What is CIT v. Tejaji Farasram Kharawalla Ltd. authority for?

Reimbursement of expenses does not constitute income and is therefore not taxable as a revenue receipt. Such receipts are treated as a reduction of cost rather than income.

How many judgments cite CIT v. Tejaji Farasram Kharawalla Ltd.?

51 judgments on BharatTax cite CIT v. Tejaji Farasram Kharawalla Ltd. (67 ITR 95), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. Tejaji Farasram Kharawalla Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 35(2AB), Section 37(1), Section 10A, Section 10AA, Section 10B.

CIT v. Tejaji Farasram Kharawalla Ltd. (67 ITR 95)

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2480/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…f income in the hands of the SITV Network on account of absence of element of income therein, did not call for deduction of tax at source. Reliance in this regard is placed on the decision of Supreme Court in the case of CIT vs Tejaji Farasram Kharawalla Ltd: 67 ITR 95 (SC) wherein, part of the total commission, @ 5%, payable to the assessee, was in lieu of contingency expenses which the assessee had to meet such as commission to dyeing masters, agents, etc. The assessee claimed such part of the total selling agency commission, as relatable to actual expenses. The relevant extract of the decision is as below: “Th…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2479/DEL/2011[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…f income in the hands of the SITV Network on account of absence of element of income therein, did not call for deduction of tax at source. Reliance in this regard is placed on the decision of Supreme Court in the case of CIT vs Tejaji Farasram Kharawalla Ltd: 67 ITR 95 (SC) wherein, part of the total commission, @ 5%, payable to the assessee, was in lieu of contingency expenses which the assessee had to meet such as commission to dyeing masters, agents, etc. The assessee claimed such part of the total selling agency commission, as relatable to actual expenses. The relevant extract of the decision is as below: “Th…

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

ITA 2478/DEL/2011[2005-06]Status: DisposedITAT Delhi15 Apr 2026AY 2005-06

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Ms. Monika Singh, CIT DR

Section 14ASection 40

…f income in the hands of the SITV Network on account of absence of element of income therein, did not call for deduction of tax at source. Reliance in this regard is placed on the decision of Supreme Court in the case of CIT vs Tejaji Farasram Kharawalla Ltd: 67 ITR 95 (SC) wherein, part of the total commission, @ 5%, payable to the assessee, was in lieu of contingency expenses which the assessee had to meet such as commission to dyeing masters, agents, etc. The assessee claimed such part of the total selling agency commission, as relatable to actual expenses. The relevant extract of the decision is as below: “Th…

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

…142 ITR 493 (Delhi) ii. Siemens Aktiongesellschaft 177 Taxman 82 (Bom HC) iii. CIT vs. Industrial Engineering Projects (P.) Ltd. [1993] 202 IATR 1014 (Delhi) iv. DLF Commercial Project Corporation 379 ITR 538 (Delhi) v. Tejaji Farasram Kharawalla Ltd. [1968] 67 ITR 95 (SC) vi. DECTA 237 ITR 190 AAR vii. ABB Ltd. 189 Taxmann 422 viii. Ernst and Young Ltd. 49 taxmann.com 386 (Kolkata ITAT) 13. We carefully considered the submissions made by the appellant. On mere perusal of the assessment order, it would reveal that the disallowance u/s. 40(a)(i) was made by the AO solely for the reason of non-deduction of tax at…

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

The appeal of the assessee is partly allowed and appeal of the

ITA 4251/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Apr 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usassessment Year: 2011-12

Section 10ASection 143(3)

…ne of the parties pays the cost and recovers the proportionate payment from the other party. Since a reduction of cost by way of reimbursement of expense, recovery in the facts of the case is not income. The appellant relies on Tejaji Farasram Kharawalla Ltd. 67 ITR 95 (SC), Industrial Engineering Projects Pvt. Ltd. 202 ITR 1014(Del) and Dunlop Rubber Co. Ltd 142 ITR 493 (Cal). It has been submitted that by reducing its cost by recoveries made the appellant has claimed only the expenses relatable to its income and is not netting off any income from expenses 26:31 23.488 even receipts are taken as income from othe…

MS. GENPACT INDIA,,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed and appeal of the

ITA 4060/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Apr 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usassessment Year: 2011-12

Section 10ASection 143(3)

…ne of the parties pays the cost and recovers the proportionate payment from the other party. Since a reduction of cost by way of reimbursement of expense, recovery in the facts of the case is not income. The appellant relies on Tejaji Farasram Kharawalla Ltd. 67 ITR 95 (SC), Industrial Engineering Projects Pvt. Ltd. 202 ITR 1014(Del) and Dunlop Rubber Co. Ltd 142 ITR 493 (Cal). It has been submitted that by reducing its cost by recoveries made the appellant has claimed only the expenses relatable to its income and is not netting off any income from expenses 26:31 23.488 even receipts are taken as income from othe…

