Distributors (Baroda) (P.) Ltd. v. Union of India

155 ITR 120Supreme Court of India1985#381 most cited

What is Distributors (Baroda) (P.) Ltd. v. Union of India authority for?

For computing the deduction under Section 80M, only the net dividend income (gross dividend income after reducing expenses attributable to earning it, as per Section 57(iii) and the principle in Section 80AB) is eligible. The case also holds that tax authorities are not bound to perpetuate an error from a previous assessment year, as each year is a separate unit and consistency cannot override substantive justice.

229

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

Distributors (Baroda) (P.) Ltd. v. Union of India · 155 ITR 120 · Section 80M deduction · net dividend income · expenses attributable to dividend · Section 80AB · Section 57(iii) · consistency principle · perpetuate error · assessment year separate unit · judicial conscience · dividend income

Issues it is cited on

Judgments citing Distributors (Baroda) (P.) Ltd. v. Union of India

CHANDER SHEIKHER SAINI,RUPNAGAR vs. INCOME TAX OFFICER, WARD-2(2), ROPAR

The appeal of the Assessee is partly allowed

ITA 769/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh13 Nov 2025AY 2016-17

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita No. 769/Chd/2023 "नधा"रण वष" / Assessment Year : 2016-17 Chander Shekher Saini, The Ito, C/P Shri Tej Mohan Singh, बना Ward 2(2), # 527, Sector 10D, Ropar म Chandigarh Vs. "थायी लेखा सं./Pan No: Acsps4233M अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Smt. Priyanka Dhar, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 10-11-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 13-11-2025 आदेश/Order This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Nfac, Dated 09.10.1023, For The Assessment Year 2016-17. 2. The Grounds Of Appeal Raised By The Assessee Are As Under: -

For Appellant: Sh. Tej Mohan Singh, AdvocateFor Respondent: Smt. Priyanka Dhar, Sr. DR
Section 10Section 154

…from High Courts (were available) require strict interpretation of exemption provisions. 8.3 The principle of consistency, though important, cannot override legal interpretation. As held by the Hon’ble Supreme Court in Distributors Baroda vs. Union of India (155 ITR 120), beneficial interpretation cannot be applied where statutory language is clear and unambiguous. 8.4 Furthermore, It is a settled principle of law that where the language of a statute is plain, clear, and unambiguous, the rule of literal interpretation must be applied. In such circumstances, neither the Tribunal nor the Court is empowered to leg…

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