the subject matter of…

ORIENT CRAFT LTD.,NEW DELHI vs. DCIT CENTRAL CIRCLE -II, GURGAON

ITA 3313/DEL/2019[2016-17]Status: DisposedITAT Delhi24 Sept 2021AY 2016-17

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Ms. Pramita M. Biswas, CIT-D.R
Section 14ASection 14A(1)Section 43(5)

…ection 43(5) of the Income Tax Act in this regard. Turnover the assessee is to the tune of Rs. 1157.57 crores which comprises mainly the exports turnover. We have seen the case laws relied upon by Learned counsel for the assessee- CIT vs. Soorajmull Nagarmull 129 ITR 169(Cal), CIT vs. Badridas Gauridu 261 ITR 256 (Bom), Friends and Friends Shipping P Ltd 217 Taxman 267 (Guj) in which it has been held that foreign exchange loss which is incidental to business of export/import is not speculative loss to which we too respectfully rely upon. Therefore, it is held that the impugned loss which is the subject matter of…

ORIENT CRAFT LTD.,NEW DELHI vs. DCIT CENTRAL CIRCLE -II, GURGAON

ITA 3310/DEL/2019[2013-14]Status: DisposedITAT Delhi24 Sept 2021AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Ms. Pramita M. Biswas, CIT-D.R
Section 14ASection 14A(1)Section 43(5)

…ection 43(5) of the Income Tax Act in this regard. Turnover the assessee is to the tune of Rs. 1157.57 crores which comprises mainly the exports turnover. We have seen the case laws relied upon by Learned counsel for the assessee- CIT vs. Soorajmull Nagarmull 129 ITR 169(Cal), CIT vs. Badridas Gauridu 261 ITR 256 (Bom), Friends and Friends Shipping P Ltd 217 Taxman 267 (Guj) in which it has been held that foreign exchange loss which is incidental to business of export/import is not speculative loss to which we too respectfully rely upon. Therefore, it is held that the impugned loss which is the subject matter of…

M/S FISERV INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal filed by the assessee in ITA No

ITA 333/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Sept 2020AY 2012-13

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2012-13]

For Appellant: Shri Sachit Jolly. AdvFor Respondent: Shri Sukesh Kumar Jain, CIT-DR
Section 143(3)

…he circumstances, the assessee was entitled to claim deduction in respect of Rs. 13.50 lakhs as a business loss. This matter is squarely covered by the judgment of the Calcutta High Court, with which we agree, in the case of CIT v. Soorajmull Nagarmull [1981] 129 ITR 169. 4. In the circumstances, there is no merit in the appeal. The appeal fails and the same is dismissed with no order as to costs.” 40. Considering the facts of the case in hand in light of the aforesaid decision of the Hon’ble High Court of Bombay, we direct the Assessing Officer to allow claim of loss of Rs.2.98 crores. This ground is, accord…

ARVIND METALS & MINERALS PRIVATE LIMITED,KOLKATA vs. A.C.I.T, CIRCLE - 4(1), KOLKATA, KOLKATA

In the result, the appeal of the assessee is partly allowed

ITA 434/KOL/2019[2014-15]Status: DisposedITAT Kolkata08 Jul 2020AY 2014-15

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.434/Kol/2019 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Manish Tiwari, FCAFor Respondent: Shri Supriyo Paul, JCIT
Section 143(3)Section 28Section 43(5)Section 43B

…ition of speculative transaction. Hence the actions of Id AO in considering the loss on hedging foreign currency exposure as speculative is not justified. For that we rely on the judgment of Hon’ble Calcutta High Court in case of CIT vs. Soarajmull Nagarmull [129 ITR 169] wherein the court observed that "where assessee enters into forward contracts in foreign exchange in order to cover the loss arising due to difference in foreign exchange rate and/or valuation, is not of speculative in nature and was incidental to the assessee's regular course of business. As such it was allowable as a trade loss. In view of the…

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1204/CHNY/2015[2011-12]Status: DisposedITAT Chennai29 Nov 2019AY 2011-12

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

For Appellant: Shri R. Srinivasan, AdvocateFor Respondent: Shri M. Srinivasa Rao, CIT
Section 129Section 143(1)Section 143(2)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी ’ "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी धु"ु" आर.एल रे"ी, "ाियक सद" एवं "ी एस जयरामन, लेखा सद" के सम" Before Shri Duvvuru RL Reddy, Judicial Member & Shri S. Jayaraman, Accountant Member आयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/s. Thiagarajar Mills (P) Ltd., Joint Commissioner of GST Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [PAN: AAACT 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri R. Srinivasan, Advocate ""थ" की ओर से/Res…

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