CIT v. Woodward Governor India Pvt. Ltd.

312 ITR 254Supreme Court of India2009#45 most cited

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.

968

judgments rely on this decision, according to BharatTax’s citation analysis of 372,010 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. Woodward Governor · 312 ITR 254 · Section 37(1) · Section 43A · Section 145(3) · foreign exchange fluctuation · mercantile system of accounting · stock valuation · closing stock · revenue expenditure

Also reported as

21 DTR 106

Sections most often in play

Section 37(1)Section 143(3)Section 14ASection 115JBSection 147Section 142(1)Section 43(5)Section 40(a)(ia)
Read the full judgment

Issues it is cited on

section 43asection 40(a)(i)mercantile system of accountingbook profitssection 37(1)section 115jrevenue expendituresection 43capital expendituresection 40(a)section 115jbsection 32

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

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 1531/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…

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 1530/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…

Asst.C.I.T., 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 613/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

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…

Infosys Ltd, Bangalore vs. Assistant Commissioner of Income Tax, Bangalore

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

ITA 532/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

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…

Dy.C.I.T., Bangalore vs. M/S Infosys Limited, Bangalore

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

ITA 509/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

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…

Infosys Ltd., Bangalore vs. DCIT, Bangalore

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

ITA 449/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

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…

ACIT 28(2), Mumbai vs. M/S. Neel Siddhi Developers, Mumbai

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

ITA 1693/MUM/2020[2012-13]Status: DisposedITAT Mumbai22 Nov 2022AY 2012-13

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleacit 28(2) Vs. M/S Neel Siddhi Room No. 307, 3Rd Floor Developers, Tower No. 6, Vashi Rly 2Nd Floor, Emerald, Stn Complex, Vashi Plot No. 195/B, Navi Mumbai – 400703 Sec-12, Vashi, Navi Mumbai – 400 703. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagfn2744N Appellant .. Respondent Appellant By : Shri Chetan M. Kacha.Dr Respondent By : Shri Subodh Ratnaparkhi.Ar Date Of Hearing 14.11.2022 Date Of Pronouncement 24.11.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Passed By The Commissioner Of Income Tax (Appeals)- 26, Mumbai Passed U/S 143(3) & 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Chetan M. Kacha.DRFor Respondent: Shri Subodh Ratnaparkhi.AR
Section 143(2)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER ACIT 28(2) Vs. M/s Neel Siddhi Room No. 307, 3rd Floor Developers, Tower No. 6, Vashi Rly 2nd Floor, Emerald, Stn Complex, Vashi Plot No. 195/B, Navi Mumbai – 400703 Sec-12, Vashi, Navi Mumbai – 400 703. "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAGFN2744N Appellant .. Respondent Appellant by : Shri Chetan M. Kacha.DR Respondent by : Shri Subodh Ratnaparkhi.AR Date of Hearing 14.11.2022 Date of Pronouncement 24.11.2022 आदेश / O R D E R PER PAVAN KUMAR GADALE JM: The…

M/S Dell International Services India Private Limited, Bangalore vs. Joint Commissioner of Income Tax Ltu, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 932/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.844/Bang/2017 Assessment Year : 2012-13 The Joint Vs. M/S.Dell International Services India Commissioner Of Private Limited, Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent It(Tp)A No.932/Bang/2017 Assessment Year : 2012-13 M/S.Dell International Services Vs. The Joint Commissioner India Private Limited, Of Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent Revenue By : Shri Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Assessee By : Shri T. Suryanarayana, Advocate Date Of Hearing : 07.11.2022 Date Of Pronouncement : 14.11.2022

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri
Section 143(2)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No.844/Bang/2017 Assessment year : 2012-13 The Joint Vs. M/s.Dell International Services India Commissioner of Private Limited, Income Tax, LTU, (for the merged entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. PAN : AAACH1925Q APPELLANT RESPONDENT IT(TP)A No.932/Bang/2017 Assessment year : 2012-13 M/s.Dell International Services Vs. The Joint Commissioner India Private L…

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Private Limited, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 844/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.844/Bang/2017 Assessment Year : 2012-13 The Joint Vs. M/S.Dell International Services India Commissioner Of Private Limited, Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent It(Tp)A No.932/Bang/2017 Assessment Year : 2012-13 M/S.Dell International Services Vs. The Joint Commissioner India Private Limited, Of Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent Revenue By : Shri Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Assessee By : Shri T. Suryanarayana, Advocate Date Of Hearing : 07.11.2022 Date Of Pronouncement : 14.11.2022