APTEAN INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 422/BANG/2022[2017-18]Status: DisposedITAT Bangalore20 Jan 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 422/Bang/2022 Assessment Year : 2017-18 M/S. Aptean India Pvt. Ltd., 1/2, 8Th Floor, Level 5, The Assistant Golden Heights, Commissioner Of 59Th C Cross Road, Income Tax, 4Th M Block, Circle – 1(1)(1), Rajajinagar, Vs. Bangalore. Bangalore – 560 010. Pan: Aaacc5890M Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Shri Praveen Karanth, Cit- Revenue By Dr Date Of Hearing : 03-11-2022 Date Of Pronouncement : 20-01-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 25/03/2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another General Ground 1. On The Facts & In The Circumstances Of The Case & In Law, Final Assessment Order Passed By National Faceless

For Respondent: Smt. Tanmayee Rajkumar

Section 143(3)Section 92D

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 422/Bang/2022 Assessment Year : 2017-18 M/s. Aptean India Pvt. Ltd., 1/2, 8th Floor, Level 5, The Assistant Golden Heights, Commissioner of 59th C Cross Road, Income Tax, 4th M Block, Circle – 1(1)(1), Rajajinagar, Vs. Bangalore. Bangalore – 560 010. PAN: AAACC5890M APPELLANT RESPONDENT : Smt. Tanmayee Rajkumar, Assessee by Advocate : Shri Praveen Karanth, CIT- Revenue by DR Date of Hearing : 03-11-2022 Date of Pronouncement : 20-01-2023 ORDER PER BEENA PILLA…

ITO WARD - 61(1), NEW DELHI vs. ANISH KUMAR GUPTA, NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1453/DEL/2020[2008-09]Status: DisposedITAT Delhi31 Aug 2022AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ITO WARD - 61(1), NEW DELHI vs. ANISH KUMAR GUPTA, NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1452/DEL/2020[2007-08]Status: DisposedITAT Delhi31 Aug 2022AY 2007-08

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ITO WARD - 61(1), NEW DELHI vs. ASHISH KUMAR GUPTA, NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1451/DEL/2020[2008-09]Status: DisposedITAT Delhi31 Aug 2022AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ITO WARD - 61(1), NEW DELHI vs. ASHISH KUMAR GUPTA, NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1450/DEL/2020[2007-08]Status: DisposedITAT Delhi31 Aug 2022AY 2007-08

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1237/DEL/2020[2009-10]Status: DisposedITAT Delhi31 Aug 2022AY 2009-10

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1236/DEL/2020[2008-09]Status: DisposedITAT Delhi31 Aug 2022AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1235/DEL/2020[2007-08]Status: DisposedITAT Delhi31 Aug 2022AY 2007-08

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ANISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1234/DEL/2020[2008-09]Status: DisposedITAT Delhi31 Aug 2022AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

ANISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

In the result, all the appeal of the revenue are dismissed on this score

ITA 1233/DEL/2020[2007-08]Status: DisposedITAT Delhi31 Aug 2022AY 2007-08

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Anish Kumar Gupta CAFor Respondent: Shri Kanav Bali, Sr.D.R

Section 143(3)Section 68

…the CIT(A)." That Hon'ble Jurisdictional High Court in the case of CIT \/s. Industrial Engineering Products (P) Ltd. 202 ITR 1014 (Delhi) (Annexure) by following the judgment of the Supreme Court in the case of CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC) in which it was held, " to the extent of the receipt representing reimbursement of the expenses the same are not taxable" ruled that reimbursement of expenses under no circumstances as revenue receipt. The appellant further rely on the decision of 7/ Bench of IT AT Mumbai in the case of Deputy Director of Income Tax vs. M/s Chubb Pacific Under…

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1345/BANG/2019[2017-18]Status: DisposedITAT Bangalore31 May 2022AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA

Section 195Section 201(1)

…Nos. 1344 & 1345/Bang/2019 e) Decision of Hon’ble Kolkotta High Court in case of CIT v. Dunlop Rubber Co. Ltd. (Now Dunlop Holdings Ltd) reported in 142 ITR 493 f) Decision of Hon’ble Supreme Court in case of CIT v. Tejaji Farasram Kharawalla Ltd. Reported in 67 ITR 95 g) Decision of Hon’ble Delhi High Court in case of CIT v. Industrial Engineering Projects (P) Ltd reported in 202 ITR 1014 g) Owen v. Pook (Inspector of Taxes) 74 ITR 147 (HL) h) Decision of Hon’ble Delhi High Court in case of ACIT vs Modicon Network (P) Ltd reported in 14 SOT 204 2.15 The Ld.AO examined the nature of payment in the light of the de…

