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)

Bharti Telemedia Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 624/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…any difference if the future date on which the liability shall have to be discharged is not certain. (f) Calcutta Company Ltd vs CIT: 37 ITR 1 (SC) (g) Metal Box Company of India Ltd vs Their Workmen: 73 ITR 53 (SC) (h) CIT vs Woodward Governor India Pvt Ltd: 312 ITR 254 (SC) (i) CIT vs U.P. State Industrial Development Corporation: 225 ITR 703 (SC) (j) CIT vs Burhwal Sugar Mills Co Ltd: 82 ITR 784 (All) (k) Madho Mahesh Sugar Mills Ltd vs CIT: 92 ITR 503 (All) (l) Delhi Flour Mills Co Ltd vs CIT: 95 ITR 151 (Del) (m) CIT vs Laxmi Sugar & Oil Mills Ltd: 114 ITR 684 (All) (n) Eddy Current Controls (India) Ltd vs C…

DCIT, Circle 4(2), New Delhi vs. M/S Bharti Telemedia Ltd, New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4966/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…any difference if the future date on which the liability shall have to be discharged is not certain. (f) Calcutta Company Ltd vs CIT: 37 ITR 1 (SC) (g) Metal Box Company of India Ltd vs Their Workmen: 73 ITR 53 (SC) (h) CIT vs Woodward Governor India Pvt Ltd: 312 ITR 254 (SC) (i) CIT vs U.P. State Industrial Development Corporation: 225 ITR 703 (SC) (j) CIT vs Burhwal Sugar Mills Co Ltd: 82 ITR 784 (All) (k) Madho Mahesh Sugar Mills Ltd vs CIT: 92 ITR 503 (All) (l) Delhi Flour Mills Co Ltd vs CIT: 95 ITR 151 (Del) (m) CIT vs Laxmi Sugar & Oil Mills Ltd: 114 ITR 684 (All) (n) Eddy Current Controls (India) Ltd vs C…

Bharti Telemedia Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4960/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…any difference if the future date on which the liability shall have to be discharged is not certain. (f) Calcutta Company Ltd vs CIT: 37 ITR 1 (SC) (g) Metal Box Company of India Ltd vs Their Workmen: 73 ITR 53 (SC) (h) CIT vs Woodward Governor India Pvt Ltd: 312 ITR 254 (SC) (i) CIT vs U.P. State Industrial Development Corporation: 225 ITR 703 (SC) (j) CIT vs Burhwal Sugar Mills Co Ltd: 82 ITR 784 (All) (k) Madho Mahesh Sugar Mills Ltd vs CIT: 92 ITR 503 (All) (l) Delhi Flour Mills Co Ltd vs CIT: 95 ITR 151 (Del) (m) CIT vs Laxmi Sugar & Oil Mills Ltd: 114 ITR 684 (All) (n) Eddy Current Controls (India) Ltd vs C…

DCIT, Circle 4(2), New Delhi vs. Ms Bharti Telemedia Ltd, New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4868/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…any difference if the future date on which the liability shall have to be discharged is not certain. (f) Calcutta Company Ltd vs CIT: 37 ITR 1 (SC) (g) Metal Box Company of India Ltd vs Their Workmen: 73 ITR 53 (SC) (h) CIT vs Woodward Governor India Pvt Ltd: 312 ITR 254 (SC) (i) CIT vs U.P. State Industrial Development Corporation: 225 ITR 703 (SC) (j) CIT vs Burhwal Sugar Mills Co Ltd: 82 ITR 784 (All) (k) Madho Mahesh Sugar Mills Ltd vs CIT: 92 ITR 503 (All) (l) Delhi Flour Mills Co Ltd vs CIT: 95 ITR 151 (Del) (m) CIT vs Laxmi Sugar & Oil Mills Ltd: 114 ITR 684 (All) (n) Eddy Current Controls (India) Ltd vs C…

