What is CIT v. Woodward Governor India Pvt. Ltd. authority for?

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

How many judgments cite CIT v. Woodward Governor India Pvt. Ltd.?

968 judgments on BharatTax cite CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254), spanning 2008 to 2026.

Which sections of the Income Tax Act does CIT v. Woodward Governor India Pvt. Ltd. come up under?

It is most often cited in judgments turning on Section 37(1), Section 143(3), Section 14A, Section 115JB, Section 147, Section 142(1).

CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254)

Ibf Industries Ltd, Mumbai vs. Asst CIT 4 (2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 8029/MUM/2019[2015-16]Status: DisposedITAT Mumbai17 Feb 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm M/S. Jbf Industries Ltd. Asst. Cit-4(2)(2) 8Th Floor, Express Towers, Mumbai Vs. Nairman Point, Mumbai-400 021 Pan/Gir No. Aaacj 2575 J (Appellant) : (Respondent) Assessee By : Shri K. Gopal : Shri Samruddhi Dhananjay Hande Revenue By : 24.11.2022 Date Of Hearing Date Of Pronouncement : 17.02.2023 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Assessing Officer (A.O. For Short) Passed In Pursuance To The Proposal Of The Ld. Dispute Resolution Panel ('Drp' For Short) U/S. 144(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2015-16. 2. The Assessee Has Challenged The Upward Adjustment Of Rs.2,28,62,345/- On Account Of Foreign Exchange Losses On Ecb Loan & Also The Upward Adjustment Of Rs.29,28,34,962/- On Account Of ‘Loss On Derivative Contracts’.

For Appellant: Shri K. GopalFor Respondent: 24.11.2022

Section 115JSection 144(3)Section 37Section 92C

…Computation and Disclosure Standards (ICDC) notified by CBDT, foreign exchange fluctuation loss was to be charged to the P&L statement. The ld. AR relied on the decision of the Hon'ble Apex Court in the case of CIT vs. Woodward Governor India (P.) Ltd. [2009] 312 ITR 254 (SC), wherein it was held that the said foreign exchange fluctuation loss as per mercantile system of accounting was claimed as ‘revenue loss’. 9. The learned Departmental Representative (ld. DR for short) for the Revenue, on the other hand, contended that the said loan was obtained for refinancing the already existing capital expenditure loans…

Principal Commissioner of Income Tax Central 1 Kolkata vs. M/S Ramkrishna Forgings Ltd

In the result the appeal is partly allowed

ITAT/258/2022HC Calcutta08 Feb 2023

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 8Th February, 2023 Appearance : Mr. Tilak Mitra, Adv. …For Appellant Mr. S.M. Surana, Adv. Ms. Sapna Das, Adv. Mr. S. Das, Adv. …For Respondent

Section 260ASection 36Section 37Section 43(5)Section 43B

…ion of law no. 1 is answered against the revenue. So far as the second substantial question of law is concerned we note that the learned Tribunal had rightly took note of the decision of the Hon’ble Supreme Court in CIT Vs. Woodward Governor India Pvt. Ltd., [312 ITR 254 (SC)] and granted relief to the assessee. The said order cannot be faulted and accordingly substantial question of law No. 2 is answered against the revenue. So far as the third substantial question of law is concerned the said issue has to be answered in favour of the revenue and against the assessee in the light of the decision of the Hon’ble…

Everest Industries Ltd., Noida vs. Dy CIT Circle- 1, Thane

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 715/MUM/2020[2008-09]Status: DisposedITAT Mumbai31 Jan 2023AY 2008-09

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

DCIT Circle-1, Thane vs. M/S Everest Industries Ltd., Delhi

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 654/MUM/2020[2012-13]Status: DisposedITAT Mumbai31 Jan 2023AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

DCIT Circle-1, Thane vs. M/S Everest Industries Ltd., Delhi

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 653/MUM/2020[2013-14]Status: DisposedITAT Mumbai31 Jan 2023AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

DCIT, Circle-1, Thane vs. Everest Industries Ltd., Mumbai

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 1423/MUM/2020[2008-09]Status: DisposedITAT Mumbai31 Jan 2023AY 2008-09

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

Everest Industries Ltd, Noida vs. Dy CIT Cirlce-1, Thane

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 7794/MUM/2019[2013-14]Status: DisposedITAT Mumbai31 Jan 2023AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

Everest Industries Ltd, Noida vs. Dy CIT Cirlce-1, Thane

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 7793/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Jan 2023AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/

Section 115J

…CIT(A) is apparently not in accordance with the decision rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward rendered by Hon'ble Supreme Court in the case of Woodward Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Governor India P Ltd (2009)(312 ITR 254)(SC), wherein the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the Hon'ble Supreme Court has expressed the view that the valuation is a part of accounting system and that th…

