Hero Cycles Pvt. Ltd. v. CIT

379 ITR 347Supreme Court of India2015#208 most cited

What is Hero Cycles Pvt. Ltd. v. CIT authority for?

The Revenue cannot substitute its judgment for that of a businessman regarding the necessity or reasonableness of an expenditure. If an expense is incurred wholly and exclusively for business purposes, it is deductible, and the Revenue cannot question its commercial expediency.

361

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2011 to 2026.

Also referred to as

Hero Cycles Pvt. Ltd. v. CIT · 379 ITR 347 · 16 SCC 359 · Section 36(1)(iii) · commercial expediency · business expediency · disallowance of expenditure · interest-free advances · corporate guarantee · wholly and exclusively for business · Revenue's armchair approach · sales promotion expenditure

Also reported as

16 SCC 359

Sections most often in play

Section 143(3)Section 36(1)(iii)Section 147Section 1961Section 143(2)Section 14ASection 132Section 142(1)
Read the full judgment

Issues it is cited on

interest free advancescommercial expediencysection 36(1)(iii)corporate guaranteebusiness expediencysection 36book profitssection 36(1)arm's length pricetransfer pricing adjustmentassociated enterprisessection 92c

Judgments citing Hero Cycles Pvt. Ltd. v. CIT

Commissioner of Income Tax VIII vs. Gopal Dass Estates & Housing Pvt.Ltd

Appeals of the Revenue are dismissed

ITA - 742 / 2009HC Delhi20 Mar 2019
Section 260

…ee advances were given to the associate companies for the purposes of Assessee‟s business. 70. The Assessee‟s case appears to be supported by the decisions in SA Builders v. CIT (2007) 288 ITR 1 (SC) which has been followed in Hero Cycles v. CIT (2015) 379 ITR 347. The ratio of the decision of the Bombay High Court in CIT v. Lokhandwala Constructions Industries Ltd. (2003) 260 ITR 579 (Bom) was rightly relied upon by the ITAT to allow the plea of the Assessee and treat the said interest payments as revenue expenditure. As explained in CIT v. Bombay Samachar Ltd. (1969) 74 ITR 723 (Bom) and this Court…

Commissioner of Income Tax vs. Gopal Dass Estates & Housing Pvt.Ltd

Appeals of the Revenue are dismissed

ITA - 548 / 2010HC Delhi20 Mar 2019
Section 260

…ee advances were given to the associate companies for the purposes of Assessee‟s business. 70. The Assessee‟s case appears to be supported by the decisions in SA Builders v. CIT (2007) 288 ITR 1 (SC) which has been followed in Hero Cycles v. CIT (2015) 379 ITR 347. The ratio of the decision of the Bombay High Court in CIT v. Lokhandwala Constructions Industries Ltd. (2003) 260 ITR 579 (Bom) was rightly relied upon by the ITAT to allow the plea of the Assessee and treat the said interest payments as revenue expenditure. As explained in CIT v. Bombay Samachar Ltd. (1969) 74 ITR 723 (Bom) and this Court…

The Commissioner of Income Tax vs. Gopal Dass Estates & Housing Pvt.Ltd

Appeals of the Revenue are dismissed

ITA - 400 / 2009HC Delhi20 Mar 2019
Section 260

…ee advances were given to the associate companies for the purposes of Assessee‟s business. 70. The Assessee‟s case appears to be supported by the decisions in SA Builders v. CIT (2007) 288 ITR 1 (SC) which has been followed in Hero Cycles v. CIT (2015) 379 ITR 347. The ratio of the decision of the Bombay High Court in CIT v. Lokhandwala Constructions Industries Ltd. (2003) 260 ITR 579 (Bom) was rightly relied upon by the ITAT to allow the plea of the Assessee and treat the said interest payments as revenue expenditure. As explained in CIT v. Bombay Samachar Ltd. (1969) 74 ITR 723 (Bom) and this Court…

