CIT v. Tara Agencies

292 ITR 444Supreme Court of India2007#1433 most cited

What is CIT v. Tara Agencies authority for?

When interpreting fiscal legislation, courts must adhere strictly to the plain and unambiguous language of the statute, without introducing intendment, equity, or words not present in the text, irrespective of perceived hardship. The legislative intent must be gathered solely from what has been said and not said in the statutory language.

80

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

CIT v. Tara Agencies · 292 ITR 444 · Supreme Court · statutory interpretation · fiscal legislation interpretation · plain language rule · no equity in tax law · legislative intent · literal construction · section 115JB · section 14A · section 80JJAA

Also reported as

162 Taxmann 337

Sections most often in play

Section 115JBSection 37(1)Section 14ASection 2(24)(xviii)Section 36(1)(va)Section 43BSection 80-IESection 80JJAA

Issues it is cited on

section 2(24)(xviii)section 14a disallowancereal income theorysection 80jjasection 80jjaamat credittrade creditorsweighted deductionprohibited by lawtransfer of capital assetindexed cost of acquisitionincome tax settlement commission

Judgments citing CIT v. Tara Agencies

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

Appeal are dismissed

ITA 914/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22
For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…t is also a well-settled proposition that when the language of a\nstatute is plain and unambiguous, the court must give effect to it\nirrespective of any perceived hardship or inequity to the assessee. The\nHon'ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC)\nheld that no intendment or equity has any place in interpreting fiscal\nlegislation. In this case, Hon'ble Supreme Court made the following\nobservations:\n“This intention of the Legislature has to be gathered from the language used in the\nstatute, which means that attention should be paid to what has been said as also to\nwhat has not bee…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

DCIT CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT , BODAKDEV AHMEDABAD

Appeal are dismissed

ITA 848/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21
For Appellant: \nShri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…t is also a well-settled proposition that when the language of a\nstatute is plain and unambiguous, the court must give effect to it\nirrespective of any perceived hardship or inequity to the assessee. The\nHon'ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC)\nheld that no intendment or equity has any place in interpreting fiscal\nlegislation. In this case, Hon'ble Supreme Court made the following\nobservations:\n“This intention of the Legislature has to be gathered from the language used in the\nstatute, which means that attention should be paid to what has been said as also to\nwhat has not bee…

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 847/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…. It is also a well-settled proposition that when the language of a statute is plain and unambiguous, the court must give effect to it irrespective of any perceived hardship or inequity to the assessee. The Hon’ble Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC) held that no intendment or equity has any place in interpreting fiscal ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years–2018-19 & 2020-21 to 2022-23 - 13– legislation. In this case, Hon’ble Supreme Court made the following observations: “This intention of the Legisl…

NUTAN NAGRIK SAHAKARI BANK LIMITED,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

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

ITA 1023/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2020-21
For Appellant: \nShri Bandish Soparkar, ARFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 10(15)Section 143(3)Section 144BSection 14ASection 263Section 28Section 36(1)(viia)

…settled that when the language of the statute is clear, plain,\nand unambiguous, it must be applied as it stands, and no interpretation can\nbe imported to give it a meaning different from what is expressed. The\nHon'ble Supreme Court in CIT v. Tara Agencies (292 ITR 444) has held\nthat where the words of a statute are clear, they must be given effect to\nregardless of consequences. Similarly, in Orissa State Warehousing\nCorporation v. CIT (237 ITR 589), the Court held that the language\nemployed by the Legislature must be given its plain meaning and that\ncourts cannot read something into the provision which is…

VIVEK MEHROTRA,MUMBAI vs. DCIT CC 3(2) , MUMBAI

In the result, appeal filed by the Revenue is partly allowed for statistical purpose