M/S.Oil Tools International Services Private Limited, Mumbai vs. Assistant Commissioner of Income Tax 15(2)(2), Mumbai

In the result, the Ground No

ITA 513/MUM/2018[2013-14]Status: DisposedITAT Mumbai30 Jan 2023AY 2013-14

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Oil Tools International V. Acit -15(2)(2) Services Pvt. Ltd., Room No. 357, 3Rd Floor Village Kharsundi, Post Kharsundi Aayakar Bhavan, M.K. Road Tal. Khalapur, Dist. Raigad - 410202 Mumbai - 400020 Pan: Aaaco7232M (Appellant) (Respondent) Assessee Represented By : Shri Poojan Mehta Department Represented By : Shri Hiren Bhatt

Section 143(1)Section 143(2)Section 43A

…Services Pvt. Ltd., purchase capital assets. Accordingly, reliance place by the assessee on the decision of the Pune ITAT is not correct. He Further, observed that the decision of Hon'ble Supreme Court in the case of CIT v. Woodward Governor India (P.) Ltd., [312 ITR 254 (SC) (2009)] is a settled law and relying on the same, he upheld the additions made by the Assessing Officer. 6. Aggrieved assessee is in appeal before us raising following grounds in its appeal: - “1. The Ld CIT(A) erred in confirming order of AO disallowing foreign exchange loss of Rs 42,80,768/- claimed by the assesse on outstanding External…

ACIT, Chennai vs. Barclays Investments and Loans (I) Ltd., Chennai

Accordingly, ground no.3 of the appeal of the learned Assessing Officer is dismissed

ITA 3292/CHNY/2016[2010-11]Status: DisposedITAT Mumbai30 Jan 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm M/S. Barclays Investments & Loans Acit, Corporate Circle 1(2), (I) Ltd. Chennai – 600 034 No. 144-145, Malavika Centre Ground Vs. Fl, Kodambakkam High Road, Chennai- 600 034 (Appellant) (Respondent) Pan No. Aaacr3653F

For Appellant: Shri. Parcy Pardiwala, Sr. Adv. &For Respondent: Dr. Mahesh Akhade, CIT DR

Section 143(3)Section 14ASection 92C

…llowed without verification of the quantum of loss. 2.4. The CIT (A) failed to appreciate that the Board’s Circular No. 3/2010 dt. 23.10.2010 which was subsequent to the quoted decision of the Apex Court in CIT vs. M/s. Woodward Governor India Pvt Ltd (2009) 312 ITR 254, indicating that notional losses on MTM valuation are not allowable, becomes relevant. 3. The learned CIT (A) has erred in holding that disallowance u/s. 14A will not apply if no exempt income is received or receivable during the year. 3.1 The learned CIT(A) erred in deleting the disallowance defected u/s. 14A without appreciating the fact that…

ACIT - 15(1)(1), Mumbai vs. Privi Speciality Chemicals Ltd. (Earswhile Privi Organics Ltd.), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 7356/MUM/2019[2011-12]Status: DisposedITAT Mumbai24 Jan 2023AY 2011-12

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Sanjay ParikhFor Respondent: Shri K.C. Salvamani

Section 143(3)Section 250

…allowable deduction where no sale or settlement has actually taken place. I have also perused the decision of Hon'ble Supreme Court in the case of CIT vs. Woodward Governor India Pvt. M/s. Privi Speciality Chemicals Ltd. (Erstwhile Privi Organics Ltd.) Ltd., 312 ITR 254 wherein the Hon'ble Court has referred to the provisions of section 43A and held that after the amendment of section 43A with effect from A.Y. 13-14, loans on account of fluctuation of foreign exchange would be required to be adjusted only when actual losses were suffered. 4.4.3 In the case under hand, it is an undisputed fact that the cost of th…

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1982/BANG/2018[2012-13]Status: DisposedITAT Bangalore12 Jan 2023AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R

Section 143(3)

…ble Supreme Court in the case of Woodward Governor Private Limited (supra). In assessment year 2008-09, the forex fluctuation loss on unexpired forward contracts was allowed by the Tribunal following the Hon’ble Supreme Court in the case of Woodward Governer (312 ITR 254).Therefore, it is relevant to refer the ratio of the Hon’ble Supreme Court in the case. In the said case, questions of law were raised in respect of impact of variation in foreign currency exchange rate on the balance sheet date both on the expenditure on account of capital as well as revenue. The questions of law framed in the case of Woodward G…

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1981/BANG/2018[2010-11]Status: DisposedITAT Bangalore12 Jan 2023AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R

Section 143(3)