Commissioner of Income Tax vs. Gopal Dass Estates & Housing Pvt.Ltd

Appeals of the Revenue are dismissed

ITA - 581 / 2010HC Delhi20 Mar 2019
Section 260

…ee advances were given to the associate companies for the purposes of Assessee‟s business. 70. The Assessee‟s case appears to be supported by the decisions in SA Builders v. CIT (2007) 288 ITR 1 (SC) which has been followed in Hero Cycles v. CIT (2015) 379 ITR 347. The ratio of the decision of the Bombay High Court in CIT v. Lokhandwala Constructions Industries Ltd. (2003) 260 ITR 579 (Bom) was rightly relied upon by the ITAT to allow the plea of the Assessee and treat the said interest payments as revenue expenditure. As explained in CIT v. Bombay Samachar Ltd. (1969) 74 ITR 723 (Bom) and this Court…

ACIT, Chandigarh vs. M/S A.B. Sugars Ltd., Chandigarh

In the result, there is no merit in the appeal of the Revenue and the same is accordingly dismissed

ITA 1051/CHANDI/2018[2011-12]Status: DisposedITAT Chandigarh21 Feb 2019AY 2011-12

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 1051/Chd/2018 "नधा"रण वष" / Assessment Year : 2011-12 The Dcit, M/S A.B. Sugars Ltd., बनाम Circle 1(1), (Formerly Known As M/S Guru Chandigarh Teg Bahadur Sugar Ltd.,) H.No. 77,Sector 11-A, Chandigarh "थायी लेखा सं./Pan No: Aabcg3045M अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri T.N. Singla, CAFor Respondent: Sh. Sandeep Dahiya, CA
Section 14ASection 36Section 36(1)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, “ए”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’, CHANDIGARH "ी संजय गग", "या"यक सद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 1051/CHD/2018 "नधा"रण वष" / Assessment Year : 2011-12 The DCIT, M/s A.B. Sugars ltd., बनाम Circle 1(1), (formerly known as M/s Guru Chandigarh Teg Bahadur Sugar Ltd.,) H.No. 77,Sector 11-A, Chandigarh "थायी लेखा सं./PAN No: AABCG3045M अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri T.N. Singla, CA राज"व क" ओ…

The Assistant Commissioner of Income Tax, Pathankot vs. M/S Walia Construction Co., Pathankot

In the result, the appeal filed by the Revenue Department stands dismissed

ITA 499/ASR/2015[2010-11]Status: DisposedITAT Amritsar14 Feb 2019AY 2010-11

Bench: Sh. N.S.Saini & Sh. N.K.Choudhryita No.499(Asr)/2015 Assessment Year:2010-11

For Appellant: Sh. Ashwani Kalia (Ld. CA)For Respondent: Sh. Bhawani Shankar (Ld. DR)
Section 133ASection 143(1)Section 250(6)

…claimed in P&L account can be made, deleted the addition under hand. In fact the decision in CIT vs. Abhishek Industries (supra) of the jurisdictional High Court has already been over ruled by the Apex Court in the case of M/s. Hero Cycle Ltd. vs. CIT [2015] 379 ITR 347 (SC), hence in our considered view, the Ld CIT(A) rightly deleted the disallowance under consideration i.e. interest amount of Rs. 11,25,110/- and therefore we sustain deletion. 8. Now coming to the deletion of addition of Rs.7,17,640/- the Ld. CIT(A) while taking into consideration the facts that both the lady partners were actively involved in…

DCIT, New Delhi vs. M/S. Albasta Wholesale Services Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 6546/DEL/2015[2011-12]Status: DisposedITAT Delhi04 Feb 2019AY 2011-12

Bench: Shri Before Shri G.D. Agrawal, Before Shri Before Shri G.D. Agrawal, G.D. Agrawal, Vice G.D. Agrawal, Vice & And & Ms. Suchitra Kamble Ms. Suchitra Kamblems. Suchitra Kamble Ms. Suchitra Kamble

For Appellant: Ms. Paramita M. Biswas, CIT-DRFor Respondent: Shri Gautam Jain, Advocate &
Section 14Section 28Section 37