ITA 2359/MUM/2018[2015-16]Status: DisposedITAT Mumbai30 Jan 2023AY 2015-16

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bleshri Vivek Mehrotra V. Dcit – Central Circle – 3(2) Office No. 116, Churchgate Chamber Room No. 1913, 19Th Floor Above Greater Bank, 5 New Marine Lines Air India Building, Nariman Point Mumbai -400020 Mumbai – 400 021 Pan: Aahpm4127B (Appellant) (Respondent) Dcit – Central Circle – 3(2) V. Shri Vivek Mehrotra Central Range - 3 Office No. 116, Churchgate Chamber Above Greater Bank, 5 New Marine Lines Room No. 1913, 19Th Floor Mumbai -400020 Air India Building, Nariman Point Mumbai – 400 021 Pan: Aahpm4127B (Appellant) (Respondent)

Section 132Section 153ASection 292CSection 69ASection 6A

…ction. It held that by undertaking the process of bottling, the LPG becomes capable of being marketed as a domestic kitchen fuel and thereby making it a viable commercial product. The Hon'ble Supreme Court also distinguished its own decision of Tara Agencies (292 ITR 444) wherein the assessee's claim for deduction was not allowed on the ground that blending of different qualities of tea amounted to 'processing of tea' and cannot be equated to a 'manufacturing process', by clarifying that in this case the issue to be adjudicated is whether bottling of LPG into cylinders constitutes "manufacturing" or "production"…

GURUDEV APPARELS,TIRUPPUR vs. DCIT, TIRUPPUR

In the result, the appeal of the Assessee in I

ITA 257/CHNY/2017[2013-14]Status: DisposedITAT Chennai27 May 2022AY 2013-14

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपील सं./I.T.A No.:257/Chny/2017 िनधा"रण वष" /Assessment Year: 2013 - 2014

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. G. Johnson, Addl. CIT
Section 1Section 143(3)Section 194CSection 250(6)Section 40Section 40ASection 40A(3)

…circumstances, 20 per cent, of such expenditure shall be disallowed. In our opinion there is no ambigu lv in the language of section 40A (3) and ‘here fore, relying upon the above referred decision of the hon’ble apex court in the cases of Tam Agencies (2007) 292 ITR 444 nd Anjum M. H. Ghaszvala, we hold that the section is to be interpreted by giving literal meaning to the language used in the section itself. In view of the above, there is no need to look elsewhere for the purpose behind the enactment of Section 40A (3) is not relevant. What is relevant is the enactment itself, i.e. Section 40A (3). The income…

PRINCIPAL COMMISIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. M/S SHALIMAR PELLET FEEDS LIMITED

In the result, the substantial questions of law framed

ITAT/29/2021HC Calcutta04 Apr 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 2Section 260ASection 40A(2)(b)Section 80I

…e to buttress her submission that when there is ambiguity in an exemption provision, the benefit has to go to the revenue. Further, the learned senior standing counsel referred to the decision in the case of Commissioner of Income Tax Vs. Tara Agencies [2007] 292 ITR 444 (SC). It is submitted that the decision in Tara Agencies was not placed before this Court when judgment was rendered in the case of Principal Commissioner of Income-Tax Vs. Sona Vets Pvt. Ltd. [2020] 424 ITR 387 (Cal) which held in favour of the assessee. 6 Firstly, the revenue has not been able to dislodge the factual findings recorded by the…

M/S AMBIKA TRANSPORT CO. vs. INCOME TAX OFFICER,

In the result, both the appeals by the assessee are dismissed

ITA 188/JAB/2013[2003-04]Status: DisposedITAT Jabalpur16 Feb 2022AY 2003-04

Bench: Sh. Sanjay Arora, Hon'Ble

Section 143(3)Section 260ASection 40Section 44A

…w is couched, where is the legislative intent to be found, so that where the law is clear, as it indeed is in the instant case, no other rule of interpretation is required (Ajmera Housing Corporation v. CIT [2010] 326 ITR 642 (SC); CIT v. Tara Agencies [2007] 292 ITR 444 (SC)). Not so doing would be to usurp the legislative function by the courts which is impermissible, as explained in (Padmasundara Rao (Decd) v. State of Tamil Nadu [2002] 255 ITR 147 (SC). Rather, taxing statutes, it is again well-settled, are to be strictly construed. Further still, as explained by the Apex Court in CBI vs. Keshub Mahindra & Ot…