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri
Section 143(2)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No.844/Bang/2017 Assessment year : 2012-13 The Joint Vs. M/s.Dell International Services India Commissioner of Private Limited, Income Tax, LTU, (for the merged entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. PAN : AAACH1925Q APPELLANT RESPONDENT IT(TP)A No.932/Bang/2017 Assessment year : 2012-13 M/s.Dell International Services Vs. The Joint Commissioner India Private L…

ITO-33(1)(2), Mumbai vs. Shri Vikram Baijnath Agarwal, Mumbai

In the result, appeal filed by the revenue is partly allowed and cross objection filed by the assessee is dismissed

ITA 103/MUM/2021[2014-15]Status: DisposedITAT Mumbai07 Nov 2022AY 2014-15

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleincome Tax Officer – 33(1)(2) V. Shri Vikrambaijnath Agarwal Room No. 945, 9Th Floor 2003/04, Birchwood Raheja Villows Kautilya Bhavan, Bandra Kurla Complex Lokhandwala Township Nr Mahindra Gate 4 Kandivali (E), Mumbai - 400101 Bandra(E), Mumbai - 400051 Pan: Adepa8582C Appellant Respondent

Section 142Section 143(1)Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER Income Tax Officer – 33(1)(2) v. Shri VikramBaijnath Agarwal Room No. 945, 9th Floor 2003/04, Birchwood Raheja Villows Kautilya Bhavan, Bandra Kurla Complex Lokhandwala Township NR Mahindra Gate 4 Kandivali (E), Mumbai - 400101 Bandra(E), Mumbai - 400051 PAN: ADEPA8582C Appellant Respondent C.O. No. 11/MUM/2022 [ARISING OUT OF ITA No. 103/MUM/2021 (A.Y. 2014-15)] Shri VikramBaijnath Agarwal v. Income Tax Officer – 33(1)(2) 2003/04, Birchwood Raheja Villow…

Rosebys Interiors India Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circel-5, Ahmedabad

In the result, this Ground of appeal of the Department is dismissed

ITA 204/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad04 Nov 2022AY 2010-11
For Appellant: Shri Mukund Bakshi, A.RFor Respondent: Shri Sudhendu Das, CIT-D.R
Section 234ASection 271Section 37

…g to Rs.8,09,35,919/-. During the course of appellate proceedings, appellant has relied upon the contentions made before the A.O. Further it has relied upon various case law such as ONGC Ltd. v/s. CIT 322 ITR 180 (SC), CIT v/s. Woodward Governor India P. Ltd. 312 ITR 254 (SC) etc. It has also relied upon the applicability of AS- 11 as issued by Institute of Chartered Accountants of India {ICAI}. Keeping in mind the stand taken by TPO, withdrawal of ground Nos.5 & 6 by the appellant itself as well as stand taken by the A.O,, it is apparent that the said loan given to M/s. Indian Wales, an AE of the appellant is co…

The DCIT, Circle-3(1)(1), Ahmedabad vs. M/S. Rosebys Interiors India Ltd., Ahmedabad

In the result, this Ground of appeal of the Department is dismissed

ITA 153/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad04 Nov 2022AY 2010-11
For Appellant: Shri Mukund Bakshi, A.RFor Respondent: Shri Sudhendu Das, CIT-D.R
Section 234ASection 271Section 37

…g to Rs.8,09,35,919/-. During the course of appellate proceedings, appellant has relied upon the contentions made before the A.O. Further it has relied upon various case law such as ONGC Ltd. v/s. CIT 322 ITR 180 (SC), CIT v/s. Woodward Governor India P. Ltd. 312 ITR 254 (SC) etc. It has also relied upon the applicability of AS- 11 as issued by Institute of Chartered Accountants of India {ICAI}. Keeping in mind the stand taken by TPO, withdrawal of ground Nos.5 & 6 by the appellant itself as well as stand taken by the A.O,, it is apparent that the said loan given to M/s. Indian Wales, an AE of the appellant is co…