…of advance was for the purpose of assessee’s business. In support of this contention, he relied upon the decision of Hon’ble Apex Court in the case of S.A. Builders Ltd. Vs. CIT(A) and Another – [2007] 288 ITR 1 (SC). (i) Hero Cycles P.Ltd. Vs. CIT – [2015] 379 ITR 347 (SC). (ii) CIT Vs. Modi Entertainment Ltd. – [2014] 89 CCH 0014 (Del). 6 ITA-6546/Del/2015 He, therefore, stated that the order of learned CIT(A) should be sustained and Revenue’s appeal may be dismissed. 6. In the rejoinder, it is stated by the learned CIT-DR that the appeal for assessment year 2010-11 was not filed because of low tax effect…

Ashok Kumar & Co. Mercantile Pvt. Ltd., Ludhiana vs. ACIT, C-VII, Ludhiana

In the result, appeal of the assessee is allowed for

ITA 1003/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh18 Jan 2019AY 2014-15

Bench: The Due Date Of Filing Of Return I.E. On 29.11.2014. Hence, No Interest U/S 234A Can Be Levied. Iv) That The Appellant Craves To Amend, Alter, Change Any Of The Ground(S) Of Appeal. 3. A Perusal Of The Grounds Of Appeal Shows That The Main Grievance Of The Assessee Is Against The Confirmation Of Disallowance Of Interest Amounting To Rs. 7,01,500/-. The

For Appellant: Shri Ashok Kumar JunejaFor Respondent: Shri Manjit Singh, Sr.DR
Section 234ASection 36(1)(iii)

…the assessee did not use the borrowed funds for the same. That the aforesaid investment was made out of own funds of the assessee. Reliance has also been placed on the decision of the Hon'ble Supreme Court in the case of Hero Cycles (P) Ltd. Vs CIT (2015) 63 Taxmann 308 (S.C) 6. The ld. DR has submitted that the assessee could not bring reliable evidence before the lower authorities to prove that there was any business expediency for the aforesaid investment made in the shares of sister concern and further that the assessee had used its own/surplus funds for making the aforesaid investment. ITA-1003/CHD…

M/S Morani Cars Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-6, Jaipur

In the result, the addition so made by the AO is hereby set- aside

ITA 1088/JPR/2018[2010-11]Status: DisposedITAT Jaipur09 Jan 2019AY 2010-11
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri P.P. Meena (JCIT) a
Section 40Section 40A(2)

…, when interest free funds are more than the interest free security deposit, no disallowance out of 9 M/s Morani Cars Pvt. Ltd. vs. ACIT interest can be made. In support, reliance was placed on the following decisions:- • Hero Cycles Pvt. Ltd. Vs. CIT (2016) 379 ITR 347/ 236 Taxman 447 (SC) • CIT Vs. Ram KishanVerma(2016) 132 DTR 107 (Raj) • CIT Vs. Vijay Solvex Ltd. (2015) 113 DTR 382 (Raj) • CIT Vs. Reliance Utilities & Power Ltd. 313 ITR 340 (Bom) 16. The ld. DR is heard who has relied on the findings of the lower authorities. 17. We have heard the rival contentions and perused the material available on…

Assistant Commissioner of Income Tax, Circle-1, Kota vs. M/S Shree Agencies Pvt. Ltd., Kota

In the result, the ground of appeal is allowed for statistical purposes

ITA 949/JPR/2018[2010-11]Status: DisposedITAT Jaipur01 Jan 2019AY 2010-11
For Appellant: Shri P. C. Parwal (CA)For Respondent: Shri Ran Singh (Addl.CIT) fu/kZkfjrh dh vksj ls@
Section 14ASection 36(1)(iii)

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE-B, JAIPUR Jh fot; iky jko] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 949/JP/2018 fu/kZkj.k o"kZ@Assessment Year :2010-11 cuke Asstt. Commissioner of M/s Shree Agencies Pvt. Vs. Income-tax Ltd., Circle-1, B-45, I.P.I.A. Jhalawar Kota Road, Kota LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAFCS3329A vihykFkhZ@Appellant izR;FkhZ@Respondent jktLo dh vksj ls@ Revenue by : Shri Ran Singh (Addl.CIT) fu/kZkfjrh dh vksj ls@ Assessee b…

