CWT v. Kripashankar Dayashankar Worah

81 ITR 763Supreme Court of India1971#18318 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2016 to 2022.

Issues it is cited on

depreciation on leased assetsstpi unitconvertible foreign exchangesection 194jtax benefitbusiness expediencysection 80ibicdssection 10aacomputer softwaresection 40(a)(i)section 10a

Judgments citing CWT v. Kripashankar Dayashankar Worah

M/S. Ibm India Private Limited, Bangalore vs. Asst. Commissioner of Income Tax, Bangalore

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

ITA 773/BANG/2016[2010-11]Status: DisposedITAT Bangalore18 Jul 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

…upon findings of coordinate bench of this (Tribunal) in assessee’s own case for assessment year 2008-09 (supra) wherein, Hon’ble Bench after analysing various rulings of Hon’ble Supreme Court in case of CWT vs Kripashankar Dayashankar Worah reported in (1971) 81 ITR 763, Philip John Plasket Thomas vs CIT reported in (1963) 49 ITR 97 and Smt. Tarulata Shyamvs CIT reported in (1977) 108 ITR 345, Hon’ble Karnataka High Court in case of CIT vs Fusion Software Engineering Pvt. Ltd., reported in (2012) 18 Taxmann.com 57 observed as under: “3.77. Apart from the above, we find that that this issue has already been concl…

M/S.Ibm India Private Limited, Bangalore vs. Assistant Commissioner of Income-Tax, Bangalore

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

ITA 2041/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Jul 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

…upon findings of coordinate bench of this (Tribunal) in assessee’s own case for assessment year 2008-09 (supra) wherein, Hon’ble Bench after analysing various rulings of Hon’ble Supreme Court in case of CWT vs Kripashankar Dayashankar Worah reported in (1971) 81 ITR 763, Philip John Plasket Thomas vs CIT reported in (1963) 49 ITR 97 and Smt. Tarulata Shyamvs CIT reported in (1977) 108 ITR 345, Hon’ble Karnataka High Court in case of CIT vs Fusion Software Engineering Pvt. Ltd., reported in (2012) 18 Taxmann.com 57 observed as under: “3.77. Apart from the above, we find that that this issue has already been concl…

DCIT, Bangalore vs. M/S Ibm India (P) Limited, Bangalore

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

ITA 1228/BANG/2016[2010-11]Status: DisposedITAT Bangalore18 Jul 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

…upon findings of coordinate bench of this (Tribunal) in assessee’s own case for assessment year 2008-09 (supra) wherein, Hon’ble Bench after analysing various rulings of Hon’ble Supreme Court in case of CWT vs Kripashankar Dayashankar Worah reported in (1971) 81 ITR 763, Philip John Plasket Thomas vs CIT reported in (1963) 49 ITR 97 and Smt. Tarulata Shyamvs CIT reported in (1977) 108 ITR 345, Hon’ble Karnataka High Court in case of CIT vs Fusion Software Engineering Pvt. Ltd., reported in (2012) 18 Taxmann.com 57 observed as under: “3.77. Apart from the above, we find that that this issue has already been concl…

M/S. Ibm India Pvt. Ltd., Bengaluru vs. Assistant Commissioner of Income-Tax, Circle-4(1)(2), Bengaluru

In the result appeal filed by assessee stands partly allowed

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

…upon findings of coordinate bench of this (Tribunal) in assessee’s own case for assessment year 2008-09 (supra) wherein, Hon’ble Bench after analysing various rulings of Hon’ble Supreme Court in case of CWT vs Kripashankar Dayashankar Worah reported in (1971) 81 ITR 763, Philip John Plasket Thomas vs CIT reported in (1963) 49 ITR 97 and Smt. Tarulata Shyam vs CIT reported in (1977) 108 ITR 345, Hon’ble Karnataka High Court in case of CIT vs Fusion Software Engineering Pvt. Ltd., reported in (2012) 18 Taxmann.com 57 observed as under: “3.77. Apart from the above, we find that that this issue has already been conc…

Mrs. Sharon Nayak, Bangalore vs. DCIT, Bangalore

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 1594/BANG/2014[2008-09]Status: DisposedITAT Bangalore27 May 2016AY 2008-09

Bench: Shri. Sunil Kumar Yadav & Shri. Abraham P. Georgei.T.A No.1594/Bang/2014 (Assessment Year : 2008-09) Mrs. Sharon Nayak, 203, Inland Exotic Apt, 14, Benson Road, Bangalore 560 046 .. Appellant Pan : Abkpn7007P V. Deputy Commissioner Of Income-Tax, Circle – 5(1), Bangalore .. Respondent Assessee By : Shri. S. Ramasubramaniyan, Ca Revenue By : Dr. P. K. Srihari, Addl. Cit Heard On : 05.05.2016 Pronounced On : 27.05.2016 O R D E R Per Abraham P. George:

For Appellant: Shri. S. Ramasubramaniyan, CAFor Respondent: Dr. P. K. Srihari, Addl. CIT
Section 161Section 17(3)Section 56Section 56(2)(i)Section 56(2)(vi)

…extent as it would be made on such fictional beneficiary. In this case too it was the beneficial interest which was assessed to wealth-tax in the hands of the trustee. It may be added that this court in the case of CWT v. Kirpashankar Dayashanker Worah [1971] 81 ITR 763 (SC), has held that section 21(1) of the Wealth-tax Act, 1957, was analogous to section 41(1) of the 1922 Act, the only difference being that whereas the former dealt with assets, the latter dealt with income and, subject to this difference, the two provisions were identically worded. Hence, the decisions rendered under section 41(1) of the 1922 A…

CWT v. Kripashankar Dayashankar Worah (81 ITR 763) — Cited in 5 Judgments | BharatTax