Delhi Cold Storage (P) Ltd. v. CIT

191 ITR 656Supreme Court of India1991#11897 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2017 to 2024.

Also reported as

59 Taxmann 144
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Issues it is cited on

section 2(7)section 4(2)section 32ainitial assessment yearfull and true disclosurematerial facts necessary for assessmentsection 80ibkelvinatormere change of opinioneligible businesslive linkincome escaping assessment

Judgments citing Delhi Cold Storage (P) Ltd. v. CIT

Assisstant Commissioner of Income Tax - 4(1), Indore vs. Prataap Snacks Limited, Indore

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

ITA 374/IND/2023[2018-19]Status: DisposedITAT Indore17 Oct 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 80I

…processing. 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Assisstant Commissioner of Income Tax - 4(1), Indore vs. Prataap Snacks Limited, Indore

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

ITA 373/IND/2023[2020-21]Status: DisposedITAT Indore17 Oct 2024AY 2020-21

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 80I

…processing. 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Assisstant Commissioner of Income Tax - 4(1), Indore vs. Prataap Snacks Limited, Indore

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

ITA 372/IND/2023[2017-18]Status: DisposedITAT Indore17 Oct 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 80I

…processing. 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Assistant Commissioner of Income Tax - 4(1), Indore vs. Prataap Snacks Limited, Indore

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

ITA 371/IND/2023[2013-14]Status: DisposedITAT Indore17 Oct 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 80I

…processing. 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Assistant Commissioner of Income Tax - 4(1), Indore vs. Prataap Snacks Limited, Indore

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

ITA 370/IND/2023[2012-13]Status: DisposedITAT Indore17 Oct 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 80I

…processing. 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Manpasand Beverages Ltd., Vadodara vs. The Pr. CIT-2, Vadodara

In the result, the appeal is allowed

ITA 1209/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad24 Jun 2019AY 2013-14

Bench: Us Is Engaged In The Business Of Manufacturing & Processing Fruit Juices. The Assessment In This Case, Under Section 143(3), Was Completed On 28Th March 2016. Subsequently, However, The Assessment Records Came Up For Perusal By The Learned Principal

Section 143(3)Section 263Section 80I

…age 5 of 7 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

Manpasand Beverages Ltd., Vadodara vs. The Pr. CIT-2, Vadodara

In the result, the appeal is allowed

ITA 1208/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad24 Jun 2019AY 2012-13

Bench: Us Is Engaged In The Business Of Manufacturing & Processing Fruit Juices. The Assessment In This Case, Under Section 143(3), Was Completed On 28Th October, 2015. Subsequently, However, The Assessment Records Came Up For Perusal By The Learned Principal

Section 143(3)Section 263Section 80I

…age 5 of 7 7. The import of the expression 'processing' can be better understood by referring to the decisions of the Supreme Court interpreting the said expression occurring in the taxing enactments. In the case of Delhi Cold Storage (P.) Ltd. v. CIT [1991] 191 ITR 6561, the Supreme Court was concerned with the question whether the assessee-company running a cold storage could be held to be an industrial company for the purposes of section 2(7)(c) of the Finance Act, 1973. An industrial company has been defined to mean a company which is mainly engaged in the manufacture or processing of goods and other activit…

M/S Anubhuti Cold Chains Pvt. Ltd., Chandigarh vs. Pr. CIT 2, Chandigarh

In the result, the appeal of the assessee is dismissed

ITA 799/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh18 Jul 2018AY 2012-13

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Anubhuti Cold Chains Pvt. Ltd., Vs. The Principal Cit-2, Sco 363-364, 2Nd Floor, Sector 35-B, Chandigarh. Chandigarh. Pan: Aagca7238R (Appellant) (Respondent)

For Appellant: Shri Sahil ChadhaFor Respondent: Dr. Gulshan Raj, CIT DR
Section 143(3)Section 263Section 80Section 80I

…act. The Ld. Pr. CIT dismissed this contention of the assessee also stating that keeping goods in a cold storage did not tantamount to be a “process”. Ld. Pr. CIT referred to the decision of the apex court in the case of Delhi Cold Storage Pvt. Ltd vs CIT -191 ITR 656 (SC) in this regard. Ld. Pr. CIT therefore held that the assessee by no means could be said to be processing fruits & vegetables by merely storing them in a cold storage. Ld. Pr. CIT further stated that the AO had also not conducted proper enquiry into the claim of assessee u/s 80-IB (11A). He therefore held the assessment order passed by the…

Shri Kaila Devi Ice & Cold Storage, Agra vs. Income Tax Officer -4(4), Agra

In the result, the appeal is dismissed

ITA 4/AGR/2015[2009-10]Status: DisposedITAT Agra30 Nov 2017AY 2009-10

Bench: Shri A. D. Jain

Section 80Section 80I

…). The other requirements of the section are processing, preservation, packaging, handling, storage and transportation of food-grains, in the assessee’s case, potatoes. So far as regards the requirement of processing, in ‘Delhi Cold Storage (P) Ltd. vs. CIT’, 191 ITR 656 (SC), it has been held that storing of goods in a cold storage does not involve any processing because processing involves bringing into existence a substance different from what the material was at the time of commencement of the process; and that in case of storage of potatoes in a cold storage, what is stored in the cold storage is potato and…

Delhi Cold Storage (P) Ltd. v. CIT (191 ITR 656) — Cited in 9 Judgments | BharatTax