Zuberi Engineering Company, Jaipur vs. Deputy Commissioner of Income Tax, Circle-2, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 979/JPR/2018[2014-15]Status: DisposedITAT Jaipur18 Dec 2018AY 2014-15
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…en no disallowance can be ITA 977 to 979/JP/2018 & 1122/JP/2018_ 68 Zuberi Engineering Vs DCIT. made on account of interest. In support of his contention, he has relied upon the decision of the Hon'ble Supreme Court in the case of Hero Cycles P Ltd. Vs CIT 379 ITR 347. Thus, the ld AR has submitted that when no new loan or advance was given during the year under consideration except for three days then the disallowance made by the Assessing Officer is not justified. He has further pointed out that the assessee has also explained that the assessee is having interest free loan of Rs. 16.5 crores taken from M/s…

Zuberi Engineering Company, Jaipur vs. Deputy Commissioner of Income Tax, Circle-2, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 978/JPR/2018[2013-14]Status: DisposedITAT Jaipur18 Dec 2018AY 2013-14
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…en no disallowance can be ITA 977 to 979/JP/2018 & 1122/JP/2018_ 68 Zuberi Engineering Vs DCIT. made on account of interest. In support of his contention, he has relied upon the decision of the Hon'ble Supreme Court in the case of Hero Cycles P Ltd. Vs CIT 379 ITR 347. Thus, the ld AR has submitted that when no new loan or advance was given during the year under consideration except for three days then the disallowance made by the Assessing Officer is not justified. He has further pointed out that the assessee has also explained that the assessee is having interest free loan of Rs. 16.5 crores taken from M/s…

Zuberi Engineering Company, Jaipur vs. DCIT, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 977/JPR/2018[2012-13]Status: DisposedITAT Jaipur18 Dec 2018AY 2012-13
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…en no disallowance can be ITA 977 to 979/JP/2018 & 1122/JP/2018_ 68 Zuberi Engineering Vs DCIT. made on account of interest. In support of his contention, he has relied upon the decision of the Hon'ble Supreme Court in the case of Hero Cycles P Ltd. Vs CIT 379 ITR 347. Thus, the ld AR has submitted that when no new loan or advance was given during the year under consideration except for three days then the disallowance made by the Assessing Officer is not justified. He has further pointed out that the assessee has also explained that the assessee is having interest free loan of Rs. 16.5 crores taken from M/s…

Assistant Commissioner of Income Tax, Circle-2, Jaipur vs. Zuberi Engineering Company, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 1122/JPR/2018[2012-13]Status: DisposedITAT Jaipur18 Dec 2018AY 2012-13
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…en no disallowance can be ITA 977 to 979/JP/2018 & 1122/JP/2018_ 68 Zuberi Engineering Vs DCIT. made on account of interest. In support of his contention, he has relied upon the decision of the Hon'ble Supreme Court in the case of Hero Cycles P Ltd. Vs CIT 379 ITR 347. Thus, the ld AR has submitted that when no new loan or advance was given during the year under consideration except for three days then the disallowance made by the Assessing Officer is not justified. He has further pointed out that the assessee has also explained that the assessee is having interest free loan of Rs. 16.5 crores taken from M/s…

ACIT Non Corporate Circle 1(10, Chennai vs. C.Subba Reddy (HUF), Chennai

In the result the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 1464/CHNY/2018[2014-15]Status: DisposedITAT Chennai14 Dec 2018AY 2014-15

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.1079/Chny/2018 (िनधा"रण वष" / Assessment Year: 2013-14) Vs The Acit, M/S. C. Subba Reddy (Huf), Sukriti No, 19/1, Iii Cross Street, Non Corporate Circle 1(1) R.A. Puram, Formerly Known As Business Circle-1, Chennai – 600 028. Chennai Pan: Aachc2523G (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./I.T.A.No.1464/Chny/2018 (िनधा"रण वष" / Assessment Year: 2014-15) Vs M/S. C. Subba Reddy (Huf), The Acit, Non Corporate Circle 1(1) Sukriti No, 19/1, Iii Cross Formerly Known As Business Circle-1, Street, R.A. Puram, Chennai Chennai – 600 028. Pan: Aachc2523G (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती की ओर से /Assessee By : Shri A.S. Sriraman, Advocate राज"व क" ओर से /Revenue By : Dr.S. Pandian, Jcit

