CIT v. Strawboard Manufacturing Company Limited

177 ITR 431Supreme Court of India1989#5217 most cited

What is CIT v. Strawboard Manufacturing Company Limited authority for?

Provisions in a taxing statute that provide for concessional rates of tax to encourage industrial activity should be construed liberally.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

CIT v. Strawboard Manufacturing Company Limited · 177 ITR 431 · concessional tax rate · liberal construction · industrial activity · taxing statute · encouragement of industry

Sections most often in play

Section 143(1)Section 143(3)Section 263Section 10B(8)Section 115BAASection 115BBESection 133(6)Section 133A

Issues it is cited on

section 69drevision u/s 263section 271aabsurvey under section 133asection 69bsection 271aasection 271asection 80ierroneous and prejudicialsection 274chief commissionersection 115b

Judgments citing CIT v. Strawboard Manufacturing Company Limited

JABALPUR ENTERTAINMENT COMPLEXES PRIVATE LIMITED,JABALPUR vs. DCIT, CPC, BENGALURU & DCIT, CIRCLE 2(1), JABALPUR, JABALPUR

In the result, the appeal is allowed for statistical purposes

ITA 184/JAB/2024[2023-24]Status: DisposedITAT Jabalpur28 Aug 2025AY 2023-24

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Apoorva Rajesh Mehta, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 115BSection 143(1)Section 250

…rectify this error. In its submissions before the ld. JCIT(A), the assessee has cited the decision of the Hon’ble Supreme Court in the case of CIT vs. Straw Board Manufacturing Company Limited 6 A.Y. 2023-24 Jabalpur Entertainment Complexes P. Ltd. (1989) 177 ITR 431 (SC), wherein the Hon’ble Supreme Court held that the law providing for concession for tax purposes, to encourage industrial activity, should be liberally construed. The question before the Court in that case was whether Straw Board could be said to fall within the expression, ‘paper and pulp’ mentioned in the schedule relevant to the respective…

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 413/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Feb 2025AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Shri Abhishek Pal Garg, DR
Section 143(1)Section 143(2)Section 147Section 148Section 263Section 801CSection 80I

…CTT [1989] 177 ITR 418 (SC) "The object of section 81(1) was to encourage and promote the growth of co- operative societles, and, consequently, a liberal construction must be given to the operation of that provision." c) CIT v. Strawboard Mfg. Co. Ltd. [1989] 177 ITR 431 (SC) "It is necessary to remember that when a provision is made in the context of a law providing for concessional rates of tax for the purpose of encouraging an Industrial activity, a liberal construction should be put upon the language of the statute." 21. Further, reliance is placed on following judicial precedents wherein the courts laid down…

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

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

ITA 688/HYD/2024[2018-19]Status: DisposedITAT Hyderabad11 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 80I

…legislative intent is not to burden the subject to tax so that some specific public purpose is furthered. The Hon'ble Supreme Court referred to the decision in Commissioner of Income-tax v. Straw Board Mfg. Co. Ltd. (1989) Supp 2 SCC 523/[1989] 44 Taxman 189/177 ITR 431 (SC) wherein it was held that in taxing statute, provision for concessional rate of tax should be liberally construed. Decision in Bajaj Tempo Ltd. v. Commissioner of Income-tax (1992) 3 SCC 78/[1992] 62 Taxman 480/196 ITR 188 (SC) was referred to wherein it was held that the provision granting incentive for promoting economic growth and developm…

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

ITA 212/HYD/2024[2017-18]Status: HeardITAT Hyderabad01 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

For Appellant: Shri A. Srinivas, C.AFor Respondent: Shri Srinath Sadanala, Sr.DR
Section 132Section 143(2)Section 143(3)Section 153CSection 801ASection 801A(4)Section 80I

…legislative intent is not to burden the subject to tax so that some specific public purpose is furthered. The Hon'ble Supreme Court referred to the decision in Commissioner of Income-tax v. Straw Board Mfg. Co. Ltd. (1989) Supp 2 SCC 523/[1989] 44 Taxman 189/177 ITR 431 (SC) wherein it was held that in taxing statute, provision for concessional rate of tax should be liberally construed. Decision in Bajaj Tempo Ltd. v. Commissioner of Income-tax (1992) 3 SCC 78/[1992] 62 Taxman 480/196 ITR 188 (SC) was referred to wherein it was held that the provision granting incentive for promoting economic growth and developm…

