India in Commissioner of Income Tax v. Meghalaya Steels Ltd.

6 SCC 747Supreme Court of India2016#10959 most cited
10

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Judgments citing India in Commissioner of Income Tax v. Meghalaya Steels Ltd.

DIRECTOR OF INCOME TAX (IT)-I, MUMBAI vs. M/S. AMERICAN EXPRESS BANK LTD

C.A. No.-008291-008291 - 2015Supreme Court15 Dec 2025

Bench: HON'BLE MR. JUSTICE J.B. PARDIWALA

Section 28Section 37(1)Section 44C

…e to’ also covers an indirect nexus. Thus, there is no doubt that the words ‘attributable to’ in the context of clause (c) would include both common and exclusive expenditure. [See Commissioner of Income Tax v. Meghalaya Steels Limited, reported in (2016) 6 SCC 747] 63. Further, if the Parliament had intended to restrict the scope of clause (c) only to common or shared expenses, it would have employed specific language to that effect. In the absence of such words of limitation, if we accept the respondents’ contention, it would tantamount to reading a qualification into clause (c) and thereby rewriting…

NATIONAL COOPERATIVE DEVELOPMENT CORPORATION vs. ASSISTANT COMMISSIONER OF INCOME TAX

C.A. No.-004612-004612 - 2014Supreme Court10 Dec 2025

Bench: HON'BLE MR. JUSTICE PAMIDIGHANTAM SRI NARASIMHA

Section 36(1)(viii)

…a direct, first-degree nexus between the income and the specified business activity. It is judicially settled that "derived from" is narrower than "attributable to", this distinction was lucidly clarified by this Court in Cambay Electric Supply 1 (2016) 6 SCC 747. 2 (1999) 4 SCC 98. 3 (2003) 5 SCC 590. 4 (2009) 9 SCC 328. 11 Industrial Co. Ltd. v. CIT5, where it was held that the legislature uses "derived from" when it intends to give a restricted meaning. The relevant part of the judgment is extracted hereunder: "8. As regards the aspect emerging from the expression "attributable to" occurr…

THE PRINCIPAL COMMISSIONER OF INCOME TAX AND ANR. vs. M/S GREENPLY INDUSTRIES LIMITED

ITA/6/2023HC Gauhati03 Mar 2025

Bench: Honourable The Chief Justice Honourable Mr. Justice N. Unni Krishnan Nair Date Of Hearing : 25.02.2025 Date Of Judgment & Order : 04.03.2025

For Respondent: B SARMA, DR. ASHOK SARAF,MR P BARUAH,MR. N N
Section 115Section 143(3)Section 260A

…oys(supra) by holding that the appeal was covered against the Revenue by the decisions of the Hon'ble Supreme Court in the case of Ponni Sugars & Chemicals Ltd.(supra) and in the case of Commissioner of Income Tax v. Meghalaya Steels Ltd., reported in (2016) 6 SCC 747. 25. The Hon'ble Supreme Court, thereafter, in its decision in the case of Commissioner of Income Tax-I, Kolhapur v. Chaphalkar Brothers, Pune, reported in (2018) 13 SCC 358; had an occasion to again consider its earlier decision in the case of Sahney Steel & Press Works Ltd.(supra) and Ponni Sugars & Chemicals Ltd. (supra); and had concluded…

M/S. SARAF EXPORTS vs. COMMISSIONER OF INCOME TAX, JAIPUR - III

C.A. No.-004822-004822 - 2022Supreme Court10 Apr 2023

Bench: HON'BLE MR. JUSTICE M.R. SHAH

Section 143(2)Section 75Section 80

…F 2022 Page 3 of 36 3. Learned counsel appearing on behalf of the assessee has heavily relied upon the decision of this Court in the case of Commissioner of Income Tax Vs. Meghalaya Steels Limited, (2016) 6 SCC 747 : (2016) 383 ITR 217 (SC), 3.1 It is submitted that the meaning of “derived from” under Section 80-IB as laid down in Liberty India (supra) has been widened by this Hon’ble Court in the case of Meghalaya Steels Limited (supra). 3.2 It is further submitted that the conclusion of Liberty India (supra) is based on the finding that “derived from” unde…

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-2, KOLKATA vs. M/S. BARAK VALLEY CEMENTS LTD.

ITAT/145/2018HC Calcutta06 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

Section 260ASection 80I

…ny answer to the substantial questions of law which have been raised before 4 us. In fact, such questions have been considered and answered by the Hon’ble Supreme Court in the case of Commissioner of Income Tax Vs. Meghalaya Steels Ltd., reported in (2016) 6 SCC 747. The learned counsel appearing for the appellant/revenue placed strong reliance upon the decision of the Hon’ble Supreme Court in Liberty India Vs. CIT, reported in (2009)9 SCC 328 and submitted that the remission of VAT is not directly relatable to the business of an industrial undertaking for manufacturing or selling its product and, therefo…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE vs. M/S. BANGALORE INTERNATIONAL AIRPORT LIMITED, BANGALORE

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

ITA 374/BANG/2020[2013-14]Status: DisposedITAT Bangalore14 Jun 2022AY 2013-14

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 250Section 271(1)(c)Section 80Section 80I