ACIT, Circle - 3 3 1, Mumbai vs. Jamnagar Utilities and Power Pvt Ltd, Mumbai

In the result, both the appeals of the Revenue are allowed

ITA 5312/MUM/2024[2019-20]Status: DisposedITAT Mumbai04 Dec 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Nimesh Vora/For Respondent: Mr. Vivek Perampurna, CIT-DR

Section 115JSection 135Section 139(1)Section 143(3)Section 144BSection 43ASection 80G

…it is computed in accordance with ICDS. As per ICDS only realized forex loss on forward contracts is allowed as deduction. 8.9.1 The AO has relied upon the decision rendered in the case of Commissioner of Income-tax, Delhi v. Woodward Governor India (P.) Ltd 312 ITR 254 (SC)/[2009]. The Hon'ble Supreme Court of India has held as under:- Assessment year 1998-99 1. Section 37(1), read with section 145, of the Income-tax Act, 1961 Business expenditure Allowablilty of Whether expression 'expenditure' as used in section 37 may, in circumstances of a particular case, cover an amount which is really a 'loss', even tho…

ACIT, Circle - 3 3 1, Mumbai vs. Jamnagar Utilities and Power Pvt Ltd, Mumbai

In the result, both the appeals of the Revenue are allowed

ITA 5310/MUM/2024[2020-21]Status: DisposedITAT Mumbai04 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Mr. Nimesh Vora/

Section 115JSection 135Section 139(1)Section 143(3)Section 144BSection 43ASection 80G

…it is computed in accordance with ICDS. As per ICDS only realized forex loss on forward contracts is allowed as deduction. 8.9.1 The AO has relied upon the decision rendered in the case of Commissioner of Income-tax, Delhi v. Woodward Governor India (P.) Ltd 312 ITR 254 (SC)/[2009]. The Hon'ble Supreme Court of India has held as under:- Assessment year 1998-99 1. Section 37(1), read with Section 145, of the Income-tax Act, 1961 Business expenditure Allowablilty of Whether expression 'expenditure' as used in Section 37 may, in circumstances of a particular case, cover an amount which is really a 'loss', even tho…

Deputy Commissioner of Income Tax-6, Lucknow vs. M/S. U.P. State Construction & Infrastructure Development Corporation Limited, Lucknow

ITA 617/LKW/2019[2014-15]Status: DisposedITAT Lucknow28 Nov 2025AY 2014-15

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143Section 143(3)Section 251Section 263

…1 IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH ‘A’, LUCKNOW BEFORE SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER AND SHRI SUBHASH MALGURIA, JUDICIAL MEMBER I.T.A. No.617/Lkw/2019 Assessment Year:2014-15 Dy.C.I.T. Vs. M/s U.P. State Construction & Range-6, Infrastructure Development Lucknow. Corpn. Ltd., TC/46V, Vibhuti Khand, Gomti Nagar, Lucknow. PAN:AAACU1932C (Appellant) (Respondent) C.O.No.01/Lkw/2020 (in I.T.A. No.617/Lkw/2019) Assessment Year:2014-15 M/s U.P. State Construction & Vs. Dy.C.I.T. Infrastructure Development Range-6, Corpn. Ltd., Lucknow. TC/46V, Vibhuti Khand, Gomti Nagar, Lucknow. PAN:A…

Assistant Commissioner of Income Tax, New Delhi vs. Lurgi India International Services Private Limited, New Delhi

In the result, the appeal of Revenue is dismissed as above

ITA 5826/DEL/2024[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: allowing carry forward of losses.”

Section 142(1)Section 37Section 79

…ady determined in the forward contract, whereas the facts of the present case were quite different. He further submitted that the case of the assessee was squarely covered by the decision of the Hon’ble Supreme Court in the case of Woodward Governor of India, 312 ITR 254, which was followed by the Ld. CIT(A) in the impugned order. Further, he also placed reliance on the case of Sutlej Cotton Mills Ltd (1979) 116 ITR 1. 10. With respect to the issue of denial of carry forward of loss under section 79 of the Act, the Ld. Counsel submitted that the case of the assessee was squarely covered by the decision of the Hon…

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…le. MTM gain of Rs. 1223 crores offered by the assessee was considered by assessing officer and brought to tax. On appeal before ld. CIT(A) MTM loss of Rs. 594 crores was allowed on the basis of decision of Supreme Court in Woodward Governor India P. Limited 312 ITR 252 and Oil and Natural Gas Commission 189 taxmann 292. Thus, revenue have challenged the order of ld. CIT(A). 15. The ld. CIT-DR for the revenue supported the order of assessing officer and would submit that assessing officer has clearly held that it was a notional loss. 16. On the other hand, the ld. AR of the assessee submits that this ground o…

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…le. MTM gain of Rs. 1223 crores offered by the assessee was considered by assessing officer and brought to tax. On appeal before ld. CIT(A) MTM loss of Rs. 594 crores was allowed on the basis of decision of Supreme Court in Woodward Governor India P. Limited 312 ITR 252 and Oil and Natural Gas Commission 189 taxmann 292. Thus, revenue have challenged the order of ld. CIT(A). 15. The ld. CIT-DR for the revenue supported the order of assessing officer and would submit that assessing officer has clearly held that it was a notional loss. 16. On the other hand, the ld. AR of the assessee submits that this ground o…

Kallakurichi Co-Operative Sugar Mills Unit II, Villupuram vs. ACIT, Villupuram Circle, Villupuram

In the result, the appeal of the assessee is dismissed…

ITA 2295/CHNY/2025[2020-21]Status: DisposedITAT Chennai13 Nov 2025AY 2020-21

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.2293, 2294 & 2295 / Chny/2025 Assessment Years-2017-18, 2018-19 & 2020-21 Kallakurichi Ii Co-Operative Sugar Assistant Commissioner Of Income Mills, Unit-Ii, Cs-11, Tax, Kachirapalayam, Kallakurichi, Circle-1 Villupuram, Cuddalore. Tamil Nadu-606 207. [Pan: Aaaak0655Q] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant)

For Appellant: Mr.S.Venugopalan, C.AFor Respondent: Mr.Aroon Praasad, Addl.CIT

…r determining the value of closing stock. The Id.AR relied on the following judgments for the proposition that consistency to be followed in income-tax proceedings : 1. United Commercial Bank v. CIT (240 ITR 355)(SC) 2. CIT v. Woodward Governor India P. Ltd. (312 ITR 254)(SC) 3. Merck Ltd. v. DCIT (2 ITR (Trib)-OL 629 (Mumbai) 4. CIT v. Dhampur Sugar Mills Ltd. (360 ITR 82) (Allahabad) Page - 3 - of 5 ITA Nos.2293, 2294 & 2295/Chny/2025 In our opinion, each assessment year is an independent assessment of unit and the wrong method of accounting followed by the assessee cannot be appropriated. In our opinion, the…

Kallakurichi Co-Operative Sugar Mills Unit II, Villupuram vs. ACIT, Villupuram Circle, Villupuram

In the result, the appeal of the assessee is dismissed…

ITA 2294/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Nov 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.2293, 2294 & 2295 / Chny/2025 Assessment Years-2017-18, 2018-19 & 2020-21 Kallakurichi Ii Co-Operative Sugar Assistant Commissioner Of Income Mills, Unit-Ii, Cs-11, Tax, Kachirapalayam, Kallakurichi, Circle-1 Villupuram, Cuddalore. Tamil Nadu-606 207. [Pan: Aaaak0655Q] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant)

For Appellant: Mr.S.Venugopalan, C.AFor Respondent: Mr.Aroon Praasad, Addl.CIT

…r determining the value of closing stock. The Id.AR relied on the following judgments for the proposition that consistency to be followed in income-tax proceedings : 1. United Commercial Bank v. CIT (240 ITR 355)(SC) 2. CIT v. Woodward Governor India P. Ltd. (312 ITR 254)(SC) 3. Merck Ltd. v. DCIT (2 ITR (Trib)-OL 629 (Mumbai) 4. CIT v. Dhampur Sugar Mills Ltd. (360 ITR 82) (Allahabad) Page - 3 - of 5 ITA Nos.2293, 2294 & 2295/Chny/2025 In our opinion, each assessment year is an independent assessment of unit and the wrong method of accounting followed by the assessee cannot be appropriated. In our opinion, the…