PRAKASH CHAND SAINI,SIKANDRA vs. PCIT(CENTRAL)JAIPUR, JAIPUR

ITA 479/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Aug 2024AY 2019-20
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Shailendra Sharma, CIT-DR
Section 133ASection 139Section 143(2)Section 143(3)Section 263

…is settled position of law that if there are divergent opinions on an issue, one which is favourable to the assessee shall apply. The following case laws are quoted in support (i) (ii) Vegetable Products 88 ITR 192 (SC) CIT Vs. Straw Board Manufacturing Ltd. 177 ITR 431 (SC) Ground No. 2 – The assessee craves your indulgence to add amend or alter all or any grounds of appeal before or at the time of hearing. Not pressed. The Hon'ble Tribunal is requested to decide the appeal in favour of the assessee by considering the above submission and oblige." 9. In support of the contention raised in the written submission…

LAXMI NARAYAN SAINI,SIKANDRA vs. PCIT(CENTRAL), JAIPUR

ITA 478/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Aug 2024AY 2019-20
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Shailendra Sharma, CIT-DR
Section 133ASection 139Section 143(2)Section 143(3)Section 263

…is settled position of law that if there are divergent opinions on an issue, one which is favourable to the assessee shall apply. The following case laws are quoted in support (i) (ii) Vegetable Products 88 ITR 192 (SC) CIT Vs. Straw Board Manufacturing Ltd. 177 ITR 431 (SC) Ground No. 2 – The assessee craves your indulgence to add amend or alter all or any grounds of appeal before or at the time of hearing. Not pressed. The Hon'ble Tribunal is requested to decide the appeal in favour of the assessee by considering the above submission and oblige." 9. In support of the contention raised in the written submission…

MUKESH KUMAR SAINI,SIKANDARA vs. PCIT(CENTRAL), JAIPUR

In the result, the appeal of the assessee is in ITA no

ITA 477/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Aug 2024AY 2019-20

Bench: or at the time of hearing.” 5. It is seen that the only grievance raised by the assessee is that PCIT erred in holding the order of the assessment as erroneous in so far as prejudicial to the interest of the revenue. Brief facts related to the issue are culled out are that in this case a Survey action u/s 133A of the Act was carried out on 26.02.2019 at the business premises of the assessee firm M/s Nirankar Tiles and Sanitory 4

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Shailendra Sharma, CIT-DR
Section 133ASection 139Section 143(2)Section 143(3)Section 263

…is settled position of law that if there are divergent opinions on an issue, one which is favourable to the assessee shall apply. The following case laws are quoted in support (i) Vegetable Products 88 ITR 192 (SC) (ii) CIT Vs. Straw Board Manufacturing Ltd. 177 ITR 431 (SC) Ground No. 2 – The assessee craves your indulgence to add amend or alter all or any grounds of appeal before or at the time of hearing. Not pressed. The Hon'ble Tribunal is requested to decide the appeal in favour of the assessee by considering the above submission and oblige.” 9. In support of the contention raised in the written submissio…

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD vs. VIJAY M. MISTRY CONSTRUCTION PVT. LTD.,, AHMEDABAD

In the result, assessee’s appeals are allowed and Revenue’s appeal is dismissed

ITA 1481/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad23 Dec 2022AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 2938/Ahd/2011, 2939/Ahd/2011, 2286/Ahd/2012, 268/Ahd/2015, 269/Ahd/2015, 502/Ahd/2017, 1145/Ahd/2019 & 1468/Ahd/2019 ("नधा"रण वष" / Assessment Year : 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 & 2016-17) Address In A.Ys. 2007-08, बनाम/ 2008-09 & 2009-10 Vs. Vijay M. Mistry Cons. P. Asst. Commissioner Of Ltd. Income Tax Circle–8, B-209, 2Nd Floor, 501, Swagat, C. G. Road, Panjara Pole, Pratyakshkar Ellisbridge, Ahmedabad – & Bhavan, Ambawadi, 380006 (Gujarat) Ahmedabad Address In A.Ys. 2010-11 Joint Commissioner Of Income Tax Vijay M. Mistry Cons. P. Range-8, B-209, 2Nd Floor, Ltd. Panjara Pole, Pratyakshkar “Mistry House”, 9, Preyas Bhavan, Ambawadi, Society, Opp. Gulbai Ahmedabad Tekra Police Choki & Ambawadi, Ahmedabad – 380015 Address In A.Ys. 2011-12 Vijay M. Mistry Cons. P. Dy. Commissioner Of Ltd. Income Tax (Osd) & Circle–8, B-209, 2Nd Floor, “Mistry House”, 9, Preyas Panjara Pole, Pratyakshkar Society, Opp. Gulbai Bhavan, Ambawadi, Tekra Police Choki, Ahmedabad Ambawadi, Ahmedabad –