ACIT, Circle-5(1), New Delhi vs. Bumi Hiway (India) P.Ltd, New Delhi

In the result, the appeal of the Revenue as well as Cross

ITA 4596/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Nov 2022AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Mrs. Shashi M Kapila, AdvFor Respondent: Shri Kanav Bali, Sr.DR
Section 143(3)

…CIT(A) looking to the facts and nature of transactions held that the entire sum could not be said to be expanded wholly and exclusively for the business purpose. Therefore, following the decision of the Supreme Court in CIT Vs Woodward Governor India P. Ltd. 312 ITR 254, the CIT(A) allowed the claim of the assessee to the extent of 50%. The ITAT upheld the decision of the CIT(A) on the ground that there was absence of complete details provided before the AO and the AR could not show that the whole funds were used for business purpose. Similarly, the DR could not show that the fluctuation was capital in nature. T…

D.C.I.T.-CC-2(4), Kolkata vs. M/S Global Wool Alliance Pvt. Ltd., Kolkata

In the result, the appeal of the revenue is dismissed

ITA 260/KOL/2020[2005-06]Status: DisposedITAT Kolkata02 Nov 2022AY 2005-06

Bench: Shri Sanjay Garg & Shri Rajesh Kumar]

Section 92C

…f the exchange fluctuation loss attributable to loan utilized for working capital needs. Moreover I find that subsequent thereto, this particular issue has since been settled and answered by the Hon'ble Supreme Court in the case of Woodward Governor Pvt. Ltd (312 ITR 254) and ONGC vs. CIT (322 ITR 180) wherein the foreign exchange loss attributable to working capital was held to be revenue in nature and allowable as deduction from profits of the business. The Hon'ble Court further held that the MTM loss determined at the year-end on the basis of the prevailing exchange rate is a real loss and admissible for tax p…

ACIT, Cir. 1(1), Kolkata vs. M/S Cookson India (P) Ltd, Kolkata

In the result, appeal of the revenue is partly allowed for statistical purpose and the Cross Objection of the assessee is dismissed

ITA 250/KOL/2021[2010-11]Status: DisposedITAT Kolkata31 Oct 2022AY 2010-11

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2010-11 Assistant Commissioner Of M/S. Cookson India Pvt. Income Tax, Circle-1(1), Vs Ltd., 10, Old Post Office Kolkata. . Street, Room No. 15A, Kolkata-700001. (Pan: Aabcc1679B) (Appellant) (Respondent) & Cross Objection No. 02/Kol/2022 In Ita No.250/Kol/2021 Assessment Year: 2010-11 M/S. Cookson India Pvt. Assistant Commissioner Of Ltd., 10, Old Post Office Vs Income Tax, Circle-1(1), Street, Room No. 15A, . Kolkata. Kolkata-700001. (Cross Objector) (Respondent)

For Respondent: Smt. Ranu Biswas, Addl. CIT, DR
Section 143(3)Section 92C

…anted relief to the assessee on the same issue vide his order dated 21.10.2016 for which the department did not go into the appeal. Assessee also placed reliance on the decision of Hon’ble Supreme Court in the case of CIT Vs. Woodward Governor India Pvt. Ltd. 312 ITR 254 wherein the Forex loss were allowed as permissible claim. Considering the submissions made by the assessee, ld. CIT(A) directed the Ld. AO to examine the claim of the assessee to find if the forex fluctuation for items are in the nature of revenue, then the same may be allowed considering the decision of Hon’ble Supreme Court in the case of Woodw…

DCIT, Circle - 12(1), Kolkata vs. M/S. Amri Hospitals Ltd., Kolkata

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

ITA 977/KOL/2018[2014-15]Status: DisposedITAT Kolkata20 Oct 2022AY 2014-15

Bench: Dr. Manish Borad & Sri Sonjoy Sarma

Section 143(2)Section 143(3)Section 250Section 37Section 37(1)

…आयकर अपीलीय अधिकरण कोलकाता ' सी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH, KOLKATA डॉ मनीष बोरड, लेखा सदस्य एवं श्री संजय शमाा, न्याधयक सदस्य के समक्ष Before DR. MANISH BORAD, ACCOUNTANT MEMBER & SRI SONJOY SARMA, JUDICIAL MEMBER I.T.A. No.: 977/Kol/2018 Assessment Year: 2014-15 DCIT, Circle-12(1), Kolkata...………….......................Appellant Vs. AMRI Hospitals Ltd...............................................Respondent [PAN: AAECS 6786 N] Appearances by: Md. Atahar H. Choudhury, CIT, appeared on behalf of the Revenue. Sh. A.K. Tibrewal, FCA & Sh. Amit AGrawal, Adv., appeared on…