…outcome of the generation and distribution of power by the Assessee since the Assessee does not have any other source of business. Reliance was placed on the decision of the Supreme Court of India in Commissioner of Income Tax v. Meghalaya Steels Ltd. (2016) 6 SCC 747. 8. Countering the above submissions, Mr. Satapathy, learned Senior Standing Counsel for the Department contended that the critical words in Section 80-IA of the IT Act were that the other income must be derived from the business of generation of electricity and not merely ‘attributable’ to it. In other words, such income should have a direct and a…

M/S. BANGALORE INTERNATIONAL AIRPORT LIMITED,BANGALORE vs. COMMISSIONER OF INCOME TAX (APPEALS)- 1, BANGALORE

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

ITA 191/BANG/2020[2013-14]Status: DisposedITAT Bangalore14 Jun 2022AY 2013-14

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 250Section 271(1)(c)Section 80Section 80I

…outcome of the generation and distribution of power by the Assessee since the Assessee does not have any other source of business. Reliance was placed on the decision of the Supreme Court of India in Commissioner of Income Tax v. Meghalaya Steels Ltd. (2016) 6 SCC 747. 8. Countering the above submissions, Mr. Satapathy, learned Senior Standing Counsel for the Department contended that the critical words in Section 80-IA of the IT Act were that the other income must be derived from the business of generation of electricity and not merely ‘attributable’ to it. In other words, such income should have a direct and a…

INCOME TAX OFFICER WARD-4(2), GUWAHATI vs. M/S. KISHLAY FOOD (P) LTD, GUWAHATI

In the result, the appeal is allowed

ITA 232/GTY/2018[2010-11]Status: DisposedITAT Guwahati13 Dec 2019AY 2010-11

Bench: Shri S.S.Godara & Dr. A.L.Sainiassessment Year :2011-12

Section 143(3)Section 14ASection 250(6)Section 43BSection 80Section 80ISection 80l

…made to tax this item should be deleted. Decision I have gone through the submission of the appellant as also the relevant observations of the Ld AO. In view of the decision of the Hon'ble Supreme Court in the case of CIT vs. Meghalaya Steels Ltd. [192 (2016) 6 SCC 747], the aggregate addition of RS.2,92,20,684/- on account of VAT remission and interest subsidy, made by the AO on this account, are hereby deleted. Since, the above amounts have been found to be exigible for deduction under section 80IC of the Act, consequential ground qua permitting the deduction under section 80IC in respect of disallowance of the…

ITO, NEW DELHI vs. MRS. AMBIKA SADH, NEW DELHI

In the result, both the appeals of the revenue are dismissed

ITA 6252/DEL/2015[2010-11]Status: DisposedITAT Delhi28 Aug 2017AY 2010-11

Bench: Shri G.D. Agrawal & Shri Amit Shuklain Ita Nos. 6252 & 6253/Del/2015 Assessment Years: 2010-11 & 2011-12 Ito, Ward -29(4), Vs. Ambika Sadh Room No. 1013, 10Th Floor, Prop. M/S. Euro Expo. E-2 Block, Dr. S.P. Sukherjee C-57, M.B. Road, Civic Centre, Jln Marg, Lal Kuan Badarpur, Minto Road, New Delhi New Delhi (Applicant) (Respondent) (Pan: Aoqps4050C)

For Appellant: NoneFor Respondent: Shri Atiq Ahmed, Sr. DR
Section 10BSection 143(3)Section 80I

…sue, namely, the entitlement of export incentives to deduction under Section 80-IB of the Income Tax Act, 1961 has been squarely decided by this Court in Liberty India vs. C.I.T. (2009) 9 SCC 328. Commissioner of Income Tax vs. Meghalaya Steels Limited (2016) 6 SCC 747 does not in any way erode the efficacy of law laid down in Liberty India (supra) as Meghalaya Page 6 of 11 Steels Limited (supra) was primarily a case where the Court was dealing with transport subsidy, which is a reimbursement of the cost incurred by the manufacturing unit in the North-Eastern part of the Country. 3. While Liberty India (supra)…

ACIT, NEW DELHI vs. M/S VINEET SOOD & SONS (HUF), NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 6205/DEL/2015[2007-08]Status: DisposedITAT Delhi25 Aug 2017AY 2007-08

Bench: Shri G.D. Agrawal & Shri Amit Shuklain Ita No. 6205/Del/2015 Assessment Year: 2007-08 Acit Vs. Vineet Sood & Sons (Huf), Circle 28(1), G-53, Sarita Vihar, New New Delhi Delhi (Applicant) (Respondent) (Pan: Aaahv3031Q)

For Appellant: Shri Rakesh Verma, CAFor Respondent: Shri Atiq Ahmed, Sr. DR
Section 10BSection 143(1)Section 143(3)Section 147Section 263

…sue, namely, the entitlement of export incentives to deduction under Section 80-IB of the Income Tax Act, 1961 has been squarely decided by this Court in Liberty India vs. C.I.T. (2009) 9 SCC 328. Commissioner of Income Tax vs. Meghalaya Steels Limited (2016) 6 SCC 747 does not in any way erode the efficacy of law laid down in Liberty India (supra) as Meghalaya Steels Limited (supra) was primarily a case where the Court was dealing with transport subsidy, which is a reimbursement of the cost incurred by the manufacturing unit in the North-Eastern part of the Country. 3. While Liberty India (supra) dealt with a si…