Section 143(3)Section 271(1)(c)Section 36(1)(va)Section 80I

…d Vs CIT 239 ITR 775(SC) 3. Kerala State Industrial Development Corpn Ltd Vs CIT 259 ITR 51(SC) 4. Bajaj Tempo Ltd Vs CIT 196 ITR 188(SC) 5. Gujarat Industrial Development Corporation and Others Vs CIT 227 ITR 414(SC) 6. CIT Vs Strawboard Manufacturing Co Ltd 177 ITR 431(SC) However, such plea taken by the assessee was not found to be acceptable and, thus, the assessment under Section 143(3) of the Act was completed on 23.12.2009 disallowing the claim made under Section 80IA of the Act, which was further confirmed by the First Appellate Authority. Hence, the instant appeal before us. ITA Nos. 2938/Ahd/2011 & 8…

VIJAY M.MISTRY CONSTRUCTION PVT.LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD

In the result, assessee’s appeals are allowed and Revenue’s appeal is dismissed

ITA 2938/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad23 Dec 2022AY 2007-08

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 2938/Ahd/2011, 2939/Ahd/2011, 2286/Ahd/2012, 268/Ahd/2015, 269/Ahd/2015, 502/Ahd/2017, 1145/Ahd/2019 & 1468/Ahd/2019 ("नधा"रण वष" / Assessment Year : 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 & 2016-17) Address In A.Ys. 2007-08, बनाम/ 2008-09 & 2009-10 Vs. Vijay M. Mistry Cons. P. Asst. Commissioner Of Ltd. Income Tax Circle–8, B-209, 2Nd Floor, 501, Swagat, C. G. Road, Panjara Pole, Pratyakshkar Ellisbridge, Ahmedabad – & Bhavan, Ambawadi, 380006 (Gujarat) Ahmedabad Address In A.Ys. 2010-11 Joint Commissioner Of Income Tax Vijay M. Mistry Cons. P. Range-8, B-209, 2Nd Floor, Ltd. Panjara Pole, Pratyakshkar “Mistry House”, 9, Preyas Bhavan, Ambawadi, Society, Opp. Gulbai Ahmedabad Tekra Police Choki & Ambawadi, Ahmedabad – 380015 Address In A.Ys. 2011-12 Vijay M. Mistry Cons. P. Dy. Commissioner Of Ltd. Income Tax (Osd) & Circle–8, B-209, 2Nd Floor, “Mistry House”, 9, Preyas Panjara Pole, Pratyakshkar Society, Opp. Gulbai Bhavan, Ambawadi, Tekra Police Choki, Ahmedabad Ambawadi, Ahmedabad –

Section 143(3)Section 271(1)(c)Section 36(1)(va)Section 80I

…d Vs CIT 239 ITR 775(SC) 3. Kerala State Industrial Development Corpn Ltd Vs CIT 259 ITR 51(SC) 4. Bajaj Tempo Ltd Vs CIT 196 ITR 188(SC) 5. Gujarat Industrial Development Corporation and Others Vs CIT 227 ITR 414(SC) 6. CIT Vs Strawboard Manufacturing Co Ltd 177 ITR 431(SC) However, such plea taken by the assessee was not found to be acceptable and, thus, the assessment under Section 143(3) of the Act was completed on 23.12.2009 disallowing the claim made under Section 80IA of the Act, which was further confirmed by the First Appellate Authority. Hence, the instant appeal before us. ITA Nos. 2938/Ahd/2011 & 8…

SHRI D. RAVIKUMAR,,CHENNAI vs. ACIT, NCC-14,, CHENNAI

In the result, the orders of the Assessing Officer and Commissioner of Income Tax (Appeals) and Income Tax