…ble Supreme Court in the case of Woodward Governor Private Limited (supra). In assessment year 2008-09, the forex fluctuation loss on unexpired forward contracts was allowed by the Tribunal following the Hon’ble Supreme Court in the case of Woodward Governer (312 ITR 254).Therefore, it is relevant to refer the ratio of the Hon’ble Supreme Court in the case. In the said case, questions of law were raised in respect of impact of variation in foreign currency exchange rate on the balance sheet date both on the expenditure on account of capital as well as revenue. The questions of law framed in the case of Woodward G…

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Additional Commissioner of Income Tax Range-12, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1980/BANG/2018[2009-10]Status: DisposedITAT Bangalore12 Jan 2023AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R

Section 143(3)

…ble Supreme Court in the case of Woodward Governor Private Limited (supra). In assessment year 2008-09, the forex fluctuation loss on unexpired forward contracts was allowed by the Tribunal following the Hon’ble Supreme Court in the case of Woodward Governer (312 ITR 254).Therefore, it is relevant to refer the ratio of the Hon’ble Supreme Court in the case. In the said case, questions of law were raised in respect of impact of variation in foreign currency exchange rate on the balance sheet date both on the expenditure on account of capital as well as revenue. The questions of law framed in the case of Woodward G…

Unilever Industries Private Ltd, Mumbai vs. ACIT Range 1(3)(1), Mumbai

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 1015/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Dec 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleunilever Industries Pvt Vs. Acit, Range – 1(3)(1) Ltd., Room No 504, 5 Floor, Unilever House, Bd Aayakar Bhavan, Sawant Marg, Chakala, M.K.Road, Andheri (E), Mumbai-400020 Mumbai -400099. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacu0791P Appellant .. Respondent Appellant By : Ms.Jasmin Amalsadvala & Mr.Hiten Chande.Ar Respondent By : Mr. Jayant Jhaveri.Dr Date Of Hearing 15.12.2022 Date Of Pronouncement 02.01.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed U/S 143(3) & U/Sec144C(13) R.W.S 143(3A) & 143(3B) Of The Income Tax Act, 1961 Passed In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) Order U/S 144C(5) Of The Act Dated 26.02.2021.The Assessee Has Raised The Following Grounds Of Appeal. Unilever Industries Pvt Ltd, Mumbai. General: 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao/ Assistant Commissioner Of Income-Tax (Transfer Pricing) -4(2)(2) ("Tpo") Subsequent To The Directions Issued By The Hon'Ble Drp Has Erred In Assessing The Total Income At Rs. 152,67,16,425 As Against Returned Income Of Rs. 116,80,08,280 Computed By The Appellant. 2. Parti-Transfer Pricing Adjustments: Transfer Pricing ('Tp') Adjustment On Account Of Benchmarking & Allocation Of Royalty In Respect Of Provision Of Scientific & Technical Services ('Contract R&D')

For Appellant: Ms.Jasmin Amalsadvala &For Respondent: Mr. Jayant Jhaveri.DR

Section 143(3)Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER Unilever Industries Pvt Vs. ACIT, Range – 1(3)(1) Ltd., Room no 504, 5 Floor, Unilever House, BD Aayakar Bhavan, Sawant Marg, Chakala, M.K.Road, Andheri (E), Mumbai-400020 Mumbai -400099. "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACU0791P Appellant .. Respondent Appellant by : Ms.Jasmin Amalsadvala & Mr.Hiten Chande.AR Respondent by : Mr. Jayant Jhaveri.DR Date of Hearing 15.12.2022 Date of Pronouncement 02.01.2023 आदेश / O R D E R PER PAVAN KUMAR GADALE JM: The a…

Universal Music India P. Ltd., Mumbai vs. National Faceless Apeal Centre (NFAC), Dehi

In the result, appeal of assessee is partly allowed in the terms aforesaid

ITA 945/MUM/2021[2011-12]Status: DisposedITAT Mumbai13 Dec 2022AY 2011-12

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.945/मुं/2021 ("न.व. 2011-12) Universal Music India Pvt. Ltd. 201, 2Nd Floor, Vibgyor Towers, Plot No.6-62, Block G, Bkc (Opp. Trident Hotel) Bandra (E), Mumbai 400 051. Pan: Aaacp-1985-C ...... अपीलाथ"/Appellant बनाम Vs. National Faceless Appeal Centre(Nfac), Delhi. .....""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Ruturaj H. Gurjar ""तवाद" "वारा/Respondent By : Ms. Richa Gulati सुनवाई क" "त"थ/ Date Of Hearing : 02/12/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 13/12/2022 आदेश/Order Per Vikash Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘ The Cit(A) ] Dated 25/03/2021, For The Assessment Year 2011-12. 2 2. The Assessee In Appeal Has Raised Four Grounds. Grounds Of Appeal No.1 & 2 Are General In Nature. The Grievance Of Assessee In Ground No. 3 & 4 Of Appeal Is:

For Appellant: Shri Ruturaj H. GurjarFor Respondent: Ms. Richa Gulati

…it does not reflect true 3 profit. In support of his submissions the ld. Authorized Representative of the assessee placed reliance on the following decisions: (i) United Commercial Bank vs. CIT, 240 ITR 355(SC) (ii) CIT vs. Woodward Governor India Pvt. Ltd., 312 ITR 254(SC) (iii) CIT vs. Santram Mangatram, 275 ITR 312 (P&H) 3.1 In respect of ground No.4 of appeal, the ld. Authorized Representative of the assessee submits that for the period relevant to assessment year under appeal, the assessee in Profit and Loss Account has not claimed any write off of bad debts/advances. The ld. Authorized Representative of th…

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1849/BANG/2017[2008-09]Status: DisposedITAT Bangalore30 Nov 2022AY 2008-09

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

…iture u/s 37 of the I.T.Act, as per the accounting standard approved by the Institute of Chartered Accountants of India. 6.3 This issue is no longer res integra. Hon’ble Supreme Court in the case of CIT vs. Woodward Governor India Pvt. Ltd. reported in (2009) 312 ITR 254 has held that, the actual payment was not a condition precedent for making adjustment in respect of foreign currency transactions at the end of the closing year. Page 17 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 6.4 We also draw support from the decision of Hon’ble Mumbai Special Be…

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1848/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Nov 2022AY 2009-10

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

…iture u/s 37 of the I.T.Act, as per the accounting standard approved by the Institute of Chartered Accountants of India. 6.3 This issue is no longer res integra. Hon’ble Supreme Court in the case of CIT vs. Woodward Governor India Pvt. Ltd. reported in (2009) 312 ITR 254 has held that, the actual payment was not a condition precedent for making adjustment in respect of foreign currency transactions at the end of the closing year. Page 17 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 6.4 We also draw support from the decision of Hon’ble Mumbai Special Be…

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1557/BANG/2017[2007-08]Status: DisposedITAT Bangalore30 Nov 2022AY 2007-08

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

…iture u/s 37 of the I.T.Act, as per the accounting standard approved by the Institute of Chartered Accountants of India. 6.3 This issue is no longer res integra. Hon’ble Supreme Court in the case of CIT vs. Woodward Governor India Pvt. Ltd. reported in (2009) 312 ITR 254 has held that, the actual payment was not a condition precedent for making adjustment in respect of foreign currency transactions at the end of the closing year. Page 17 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 6.4 We also draw support from the decision of Hon’ble Mumbai Special Be…

M/S Infosys Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1532/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Nov 2022AY 2009-10

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

…iture u/s 37 of the I.T.Act, as per the accounting standard approved by the Institute of Chartered Accountants of India. 6.3 This issue is no longer res integra. Hon’ble Supreme Court in the case of CIT vs. Woodward Governor India Pvt. Ltd. reported in (2009) 312 ITR 254 has held that, the actual payment was not a condition precedent for making adjustment in respect of foreign currency transactions at the end of the closing year. Page 17 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 6.4 We also draw support from the decision of Hon’ble Mumbai Special Be…

CIT v. Woodward Governor India Pvt. Ltd.

What is CIT v. Woodward Governor India Pvt. Ltd. authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. Woodward Governor India Pvt. Ltd.

Ibf Industries Ltd, Mumbai vs. Asst CIT 4 (2)(2), Mumbai

Principal Commissioner of Income Tax Central 1 Kolkata vs. M/S Ramkrishna Forgings Ltd

Everest Industries Ltd., Noida vs. Dy CIT Circle- 1, Thane

DCIT Circle-1, Thane vs. M/S Everest Industries Ltd., Delhi

DCIT Circle-1, Thane vs. M/S Everest Industries Ltd., Delhi

DCIT, Circle-1, Thane vs. Everest Industries Ltd., Mumbai

Everest Industries Ltd, Noida vs. Dy CIT Cirlce-1, Thane

Everest Industries Ltd, Noida vs. Dy CIT Cirlce-1, Thane

M/S.Oil Tools International Services Private Limited, Mumbai vs. Assistant Commissioner of Income Tax 15(2)(2), Mumbai

ACIT, Chennai vs. Barclays Investments and Loans (I) Ltd., Chennai

ACIT - 15(1)(1), Mumbai vs. Privi Speciality Chemicals Ltd. (Earswhile Privi Organics Ltd.), Mumbai

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

M/S Harman Connected Services Corporation India Private Limited, Bangalore vs. Additional Commissioner of Income Tax Range-12, Bangalore

Unilever Industries Private Ltd, Mumbai vs. ACIT Range 1(3)(1), Mumbai

Universal Music India P. Ltd., Mumbai vs. National Faceless Apeal Centre (NFAC), Dehi

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

M/S Infosys Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore