M/S. Kamakhaya Oil Company, New Delhi vs. CIT, New Delhi
In the result, appeal of the assessee is dismissed
ITA 3030/DEL/2014[2009-10]Status: DisposedITAT Delhi21 Nov 2017AY 2009-10
Bench: Sh. Bhavnesh Saini & Sh. O.P. Kantassessment Year: 2009-10 M/S. Kamakhaya Oil Company, Vs. Cit, Delhi-X, New Delhi C/O- M/S. Rra Taxindia, D-28, South Extension, Part-I, New Delhi. Pan : Aahfk3040R (Appellant) (Respondent) Appellant By Sh. R.S. Singhvi, Ca Respondent By Sh. Vijay Verma, Cit(Dr) Date Of Hearing 07.11.2017 Date Of Pronouncement 21.11.2017 Order Per O.P. Kant, A.M.:
Section 143(2)Section 143(3)Section 263Section 80I
…ived from the industrial undertaking and there was no direct nexus between the interest income and the industrial activity carried out by the assessee. He placed reliance on following judgments: (i) In the case of India Leather Corporation P. Ltd. Vs CIT(SC) 227 ITR 552 it has been held that "The phrase "derived from" is different from "Attributable to" - It is no doubt true that the words 'attributable to' have a wider meaning than the words 'derived from' - But at the same time it cannot be ignored that normally the word 'attribute' implies that 'for a result to be attributable to anything' it must be wholly,…