ITA 3314/CHNY/2019[2007-08]Status: DisposedITAT Chennai27 Jul 2022AY 2007-08

Bench: Shri V. Durga Rao & Shri G. Manjunatha

For Appellant: Mr. P.Sajit Kumar, JCITFor Respondent: 14.07.2022
Section 54F

…ttled legal proposition that a provision in a taxing statute providing incentive for promoting growth and development has to be construed liberally so as to advance the object of the section and not to frustrate it. See: CIT v. Strawboard Mig. Co. Ltd. (1989) 177 ITR 431 (SC) and Bajaj Tempo Ltd. (Supra) A bench of this court in Sambandam Uday Kumar Supra while interpreting section 54F of the Act has held that provisions of section 54F is a beneficial provision for promoting construction of residential houses and has to be construed liberally. Kerala, Delhi, Allahabad, Calcutta and Hyderabad High Courts have take…

YASH SUNEJA,NEW DELHI vs. ACIT, CIRCLE-42(1), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 7947/DEL/2018[2015-16]Status: DisposedITAT Delhi04 Jan 2022AY 2015-16

Bench: Shri R.K. Panda & Shri K.Narasimha Chary

Section 143(3)Section 54F

…d legal proposition that a provision in a taxing statute providing incentive for promoting growth and development has to be construed liberally so as to advance the object of the Section and not to frustrate it. [SEE:'CIT VS. STRAWBOARD MFg. CO. LTD.', (1989) 177 ITR 431 (SC) AND 'BAJAJ TEMPO LTD. SUPRA]. A bench of this court in SAMBANDAM UDAY KUMAR SUPRA while interpreting Section 54F of the Act has held that provisions of Section 54F is a beneficial provision for promoting construction of residential houses and has to be construed liberally. Kerala, Delhi, Allahabad, Calcutta and Hyderabad High Courts have tak…

NUCLEAR POWER CORPORATION OF INDIA LTD,MUMBAI vs. CIT LTU, MUMBAI

In the result, this appeal by the assessee stands allowed for statistical purpose

ITA 4815/MUM/2018[2014-15]Status: DisposedITAT Mumbai01 Sept 2021AY 2014-15
Section 115JSection 143(3)Section 263Section 271Section 32Section 32(1)Section 32A

…rt in the case of Commissioner Trade Tax vs. DSM Group of Industries, reported in 2005 UPTC page 121. Similar views have been expressed in the following Supreme Court decisions: • Kamlapat v. CIT (73 ITR 702) (SC); • CIT v. Strawboard Manufacturing Co. Ltd. (177 ITR 431)(SC) at page 434, and • CIT v. South Arcot District Co-operative Marketing Society Ltd. (176 ITR 117) (SC) at page 119. The Company has to also submit that section 32AC is a beneficial provision and accordingly, where two views possible on reading of the said section, the view beneficial to the taxpayer should be adopted. As acquisition and insta…

INCOME-TAX OFFICER, WARD - 2(3),, PUNE vs. LAXMAN SOPANRAO NIMHAN,, PUNE

In the result, the appeal of Revenue is dismissed

ITA 1870/PUN/2017[2012-13]Status: DisposedITAT Pune23 Sept 2020AY 2012-13

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: N O N EFor Respondent: Shri Navin Gupta
Section 143(2)Section 143(3)Section 80ISection 80l

…estriction on it too has to be construed so as to advance the objective of the section and not to frustrate it. Reference may further be made to the cases of CIT Vs Gwalior Rayon Silk Mfg Co. Ltd (1992) 196 ITR 149 (SC) and CIT Vs Straw Board Mfg. Ltd. (1989) 177 ITR 431 (SC) wherein, the Hon'ble Supreme Court held that it is the settled law that the expression used in a taxing statute would ordinarily be understood in the sense in which it is harmonious with the object of the statute to effectuate the legislative intention, which is to be interpreted beneficially to the assessee. In another case the Hon’ble Pune…

SHRI. NAVIN JOLLY vs. THE INCOME-TAX OFFICER

In the result, appeal is allowed

ITA/320/2011HC Karnataka18 Jun 2020

Bench: ALOK ARADHE,M.NAGAPRASANNA

Section 143(2)Section 260Section 260ASection 54FSection 54F(1)

…al proposition that a provision in a taxing statute providing incentive for promoting growth and development has to be construed liberally so as to advance the object of the Section and not to frustrate it. [SEE:’CIT VS. STRAWBOARD MFg. CO. LTD.’, (1989) 177 ITR 431 (SC) AND ‘BAJAJ TEMPO LTD. SUPRA]. A bench of this court in 15 SAMBANDAM UDAY KUMAR SUPRA while interpreting Section 54F of the Act has held that provisions of Section 54F is a beneficial provision for promoting construction of residential houses and has to be construed liberally. Kerala, Delhi, Allahabad, Calcutta and Hyderaba…

ACIT, CIR-32, KOLKATA, KOLKATA vs. JITENDRA SETH, KOLKATA

Appeal is dismissed

ITA 1420/KOL/2016[2012-13]Status: DisposedITAT Kolkata27 Jul 2018AY 2012-13

Bench: Shri J.Sudhakar Reddy & Shri S.S.Godaraassessment Year:2012-13 Acit, Circle-32, Jitendra Seth बनाम 10B, Middleton Row, 87, Karnani Estate, 209, / 2Nd Floor, Kolkata-71 V/S. A.J.C. Bose Road, Kolkata-700 017 [Pan No.Ajhs 9552 M] .. अपीलाथ" /Appellant ""यथ" /Respondent Shri Saurabh Kumar, Addl. Cit-Sr-Dr अपीलाथ" क" ओर से/By Appellant Shri Miraj D Shah, Ar ""यथ" क" ओर से/By Respondent 04-07-2018 सुनवाई क" तार"ख/Date Of Hearing 27-07-2018 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Revenue’S Appeal For Assessment Year 2012-13 Challenges Commissioner Of Income Tax (Appeals)-9, Kolkata’S Order Dated 31.03.2016 Passed In Case No. 749/Cit(A)-9/Cir-32/2014-15/Kol, Reversing Assessing Officer’S Action Disallowing Assessee’S Commission Paid Of ₹51,56,694/- As Well As Partly Restricting Section 54F Deduction Disallowance To ₹42,39,181/- Out Of ₹56,52,242/-; Respectively, Involving Proceedings U/S. 143(3) Of The Income Tax Act, 1961; In Short ‘The Act’ Heard Both The Parties. Case File Perused.

Section 133(6)Section 143(3)Section 44ASection 54F

…atic approach should be adopted so that the object of the introduction/insertion of a particular provision could be achieved. [Similar views have been expressed in Juggilal Kamlapat v CIT [1969] 73 ITR 702 (SC); CIT v. Strawboard Manufacturing Co. Ltd. [1989] 177 ITR 431 (SC) at page 434 and CIT v. South Arcot District Co-operative Marketing Society Ltd. 176 ITR 117 (SC) at page 119]. The Supreme Court in CCE versus Favourite Industries, (2012) 7 SCC 153 has observed:- ’21 Furthermore, this Court in Associated Cement Companies Ltd. v. State of Bihar [(2004) 7 SCC 642], while explaining the nature of the exemption…

CHOICE BUILDESTATE PRIVATE LIMITED,JAIPUR vs. ITO, JAIPUR

In the result, ground no.2 taken by the assessee company is allowed

ITA 431/JPR/2016[2007-08]Status: DisposedITAT Jaipur28 Mar 2018AY 2007-08
For Appellant: Shri S. L. Poddar &For Respondent: Shri Ran Singh (Addl. CIT)
Section 132(4)Section 139(2)Section 143(1)Section 143(3)Section 147Section 148Section 68

…w that if there are two opinions on the same issue then one favourable to the assessee has to M/s Choice Buildestate Pvt. Ltd., Jaipur vs. ITO, Jaipur be followed as held in CIT vs. Vegetable Products (SC) 88 ITR 192 and CIT Strawboard Manufacturing Ltd. (sc) 177 ITR 431. 7. In view of the aforesaid facts, it is submitted that the Learned Assessing officer and the Learned CIT(A) have acted by placing uncalled for and blind reliance on the report of the Investigation Wing Mumbai disregarding the documentary evidences furnished by the assessee. They have also not been able to controvert a number of decisions on the…