ACIT, Circle-5(1), Hyderabad vs. Lampex Electronics Limited, Hyderabad

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

ITA 96/HYD/2021[2017-18]Status: DisposedITAT Hyderabad17 Oct 2022AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.N.Moorthy, ARFor Respondent: Shri Kumar Aditya, DR
Section 115JSection 253(2)Section 36(1)(va)Section 68

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B”, HYDERABAD BEFORE SHRI RAMA KANTA PANDA, ACCOUNTANT MEMBER & SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER आ.अपी.सं / निर्धारण अपीलधर्थी / प्रत् यर्थी / वर्ा / A.Y. ITA Nos. Appellant Respondent Lampex Electronics DCIT, Circle-5(1), Limited, Erstwhile 589/Hyd/2020 2017-18 Hyderabad Circle-16(1), [PAN: AAACL4134B] Hyderabad Lampex Electronics ACIT, Limited, 96/Hyd/2021 2017-18 Circle-5(1), Hyderabad Hyderabad [PAN: AAACL4134B] सी.ओ./ C.O. No. 6/HYD/2021 (Arising out of ITA Nos. 96/Hyd/2021) निर्धारण वर्ा / Assessment Year…

Lampex Electronics Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

ITA 589/HYD/2020[2017-18]Status: DisposedITAT Hyderabad17 Oct 2022AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.N.Moorthy, ARFor Respondent: Shri Kumar Aditya, DR
Section 115JSection 253(2)Section 36(1)(va)Section 68

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B”, HYDERABAD BEFORE SHRI RAMA KANTA PANDA, ACCOUNTANT MEMBER & SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER आ.अपी.सं / निर्धारण अपीलधर्थी / प्रत् यर्थी / वर्ा / A.Y. ITA Nos. Appellant Respondent Lampex Electronics DCIT, Circle-5(1), Limited, Erstwhile 589/Hyd/2020 2017-18 Hyderabad Circle-16(1), [PAN: AAACL4134B] Hyderabad Lampex Electronics ACIT, Limited, 96/Hyd/2021 2017-18 Circle-5(1), Hyderabad Hyderabad [PAN: AAACL4134B] सी.ओ./ C.O. No. 6/HYD/2021 (Arising out of ITA Nos. 96/Hyd/2021) निर्धारण वर्ा / Assessment Year…

Sony India Pvt. Ltd., New Delhi vs. Natioanal E- Assesment Centre, New Delhi

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

ITA 493/DEL/2021[2016-17]Status: FixedITAT Delhi17 Oct 2022AY 2016-17

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Bhaskar Goswami, CIT- DR
Section 115JSection 143(3)Section 80G

…t is an undisputed fact that the assessee has been consistently following the same method of valuation of closing stock which was cost or net realizable value, whichever is lower. 57. The Hon'ble Supreme Court in the case of Woodward Governor India [P] Ltd 312 ITR 254 had an occasion to consider similar grievance and the Hon'ble Supreme Court held as under: “The 1961 Act makes no provision with regard to valuation of stock. But the ordinary principle of commercial accounting requires that in the P&L account the value of the stock-in-trade at the beginning and at the end of the year should be entered at cost…

Idea Cellular Ltd, Mumbai vs. DCIT 3(2), Mumbai

In the result, appeal of the Revenue in ITA No

ITA 2285/MUM/2014[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09
Section 143(3)Section 194HSection 40

…heir services, which is nothing but an expenditure u/s 37(1) of the Act. 9.2.8 Though discount on premium is nothing but an expenditure u/s 37(1), it is worth noting that the Hon'ble Supreme Court in the case of CIT v. Woodward Governor India (P.) Ltd. [2009] 312 ITR 254/179 Taxman 326 has gone to the extent of covering "loss" in certain circumstances within the purview of "expenditure" as used in section in 37(1). In that case, the assessee incurred additional liability due to exchange rate fluctuation on a revenue account. The Assessing Officer did not allow deduction u/s 37. When the matter finally reached the…