CIT v. Woodward Governor India Pvt. Ltd.

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that ITA Nos.4859/Del/2009; ITA Nos.157 to 159,…

GUJARAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon the…

GUJRAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singhsl.No. Ita No. Filed By Assessee/Revenue Assessment Year Authority Passing The Order

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that ITA Nos.4859/Del/2009; ITA Nos.157 to 159, 4791…

ACIT, NEW DELHI vs. M/S GUJARAT GUARDIAN LTD., NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon t…

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon t…

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon t…

DCIT, NEW DELHI vs. M/S. GUJRAT GUARDIAN LTD., NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon t…

DCIT, NEW DELHI vs. M/S GUJRAT GUARDIAN LTD.,, NEW DELHI

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon t…

ACIT SPL. RANGE-7, NEW DELHI vs. PRUDENT-AGRI COMMODITIES INDIA PRIVATE LIMITED , NEW DELHI

In the result, the appeal filed by the Revenue partly allowed

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Y.: 2014-15 Acit, Special Range-7, Prudent Agri Commodities C.R. Building, New Delhi Vs India Pvt. Ltd., (Earlier M/S Sunder Agri Commodities India Pvt. Ltd.) 68/2, Rnm Centre, Janpath New Delhi – 110 001 (Pan: Aascs3922N) (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Adv., Ms. Ananya Kapoor, Adv., Sh. Sumit Lal Chandani, Adv. & Sh. Shivam Yadav, Adv. Department By : Ms. Harpreet Kaur Hansra, Sr. Dr. Date Of Hearing : 26.06.2025 Date Of Pronouncement : 09.07.2025 Order Per Shamim Yahya, Am : This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Cit(A)-Xxv, New Delhi Dated 21.12.2018 Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That Assessee Company E-Filed Its Return Of Income For Ay 2014-15 On 26.11.2014 Declaring An Income Of Rs. 1,06,26,080/- The Case Was Selected For Scrutiny Assessment Under Cass & Statutory Notice U/S. 143(2) Of The Act Was Issued On 28.08.2015. Thereafter, Notice Under Section 142(1) Of The I.T. Act, 1961 Was Issued On 06.06.2016 & 12.09.2016

…ssessee on account of fluctuation in the rate of foreign exchange as on the date of the balance- sheet is an item of expenditure under section 37(1) of the Income-tax Act, 1961. Decision of the Delhi High Court in CIT v. WOODWARD GOVERNOR INDIA P. LTD. [2007] 294 ITR 451 affirmed. For valuing the closing stock at the end of a particular year, the value prevailing on the last date is relevant. This is because profit/loss is embedded in the closing stock. While anticipated loss is taken into account, anticipated profit in the shape of appreciated value of the closing stock is not brought into account, as no prudent…

SHREE CHANDI MAA MAHAKALI PRACHIN MANDIR SIDH PEETH SAMITI,SONIPAT vs. CPC, BANGLORE

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…asset will only be made at the time of actual payment. The disallowance of depreciation as aforesaid was affirmed by the ld. CIT(A) in view of the amendment. 14. Ld. Counsel for the assessee relied upon the judgement in the case Woodward Governor reported in 294 ITR 451 for the proposition that the amendment brought in section 43A of the Act is prospective and applicable w.e.f. 1.4.2003. 15. Ld. D.R. could not provide any adverse ruling holding otherwise against the assessee. Finding of the Bench: 16. After considering the rival submissions, we are of the view that the authorities have erred in relying upon th…

DCIT, NEW DELHI vs. M/S HUDCO LTD.,, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

…com 298/234 Taxman 868/378 ITR 533 (Mad.); CIT v. Bharat Aluminium Co. Ltd. [2010] 187 Taxman 111(Delhi); CIT v. Virtual Soft Systems Ltd. [2018] 92 taxmann.com 370/255 Taxman 352/404 ITR 409 (SC); CIT v. Woodward Governor India (P.) Ltd. [2007] 162 Taxman 60/294 ITR 451 (Delhi) and CIT v. Excel Industries Ltd. [2013] 38 taxmann.com 100/219 Taxman 379/358 ITR 295 (SC). 24. Mr. Zoheb Hossain and Mr. Deepak Anand, learned counsels for the revenue, on the other hand urged that the assessee was required to make the book of accounts in accordance with the provisions of the Companies Act, 1956. However, profits compute…

M/S. HOUSING & URBAN DEVELOPMENT CORPORATION LTD. (HUDCO),NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

…com 298/234 Taxman 868/378 ITR 533 (Mad.); CIT v. Bharat Aluminium Co. Ltd. [2010] 187 Taxman 111(Delhi); CIT v. Virtual Soft Systems Ltd. [2018] 92 taxmann.com 370/255 Taxman 352/404 ITR 409 (SC); CIT v. Woodward Governor India (P.) Ltd. [2007] 162 Taxman 60/294 ITR 451 (Delhi) and CIT v. Excel Industries Ltd. [2013] 38 taxmann.com 100/219 Taxman 379/358 ITR 295 (SC). 24. Mr. Zoheb Hossain and Mr. Deepak Anand, learned counsels for the revenue, on the other hand urged that the assessee was required to make the book of accounts in accordance with the provisions of the Companies Act, 1956. However, profits compute…