For Appellant: Shri A.S. Sriraman, AdvocateFor Respondent: Dr.S. Pandian, JCIT
Section 14Section 143(2)Section 143(3)Section 14ASection 250(6)

…fore there was a business and commercial nexus for the loan advanced by the assessee. Reliance was placed in the decision of the Hon’ble Apex Court in the case M/s. SA Builders Pvt. Ltd., reported in 288 ITR 0001 and Hero Cycles Pvt. Ltd., vs. CIT reported in 379 ITR 347.. Hence it was pleaded that the addition made by the Ld.AO which was further sustained by the Ld.CIT(A) may be deleted. 6.3 We have heard the rival submissions and carefully perused the material on record. From the facts of the case it is obvious that the assessee has extended interest free loan to its own concern M/s. Ceebros Hotels out of its…

M/S C Subba Reddy (HUF), Chennai vs. ACIT Non Corporate Circle 1, Chennai

In the result the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 1079/CHNY/2018[2014-15]Status: DisposedITAT Chennai14 Dec 2018AY 2014-15

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.1079/Chny/2018 (िनधा"रण वष" / Assessment Year: 2013-14) Vs The Acit, M/S. C. Subba Reddy (Huf), Sukriti No, 19/1, Iii Cross Street, Non Corporate Circle 1(1) R.A. Puram, Formerly Known As Business Circle-1, Chennai – 600 028. Chennai Pan: Aachc2523G (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./I.T.A.No.1464/Chny/2018 (िनधा"रण वष" / Assessment Year: 2014-15) Vs M/S. C. Subba Reddy (Huf), The Acit, Non Corporate Circle 1(1) Sukriti No, 19/1, Iii Cross Formerly Known As Business Circle-1, Street, R.A. Puram, Chennai Chennai – 600 028. Pan: Aachc2523G (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती की ओर से /Assessee By : Shri A.S. Sriraman, Advocate राज"व क" ओर से /Revenue By : Dr.S. Pandian, Jcit

For Appellant: Shri A.S. Sriraman, AdvocateFor Respondent: Dr.S. Pandian, JCIT
Section 14Section 143(2)Section 143(3)Section 14ASection 250(6)

…fore there was a business and commercial nexus for the loan advanced by the assessee. Reliance was placed in the decision of the Hon’ble Apex Court in the case M/s. SA Builders Pvt. Ltd., reported in 288 ITR 0001 and Hero Cycles Pvt. Ltd., vs. CIT reported in 379 ITR 347.. Hence it was pleaded that the addition made by the Ld.AO which was further sustained by the Ld.CIT(A) may be deleted. 6.3 We have heard the rival submissions and carefully perused the material on record. From the facts of the case it is obvious that the assessee has extended interest free loan to its own concern M/s. Ceebros Hotels out of its…

DCIT, C-1, Ludhiana vs. M/S Majestic Auto Limited, Ludhiana

ITA 804/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh13 Dec 2018AY 2014-15

Bench: Shri Sanjay Garg & Dr. B.R.R.Kumarआयकर अपील सं./ Ita No. 406/Chd/2018 "नधा"रण वष" / Assessment Year : 2012-13 The Dcit, Circle-1 Vs. M/S Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./Pan No: Aabcm2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal Against The Order Of Cit(A)-1,Ludhiana Dated 24.01.2018

For Appellant: Sh Subhash Aggarwal, AdvocateFor Respondent: Sh. Manjit Singh, Sr.DR
Section 36(1)(iii)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, “बी”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’, CHANDIGARH "ी संजय गग", "या"यक सद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Dr. B.R.R.KUMAR, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 406/CHD/2018 "नधा"रण वष" / Assessment Year : 2012-13 The DCIT, Circle-1 Vs. M/s Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./PAN NO: AABCM2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal against the order of CIT(A)-1,Ludhiana dated 24.01.2018 आयकर अपील सं./ ITA No. 799/CHD/2018 "नधा"रण वष" / Asses…

