Goodyear v. State of Haryana

188 ITR 402Supreme Court of India1991#1197 most cited

What is Goodyear v. State of Haryana authority for?

A reasonable construction of a taxing statute should be followed, and a literal construction should be avoided if it defeats the manifest purpose and object of the Act.

94

judgments rely on this decision, according to BharatTax’s citation analysis of 366,406 Indian tax judgments — from 2015 to 2025.

Also referred to as

Goodyear India Ltd. v. State of Haryana · 188 ITR 402 · reasonable construction · literal construction · taxing statute · manifest purpose and object · Income Tax Act

Sections most often in play

Section 1961Section 147 of the Income Tax ActSection 148 of the Income Tax ActSection 194CSection 234BSection 234B of the Income Tax ActSection 234CSection 234C of the Income Tax Act

Issues it is cited on

bright line testamp expenditurecomparable uncontrolled price methodsection 92(1)cost plus methodfunctional analysissection 80jjasection 80jjaasection 92fsection 92c(3)management feessection 55

Judgments citing Goodyear v. State of Haryana

Lg Electronics India Private Limited, Mathura Road, New Delhi vs. Deputy Commissioner of Income Tax, Delhi

In the result, the appeal of the revenue in ITA No

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

Lg Electronics India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Delhi

In the result, the appeal of the revenue in ITA No

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

DCIT, Circle-13(1), New Delhi vs. Lg Electronics India Pvt. Ltd., Delhi

In the result, the appeal of the revenue in ITA No

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

DCIT, Circle-15(2), New Delhi vs. Lg Electronics India Pvt. Ltd., New Delhi

In the result, the appeal of the revenue in ITA No

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

Lg Electronics India Pvt. Ltd., New Delhi vs. DCIT, Circle-15(2), New Delhi

In the result, the appeal of the revenue in ITA No

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

Lg Electronics India Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 5, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

Lg Electronics India Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 5, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

M/S Lg Electronics India Pvt. Ltd., New Delhi vs. DCIT, Noida

In the result, the appeal of the revenue in ITA No

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

DCIT, Noida vs. M/S. L.G. Electronics India Pvt. Ltd., Greater Noida

In the result, the appeal of the revenue in ITA No

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

…we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: ―In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

Dy. Commissioner of Income Tax, Central Circle-2(2), Hyderabad vs. Sew Infrastructure Limited, Hyderabad

ITA 1717/HYD/2017[2009-10]Status: HeardITAT Hyderabad07 Oct 2024AY 2009-10

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

For Appellant: Shri K.K. ChaitanyaFor Respondent: Smt. Mamata Choudhary
Section 132Section 139(1)Section 143(3)Section 147Section 153ASection 80I

…mile Construction Co. (P.) Ltd. [2012] 143 TTJ 322 (Mumbai)  KNR Constructions Vs. DIT IT Appeal Nos.946 to 948 and 983 to 986/Hyd/2015, dated 16-102015  Malpani Estates Vs. Asst. CIT [2014] 64SOT 105 (Pune)  Goodyear India Ltd. Vs. State of Haryana [19891 188 ITR 402 (SC)  Mavilayi Service Co-operative Bank Ltd. Vs. CIT [2021] 431 ITR 1 (SC)  Government of Kerala Vs. Mother Superior Adoration Convent [2021] 126 taxmann.com 68 (SC)  V Jaganmohan Rao Vs. CIT/EPT (1970) 75 ITR 373 (SC)  ITO Vs. Mewalal Dwarka Prasad [1989] 176 ITR 529 (SC) 14. The learned Counsel for the assessee further referring to the de…

Nabhiraj Ratna Balraj by Legal Heir B.R.Rakesh, Bangalore vs. Income-Tax Officer, Ward-7(2)(1), Bangalore

In the result the appeal of the assessee is allowed

ITA 603/BANG/2024[2016-17]Status: DisposedITAT Bangalore26 Jun 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Ms. Suman Lunkar, CAFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 234BSection 50C