Kallakurichi Co-Operative Sugar Mills Unit II, Villupuram vs. ACIT, Villupuram Circle, Villupuram

In the result, the appeal of the assessee is dismissed…

ITA 2293/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Nov 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.2293, 2294 & 2295 / Chny/2025 Assessment Years-2017-18, 2018-19 & 2020-21 Kallakurichi Ii Co-Operative Sugar Assistant Commissioner Of Income Mills, Unit-Ii, Cs-11, Tax, Kachirapalayam, Kallakurichi, Circle-1 Villupuram, Cuddalore. Tamil Nadu-606 207. [Pan: Aaaak0655Q] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant)

For Appellant: Mr.S.Venugopalan, C.AFor Respondent: Mr.Aroon Praasad, Addl.CIT

…r determining the value of closing stock. The Id.AR relied on the following judgments for the proposition that consistency to be followed in income-tax proceedings : 1. United Commercial Bank v. CIT (240 ITR 355)(SC) 2. CIT v. Woodward Governor India P. Ltd. (312 ITR 254)(SC) 3. Merck Ltd. v. DCIT (2 ITR (Trib)-OL 629 (Mumbai) 4. CIT v. Dhampur Sugar Mills Ltd. (360 ITR 82) (Allahabad) Page - 3 - of 5 ITA Nos.2293, 2294 & 2295/Chny/2025 In our opinion, each assessment year is an independent assessment of unit and the wrong method of accounting followed by the assessee cannot be appropriated. In our opinion, the…

Sony India Private Limited, Delhi vs. ACIT Circle 22(2), Delhi

In the result, appeal filed by the assessee is partly allowed as indicated above

ITA 3851/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi12 Nov 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roysony India Private Limited, Vs. Acit, Circle 22 (2), A – 18, Mohan Cooperative Indl. Area, New Delhi. Mathura Road, New Delhi – 110 044. (Pan :Aabcs1571Q) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 23.09.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appealpreferred By The Assesseeis Directed Against The Assessment Order Dated 30.07.2024Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144Bof The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020- 21Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)

…ing stock and closing stock – on the basis of cost or realisable value, whichever is lower. 16 The aforesaid basis is well accepted for valuation of stock. The said basis was also noted by the Supreme Court in CIT v. Woodword Governor India (P.) Ltd.: (2009) 312 ITR 254. The learned counsel for the Revenue also does not dispute that if the aforesaid basis is followed consistently, the assessee’s income for the year would be fully captured as the element of profit would also not be included in the opening stock. 20. The finding of the Tribunal cannot be faulted. Clearly, no substantial question of law arises from…

Hyderabad Yadgiri Tollway Private Limited, Ahmedabad vs. The Pr.CIT-1, Ahmedabad

The appeal of the assessee is dismissed

ITA 1332/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 143Section 143(3)Section 263Section 43A

…THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH, AHMEDABAD BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER Assessment Year: 2018-19 Hyderabad Yadgiri Tollway Principal Commissioner of Private Limited, Income Tax-1, Sadbhav House, Aayakar Bhavan (Vejalpur), Opp. Law Garden Police Nr. Sachin Tower, Chowki, 100 Foot Road, Vs. Ellisbridge, Anandnagar-Prahladnagar Ahmedabad – 380 006. Road, (Gujarat). Ahmedabad – 380 015. [PAN – AACCH 3521 J] (Gujarat) (Appellant) (Respondent) Assessee by Shri Dhinal Shah, AR Revenue by Shri R. P. Rastogi, CIT-DR Date of Hearing 24.…