DCIT, C-1, Ludhiana vs. M/S Majestic Auto Limited, Ludhiana

ITA 799/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh13 Dec 2018AY 2013-14

Bench: Shri Sanjay Garg & Dr. B.R.R.Kumarआयकर अपील सं./ Ita No. 406/Chd/2018 "नधा"रण वष" / Assessment Year : 2012-13 The Dcit, Circle-1 Vs. M/S Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./Pan No: Aabcm2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal Against The Order Of Cit(A)-1,Ludhiana Dated 24.01.2018

For Appellant: Sh Subhash Aggarwal, AdvocateFor Respondent: Sh. Manjit Singh, Sr.DR
Section 36(1)(iii)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, “बी”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’, CHANDIGARH "ी संजय गग", "या"यक सद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Dr. B.R.R.KUMAR, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 406/CHD/2018 "नधा"रण वष" / Assessment Year : 2012-13 The DCIT, Circle-1 Vs. M/s Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./PAN NO: AABCM2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal against the order of CIT(A)-1,Ludhiana dated 24.01.2018 आयकर अपील सं./ ITA No. 799/CHD/2018 "नधा"रण वष" / Asses…

DCIT, C-1, Ludhiana vs. M/S Majestic Auto Limited, Ludhiana

ITA 406/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh13 Dec 2018AY 2012-13

Bench: Shri Sanjay Garg & Dr. B.R.R.Kumarआयकर अपील सं./ Ita No. 406/Chd/2018 "नधा"रण वष" / Assessment Year : 2012-13 The Dcit, Circle-1 Vs. M/S Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./Pan No: Aabcm2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal Against The Order Of Cit(A)-1,Ludhiana Dated 24.01.2018

For Appellant: Sh Subhash Aggarwal, AdvocateFor Respondent: Sh. Manjit Singh, Sr.DR
Section 36(1)(iii)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, “बी”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’, CHANDIGARH "ी संजय गग", "या"यक सद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Dr. B.R.R.KUMAR, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 406/CHD/2018 "नधा"रण वष" / Assessment Year : 2012-13 The DCIT, Circle-1 Vs. M/s Majestic Auto Limited, C-48, Focal Point, Ludhiana बनाम Ludhiana "थायी लेखा सं./PAN NO: AABCM2162M अपीलाथ"/Appellant ""यथ"/Respondent Appeal against the order of CIT(A)-1,Ludhiana dated 24.01.2018 आयकर अपील सं./ ITA No. 799/CHD/2018 "नधा"रण वष" / Asses…

DCIT, C-I, Ludhiana vs. M/S R. N. Gupta & Co. Ltd., Ludhiana

ITA 403/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh13 Dec 2018AY 2014-15

Bench: Shri Sanjay Garg & Dr. B.R.Kumarआयकर अपील सं./ Ita No. 403/Chd/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Dcit, Circles-1 Vs. M/S R.N. Gupta &Company Limited, Ludhiana बनाम C-55, Focal Point, Ludhiana "थायी लेखा सं./Pan No: Aabcr9636F अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh Subhash Aggarwal, AdvocateFor Respondent: Sh. Manjit Singh, Sr.DR
Section 36(1)(iii)Section 37(1)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, “बी”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’, CHANDIGARH "ी संजय गग", "या"यक सद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Dr. B.R.KUMAR, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 403/CHD/2018 "नधा"रण वष" / Assessment Year : 2014-15 The DCIT, Circles-1 Vs. M/s R.N. Gupta &Company Limited, Ludhiana बनाम C-55, Focal Point, Ludhiana "थायी लेखा सं./PAN NO: AABCR9636F अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Sh Subhash Aggarwal, Advocate राज"व क" ओर से/ Revenue by : Sh. Manjit Singh, Sr.DR…