…n. Apex Court has followed reasonable construction instead of strict interpretation in the following cases:- 1. R.B. Jodha Mal Kuthiala vs. CIT 82 ITR 570 (SC) [1971] 2. CIT vs. J.H. Gotla 156 I.T.R. 323(SC) [1985] 3. Good Year India Ltd. vs. State of Haryana 188 ITR 402 SC [1991] e) In CIT v. Calcutta Export Company (SC) (2018) 93 taxmann.com 51. The issue before the Hon. Apex Court was whether the amendment to sec 40(a)(ia) by Finance Act 2010 can be considered to be retrospective in nature. The hon. Apex Court after considering the relevant schema of Section 40(a)(ia) & taking into consideration the purpose o…

Kalasa Lakshmanashetty Mahesh, Chikkamagaluru vs. Income Tax Officer, Income Tax

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 792/BANG/2024[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Manish Golyan, CA
Section 250

…ce without sufficient cause or justification constitutes an abuse of discretion. Such actions undermine the integrity of the appellate process and erode public trust in the administration of justice. Case Laws in Support: 1. Goodyear India Ltd. vs. CIT (1991) 188 ITR 402 (SC): The Supreme Court emphasized that the principles of natural justice require that both parties be given an. adequate opportunity to present their case and rebut the evidence against them. Any departure from this fundamental principle would vitiate the proceedings. 2. The Hon’ble Supreme Court in the case of Collector Land Katji, 167 ITR 471…

State Bank of India, Thalassery( Erstwhile State Bank of Travancore), Kannur vs. ITO (TDS), Kannur

In the result, the assessee’s appeal is allowed on the aforesaid terms

ITA 926/COCH/2022[2014-15]Status: DisposedITAT Cochin31 May 2024AY 2014-15

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopalstate Bank Of India (Erstwhile Sbt) Income Tax Officer-Tds Thalassery Branch Aayakar Bhavan Gundert Road Vs. Konnothumchal Thalassery 670101 Chovva P.O., Kannur 670006 [Pan: Aaacs8577K] (Appellant) (Respondent)

For Appellant: Shri A. Kumar, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 10(5)Section 12Section 192Section 201Section 286

…by the assessee under abeyance with a view to balance the interest of both the sides. The question of the taxability of LTC was not in issue. A decision is an authority for what it actually decides (viz. Goodyear India Ltd. vs. State of Haryana & Anr. [1991] 188 ITR 402 (SC); Mavilayi Service Cooperative Bank Ltd. & Ors. v. CIT [2021] 431 ITR 1 (SC)). 4.2 The order of the Hon'ble High Court is thus in the nature of a compromise arrangement, arrived at under it’s aegis. Nothing more and, nothing less. There is no estoppel against law, which in the instant case, the Income Tax Law, is a public law. Rather, even i…

Sky Gem, Mumbai vs. DCIT, CC-1(1), Mumbai

ITA 787/MUM/2023[2010-11]Status: DisposedITAT Mumbai23 Aug 2023AY 2010-11
For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri Paresh Deshpande
Section 143(1)Section 143(3)Section 147Section 148Section 68

…enue holding that no question of law arose in the said appeal. It is well-settled that a precedent is an authority only for what it actually decides and not for what may remotely or even logically follow from it [Goodyear India Ltd. v. State of Haryana [1991] 188 ITR 402 (SC)]. Therefore, we conclude that reliance placed by Appellant on the judgment of the Hon’ble Bombay High Court in the case of Mohommad Haji Adam & Co (supra) as regards computation of profit element embedded in purchases made from grey market is misplaced. Accordingly, we reject the contention of the Appellant ITA No.787-790/Mum/2023 (Assessm…

Shri Hingulambika Education Society, Gulbarga vs. ITO (Exemptions), Ward-1, Kalburgi

In the result, appeal of the assessee is allowed

ITA 1126/BANG/2022[2020-21]Status: DisposedITAT Bangalore22 Jun 2023AY 2020-21

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2020-21

For Appellant: Shri Phalguna Kumar, A.RFor Respondent: Shri Shahnawaz Ul Rahman, D.R
Section 11Section 12ASection 12A(2)Section 143(1)Section 154Section 250

…he SOCIETY/TRUST shall regularly file its Income Tax Return." 3. Allied Motors (P) Ltd. ETC. vs. Commissioner of Income Tax, (1997) 224 ITR 0677, wherein it has been observed as under:- "In the case of Goodyear India Ltd. v. State of Haryana and Anr. [1991] 188 ITR 402 (SC) this Court said that the rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge Learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes hav…

Assistant Commissioner of Income Tax, Central Circle-2, Surat vs. M/S Hi-Tech Sweet Water Technologies(P) Ltd., Surat

In the result, appeal filed by the Revenue is dismissed

ITA 230/SRT/2022[2019-20]Status: DisposedITAT Surat30 Jan 2023AY 2019-20

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.230/Srt/2022 "नधा"रण वष"/Assessment Year: (2019-20) (Physical Court Hearing) Assistant Commissioner Of M/S Hi-Tech Sweet Water Income-Tax, Central Circle-2, Technologies (P.) Ltd., 5Th Room No.505, Floor, Vs. 4, Gopal Nagar, Nandeda Char Aayakar Bhawan, Majura Gate, Rasta, Gidc, Bardoli–394601 Surat-395001 (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaach7432C िनधा"रती क" ओर से Assessee By Shri Kiran K. Shah, Ca राज"व क" ओर से /Respondent By Shri Vinod Kumar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 घोषणा क" तारीख/Date Of Pronouncement 30/01/2023

Section 143(1)Section 143(3)Section 250(4)Section 80I

…nly to taxing provisions such as a charging provision or a provision imposing penalty and not to those parts of the statute which contain machinery provisions." In the case of Goodyear India Ltd. v. State of Haryana and other group matters, reported in [1991] 188 ITR 402, the Supreme Court once again considered this question and, speaking through Sabyasachi Mukharji. (as he then was), made the following pertinent observations (headnote): "It is well-settled that a reasonable construction of the taxing statute should be followed and literal construction may be avoided if that defeats the manifest purpose and objec…

Pr Commissioner of Income Tax vs. The Kangra Central Cooperative Bank Ltd

The appeals are dismissed

ITA/82/2018HC Himachal Pradesh07 Dec 2022

Bench: HON'BLE MRS. JUSTICE SABINA,HON'BLE MR. JUSTICE SUSHIL KUKREJA

Section 145Section 36Section 43D

…11 April 1, 1984. In these References and appeals we are concerned with the application of Section 43B as it stood before the provisos were added. xxx xxx xxx In the case of Goodyear India Ltd. v. State of Haryana and Anr. (1991) 188 ITR 402, this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember th…

Pr Commissioner of Income Tax vs. The Kangra Central Cooperative Bank Ltd

The appeals are dismissed

ITA/83/2018HC Himachal Pradesh07 Dec 2022

Bench: HON'BLE MRS. JUSTICE SABINA,HON'BLE MR. JUSTICE SUSHIL KUKREJA

Section 145Section 36Section 43D

…11 April 1, 1984. In these References and appeals we are concerned with the application of Section 43B as it stood before the provisos were added. xxx xxx xxx In the case of Goodyear India Ltd. v. State of Haryana and Anr. (1991) 188 ITR 402, this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember th…

Mayur Uniquoters Limited, Jaipur vs. Commissioner of Income Tax NFAC, New Delhi

Appeals of the assesse are disposed of in the terms indicated as above

ITA 2/JPR/2022[2018-19]Status: DisposedITAT Jaipur09 Nov 2022AY 2018-19
For Appellant: Shri S. S. Nagar, C.AFor Respondent: MonishaChoudhary, JCIT
Section 14ASection 234CSection 80Section 80J

…, we draw support from the judgment of the Hon'bleSupreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: “In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that the rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well-known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have so…

M/S Assetz Infrastructure Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-1(1)(1), Bangalore

In the result, the grounds 3

ITA 563/BANG/2019[2014-15]Status: DisposedITAT Bangalore23 Mar 2022AY 2014-15

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2014-15

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Smt. Priyadarshini Besaganni, D.R
Section 2(22)(e)

…n the context of accrual of income u/s 5 of the Income tax Act and not in the context of “accumulated profits” defined u/s 2(22)(e) of the Act. He submitted that the Hon’ble Supreme Court has held in the case of Good year India Ltd Vs. State of Haryana (1991)(188 ITR 402) M/s. Assetz Infrastructure Pvt. Ltd., Bangalore Page 10 of 15 that a decision is an authority only for what it decides and not for what may remotely or even logically follow. Hence a decision on a question not argued cannot be treated as a precedent. Accordingly, the Ld A.R contended that the decision rendered by Hon’ble Supreme Court in the ca…