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1344/BANG/2019[2016-17]Status: DisposedITAT Bangalore31 May 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA

Section 195Section 201(1)

…Nos. 1344 & 1345/Bang/2019 e) Decision of Hon’ble Kolkotta High Court in case of CIT v. Dunlop Rubber Co. Ltd. (Now Dunlop Holdings Ltd) reported in 142 ITR 493 f) Decision of Hon’ble Supreme Court in case of CIT v. Tejaji Farasram Kharawalla Ltd. Reported in 67 ITR 95 g) Decision of Hon’ble Delhi High Court in case of CIT v. Industrial Engineering Projects (P) Ltd reported in 202 ITR 1014 g) Owen v. Pook (Inspector of Taxes) 74 ITR 147 (HL) h) Decision of Hon’ble Delhi High Court in case of ACIT vs Modicon Network (P) Ltd reported in 14 SOT 204 2.15 The Ld.AO examined the nature of payment in the light of the de…

SATYA PRAKASH GUPTA,DELHI vs. DCIT CENTRAL CIRCLE-19, NEW DELHI

In the result, the appeals of the Revenue are dismissed as well as the appeals of the assessee are allowed

ITA 724/DEL/2021[2013-14]Status: DisposedITAT Delhi09 Mar 2022AY 2013-14

Bench: Shri N.K. Billaiya & Shri Amit Shukla

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri H.K. Chaudhary, CIT DR

Section 10ASection 153A

…n India. Even otherwise, since the aforesaid receipt were pure reimbursement, the same 61 ITA Nos.1277 to 1281/Del./2021 ITA Nos.723 & 724/Del./2021 CO Nos.55 to 58/Del/2021 was not income to be brought to tax. [Refer: CIT v. Tejaji Farasram Kharawalla Ltd.: 67 ITR 95 (SC); DIT v. A.P. Moller Maersk A S: 392 ITR 186 (SC); CIT vs. Fortis Healthcare Ltd: 181 Taxman 257 (Del)] 17.30 On perusal of the above, it would be appreciated that the Revenue did not find any material, leave alone incriminating material suggesting accrual of alleged commission income and nexus of aforesaid receipt with that income. The allegat…

SATYA PRAKASH GUPTA,DELHI vs. DCIT CENTRAL CIRCLE-19, NEW DELHI

In the result, the appeals of the Revenue are dismissed as well as the appeals of the assessee are allowed

ITA 723/DEL/2021[2012-13]Status: DisposedITAT Delhi09 Mar 2022AY 2012-13

Bench: Shri N.K. Billaiya & Shri Amit Shukla

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri H.K. Chaudhary, CIT DR

Section 10ASection 153A

…n India. Even otherwise, since the aforesaid receipt were pure reimbursement, the same 61 ITA Nos.1277 to 1281/Del./2021 ITA Nos.723 & 724/Del./2021 CO Nos.55 to 58/Del/2021 was not income to be brought to tax. [Refer: CIT v. Tejaji Farasram Kharawalla Ltd.: 67 ITR 95 (SC); DIT v. A.P. Moller Maersk A S: 392 ITR 186 (SC); CIT vs. Fortis Healthcare Ltd: 181 Taxman 257 (Del)] 17.30 On perusal of the above, it would be appreciated that the Revenue did not find any material, leave alone incriminating material suggesting accrual of alleged commission income and nexus of aforesaid receipt with that income. The allegat…

CIT v. Tejaji Farasram Kharawalla Ltd.

What is CIT v. Tejaji Farasram Kharawalla Ltd. authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. Tejaji Farasram Kharawalla Ltd.

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

MS. GENPACT INDIA,,NEW DELHI vs. DCIT, NEW DELHI

APTEAN INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

ITO WARD - 61(1), NEW DELHI vs. ANISH KUMAR GUPTA, NEW DELHI

ITO WARD - 61(1), NEW DELHI vs. ANISH KUMAR GUPTA, NEW DELHI

ITO WARD - 61(1), NEW DELHI vs. ASHISH KUMAR GUPTA, NEW DELHI

ITO WARD - 61(1), NEW DELHI vs. ASHISH KUMAR GUPTA, NEW DELHI

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

ASHISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

ANISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

ANISH KUMAR GUPTA,NEW DELHI vs. ITO WARD - 37(1), NEW DELHI

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

SATYA PRAKASH GUPTA,DELHI vs. DCIT CENTRAL CIRCLE-19, NEW DELHI

SATYA PRAKASH GUPTA,DELHI vs. DCIT CENTRAL CIRCLE-19, NEW DELHI