DCIT CEN CIR 4(4) CEN RG 4, MUMBAI vs. NAHAR ENTERPRISES, MUMBAI

ITA 3574/MUM/2015[2012-13]Status: DisposedITAT Mumbai07 Apr 2017AY 2012-13

Bench: Shri C.N. Prasad, Jm & Shri Rajesh Kumar, Am

For Appellant: Sarvshree Vimal Punmiya, KetanFor Respondent: Shri Anand Mohan
Section 143(3)Section 801B(10)Section 80I

…f the expressed words do not apply. " 22. Notwithstanding the aforesaid. the courts have also held that incentive provisions contained in a taxing statute are given a more liberal construction. In case of CIT v. Strawboard Manufacturing Company Limited [1989) 177 ITR 431 (SC) the Hon'ble Supreme Court has held that the law providing for concession for tax purposes to encourage industrial activity should be liberally construed. So also in the case of Bajaj Tempo Limited V. CIT [AIR 1992 SC 1622J the Hon'ble Supreme Court has accepted the principle laid down in the case of Straw board Manufacturing (supra). 23. As…

DCIT CEN CIR 4(4) CEN RG 4, MUMBAI vs. NAHAR ENTERPRISES, MUMBAI

ITA 3573/MUM/2015[2011-12]Status: DisposedITAT Mumbai07 Apr 2017AY 2011-12

Bench: Shri C.N. Prasad, Jm & Shri Rajesh Kumar, Am

For Appellant: Sarvshree Vimal Punmiya, KetanFor Respondent: Shri Anand Mohan
Section 143(3)Section 801B(10)Section 80I

…f the expressed words do not apply. " 22. Notwithstanding the aforesaid. the courts have also held that incentive provisions contained in a taxing statute are given a more liberal construction. In case of CIT v. Strawboard Manufacturing Company Limited [1989) 177 ITR 431 (SC) the Hon'ble Supreme Court has held that the law providing for concession for tax purposes to encourage industrial activity should be liberally construed. So also in the case of Bajaj Tempo Limited V. CIT [AIR 1992 SC 1622J the Hon'ble Supreme Court has accepted the principle laid down in the case of Straw board Manufacturing (supra). 23. As…

DCIT CEN CIR 4(4) CEN RG 4, MUMBAI vs. NAHAR ENTERPRISES, MUMBAI

ITA 3572/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Apr 2017AY 2010-11

Bench: Shri C.N. Prasad, Jm & Shri Rajesh Kumar, Am

For Appellant: Sarvshree Vimal Punmiya, KetanFor Respondent: Shri Anand Mohan
Section 143(3)Section 801B(10)Section 80I

…f the expressed words do not apply. " 22. Notwithstanding the aforesaid. the courts have also held that incentive provisions contained in a taxing statute are given a more liberal construction. In case of CIT v. Strawboard Manufacturing Company Limited [1989) 177 ITR 431 (SC) the Hon'ble Supreme Court has held that the law providing for concession for tax purposes to encourage industrial activity should be liberally construed. So also in the case of Bajaj Tempo Limited V. CIT [AIR 1992 SC 1622J the Hon'ble Supreme Court has accepted the principle laid down in the case of Straw board Manufacturing (supra). 23. As…

NAHAR ENTERPRISES,MUMBAI vs. DCIT (OSD) CEN RG 7, MUMBAI

ITA 2855/MUM/2015[2012-13]Status: DisposedITAT Mumbai07 Apr 2017AY 2012-13

Bench: Shri C.N. Prasad, Jm & Shri Rajesh Kumar, Am

For Appellant: Sarvshree Vimal Punmiya, KetanFor Respondent: Shri Anand Mohan
Section 143(3)Section 801B(10)Section 80I

…f the expressed words do not apply. " 22. Notwithstanding the aforesaid. the courts have also held that incentive provisions contained in a taxing statute are given a more liberal construction. In case of CIT v. Strawboard Manufacturing Company Limited [1989) 177 ITR 431 (SC) the Hon'ble Supreme Court has held that the law providing for concession for tax purposes to encourage industrial activity should be liberally construed. So also in the case of Bajaj Tempo Limited V. CIT [AIR 1992 SC 1622J the Hon'ble Supreme Court has accepted the principle laid down in the case of Straw board Manufacturing (supra). 23. As…

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CIT v. Strawboard Manufacturing Company Limited (177 ITR 431) — Cited in 22 Judgments | BharatTax