M/S AMBIKA TRANSPORT CO. vs. INCOME TAX OFFICER,

In the result, both the appeals by the assessee are dismissed

ITA 187/JAB/2013[2002-03]Status: DisposedITAT Jabalpur16 Feb 2022AY 2002-03

Bench: Sh. Sanjay Arora, Hon'Ble

Section 143(3)Section 260ASection 40Section 44A

…w is couched, where is the legislative intent to be found, so that where the law is clear, as it indeed is in the instant case, no other rule of interpretation is required (Ajmera Housing Corporation v. CIT [2010] 326 ITR 642 (SC); CIT v. Tara Agencies [2007] 292 ITR 444 (SC)). Not so doing would be to usurp the legislative function by the courts which is impermissible, as explained in (Padmasundara Rao (Decd) v. State of Tamil Nadu [2002] 255 ITR 147 (SC). Rather, taxing statutes, it is again well-settled, are to be strictly construed. Further still, as explained by the Apex Court in CBI vs. Keshub Mahindra & Ot…

NIKHIL MOHINE,PARASIA vs. COMMISSIONER OF INCOME TAX (APPEALS), JABALPUR

In the result, the assessee’s appeals are allowed

ITA 38/JAB/2021[2019-20]Status: DisposedITAT Jabalpur18 Nov 2021AY 2019-20

Bench: Sh. Sanjay Arora, Hon'Ble

Section 139(1)Section 143(1)Section 154Section 2Section 36(1)(va)Section 43B

…s clear, ITA Nos. 37& 38/Jab/2021 (AY 2018-19& 2019-20) Nikhil Mohinev. Dy. CIT/Asst. DIT as it indeed is in the instant case, no other rule of interpretation is required (Ajmera Housing Corporation v. CIT [2010] 326 ITR 642 (SC); CIT v. Tara Agencies [2007] 292 ITR 444 (SC)). Not so doing would be to usurp the legislative function by the courts which is impermissible. The following extract from PadmasundaraRao (Decd) (supra), even as the case law in the matter is legion, as a reference to the afore-stated decisions by the Apex Court would reveal, would be instructive in the matter: The rival pleas regarding rew…

NIKHIL MOHINE,CHHINDWARA vs. DCIT, CPC, BENGULURU

In the result, the assessee’s appeals are allowed

ITA 37/JAB/2021[2018-19]Status: DisposedITAT Jabalpur18 Nov 2021AY 2018-19

Bench: Sh. Sanjay Arora, Hon'Ble

Section 139(1)Section 143(1)Section 154Section 2Section 36(1)(va)Section 43B

…. 37 & 38/Jab/2021 (AY 2018-19 & 2019-20) Nikhil Mohine v. Dy. CIT/Asst. DIT law is clear, as it indeed is in the instant case, no other rule of interpretation is required (Ajmera Housing Corporation v. CIT [2010] 326 ITR 642 (SC); CIT v. Tara Agencies [2007] 292 ITR 444 (SC)). Not so doing would be to usurp the legislative function by the courts which is impermissible. The following extract from Padmasundara Rao (Decd) (supra), even as the case law in the matter is legion, as a reference to the afore-stated decisions by the Apex Court would reveal, would be instructive in the matter: The rival pleas regarding re…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(2), BENGALURU vs. M/S. PURVANKARA PROJECTS LIMITED, BENGALURU

In the result, the appeals of the revenue are allowed for statistical purposes

ITA 348/BANG/2021[2011-12]Status: DisposedITAT Bangalore08 Nov 2021AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Pradeep Kumar, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Padamchand Khincha, CA
Section 139(1)Section 80Section 80I

…ces (P) Ltd v DCIT [2021] 128 taxmann.com 22 (Madras) 9 CBDT Circular No. 1 of 2013 dated 17.1.2013 10 Text of section 80IBA which requires separate books of account in respect of the housing project filed at pages 122-124 of PB. 11 CIT v Tara Agencies 120071 292 ITR 444 (SC) 12 Arisudana Spinning Mills Ltd v CIT 120121 26 taxmann.com 39 (SC) 13 Hughes Communications India Ltd v DCIT — ITAT Delhi — 14.9.2021 14 DCIT v NIIT Ltd — ITAT Delhi — 8.5.2015 13. We have heard both the parties and perused the material on record. In the present case, the assessee is carrying on various activities. Out of this, certain und…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(2), BANGALORE vs. M/S. PURVANKARA PROJECTS LIMITED, BENGALURU

In the result, the appeals of the revenue are allowed for statistical purposes

ITA 347/BANG/2021[2010-11]Status: DisposedITAT Bangalore08 Nov 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Pradeep Kumar, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Padamchand Khincha, CA
Section 139(1)Section 80Section 80I

…ces (P) Ltd v DCIT [2021] 128 taxmann.com 22 (Madras) 9 CBDT Circular No. 1 of 2013 dated 17.1.2013 10 Text of section 80IBA which requires separate books of account in respect of the housing project filed at pages 122-124 of PB. 11 CIT v Tara Agencies 120071 292 ITR 444 (SC) 12 Arisudana Spinning Mills Ltd v CIT 120121 26 taxmann.com 39 (SC) 13 Hughes Communications India Ltd v DCIT — ITAT Delhi — 14.9.2021 14 DCIT v NIIT Ltd — ITAT Delhi — 8.5.2015 13. We have heard both the parties and perused the material on record. In the present case, the assessee is carrying on various activities. Out of this, certain und…

DCIT CC 3(2) CEN RG 3, MUMBAI vs. VIVEK MEHROTRA, MUMBAI

In the result, both the appeals are partly allowed for statistical purposes

ITA 2171/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2021AY 2014-15

Bench: Shri Saktijit Dey & Shri Rajesh Kumarassessment Year: 2014-15 & Assessment Year: 2013-14

For Appellant: Shri Nitesh Joshi (AR)For Respondent: Shri Narendra Singh Janpangi (DR)
Section 132Section 139Section 153ASection 80I

…and the exemption available to 100% EOU u/s 10B of the Act are very similar in nature and the wordings of the statutory provisions are similar in nature. Hon‟ble Kerala High Court also considered the judgment in the decision of Supreme Court in Tara Agencies (292 ITR 444 (SC) relied upon by the Sr. Standing Counsel for the revenue, wherein Hon‟ble Supreme Court clearly held that blending of tea does not amount to „manufacture‟ or „production‟ of an article or thing, but is only processing. Hon‟ble High Court allowing the appeal of the assessee held that the assessee was exclusively engaged in blending and packing…

M/S NANDI STEELS LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the findings

ITA/103/2012HC Karnataka23 Feb 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(1)Section 143(3)Section 147Section 148Section 260Section 260ASection 6

…d rule of statutory interpretation that intention of statute has to 22 be gathered from the language employed by the legislature which means attention has to be paid to what has been said and what has not been said [See: 'CIT vs. TARA AGENCIES', (2007) 292 ITR 444 (SC)]. In 'GVK INDUSTRIES LTD. Vs. ITO', (2011) 332 ITR 130 (SC), the Supreme Court dealt with the legal maxim expression unius est exclusion alterius and held that express mention of one thing implies the exclusion of another. Section 72(1) of the Act employs the expression computation 'under the head profits and gains or profession', whe…

Showing 1–20 of 80 · Page 1 of 4