Indian Molasses Co. Pvt. Ltd. v. CIT

37 ITR 66Supreme Court of India1959#438 most cited

What is Indian Molasses Co. Pvt. Ltd. v. CIT authority for?

Expenditure is defined as money paid out or away, which is gone irretrievably. To be deductible under Section 37(1), expenditure must be wholly and exclusively for business, not capital or personal, and not fall under specific provisions of Sections 30 to 36, often justifiable on grounds of commercial expediency.

206

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

Indian Molasses Co. Pvt. Ltd. v. CIT · Section 37(1) · definition of expenditure · business expenditure deduction · commercial expediency · wholly and exclusively for business · expenditure irretrievably gone · Sections 30-36

Sections most often in play

Section 142(1)Section 143(2)Section 143(3)Section 234BSection 234CSection 11Section 13(1)(c)Section 13(2)(h)
Read the full judgment

Issues it is cited on

section 13(2)accumulation of incomesection 13(3)section 13(1)(c)infrastructure facilitysection 13(1)section 30business expediencymercantile system of accountingcommercial expediencysection 40(a)(i)profits and gains of business or profession

Judgments citing Indian Molasses Co. Pvt. Ltd. v. CIT

Addl.CIT, Special Range-7, New Delhi vs. Ptc India Financial Services Ltd., New Delhi

In the result, appeal is dismissed

ITA 5654/DEL/2019[2015-16]Status: HeardITAT Delhi21 Dec 2023AY 2015-16

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2015-16 With Assessment Year: 2016-17 Ptc India Financial Services Vs. Addl. Cit, Ltd., Special Range-7, Telephone Exchange Building, New Delhi 8, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent) With Assessment Year: 2015-16 With Assessment Year: 2016-17 Addl. Cit, Vs. Ptc India Financial Services Special Range-7, Ltd., New Delhi 2Nd Floor, Nbcc Tower, 15, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent)

…olasses Co. P. Ltd. to the instant case 3.14 It is respectfully submitted that, recently your Honour while adjudicating the matter for AY 2013-14, placed incorrect reliance on the decision rendered by Hon'ble Apex Court in case of Indian Molasses Co. P. Ltd. (37 ITR 66). Your Honour held that although such loss was revenue in nature, however, it did not qualify as "expenditure" and thus cannot be allowed as deduction under the provisions of the Act. Further, on the contention of the Appellant that the matter is covered in its favour by Apex Court Judgement in ca of Woodward Governer, your Honour held that the sam…

Addl. CIT, Special Range- 7, New Delhi vs. Ptc India Financial Services Ltd, New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7433/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

…olasses Co. P. Ltd. to the instant case 3.14 It is respectfully submitted that, recently your Honour while adjudicating the matter for AY 2013-14, placed incorrect reliance on the decision rendered by Hon'ble Apex Court in case of Indian Molasses Co. P. Ltd. (37 ITR 66). Your Honour held that although such loss was revenue in nature, however, it did not qualify as "expenditure" and thus cannot be allowed as deduction under the provisions of the Act. Further, on the contention of the Appellant that the matter is covered in its favour by Apex Court Judgement in ca of Woodward Governer, your Honour held that the sam…

Ptc India Financial Services Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7273/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

…olasses Co. P. Ltd. to the instant case 3.14 It is respectfully submitted that, recently your Honour while adjudicating the matter for AY 2013-14, placed incorrect reliance on the decision rendered by Hon'ble Apex Court in case of Indian Molasses Co. P. Ltd. (37 ITR 66). Your Honour held that although such loss was revenue in nature, however, it did not qualify as "expenditure" and thus cannot be allowed as deduction under the provisions of the Act. Further, on the contention of the Appellant that the matter is covered in its favour by Apex Court Judgement in ca of Woodward Governer, your Honour held that the sam…

ACIT, New Delhi vs. M/S. Ptc India Financial Services Ltd., New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2175/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

…olasses Co. P. Ltd. to the instant case 3.14 It is respectfully submitted that, recently your Honour while adjudicating the matter for AY 2013-14, placed incorrect reliance on the decision rendered by Hon'ble Apex Court in case of Indian Molasses Co. P. Ltd. (37 ITR 66). Your Honour held that although such loss was revenue in nature, however, it did not qualify as "expenditure" and thus cannot be allowed as deduction under the provisions of the Act. Further, on the contention of the Appellant that the matter is covered in its favour by Apex Court Judgement in ca of Woodward Governer, your Honour held that the sam…

M/S. Ptc India Financial Services Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2162/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

…olasses Co. P. Ltd. to the instant case 3.14 It is respectfully submitted that, recently your Honour while adjudicating the matter for AY 2013-14, placed incorrect reliance on the decision rendered by Hon'ble Apex Court in case of Indian Molasses Co. P. Ltd. (37 ITR 66). Your Honour held that although such loss was revenue in nature, however, it did not qualify as "expenditure" and thus cannot be allowed as deduction under the provisions of the Act. Further, on the contention of the Appellant that the matter is covered in its favour by Apex Court Judgement in ca of Woodward Governer, your Honour held that the sam…

Thomas Cook (India) Ltd., Mumbai vs. Addl/ Jt/ Dy/CIT/Asstt/ITO, National E-Assessment Centre, Delhi

In the result, appeal filed by the assessee is partly allowed

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

Section 92CSection 92C(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND MS. KAVITHA RAJAGOPAL, HON'BLE JUDICIAL MEMBER ITA NO. 752/MUM/2022 (A.Y. 2017-18) Thomas Cook (India) Limited v. Additional/Joint/Dy. /Asst., CIT National e-Assessment Centre Thomas Cook Building Delhi Dr. D.N. Road, Fort Mumbai - 400001 PAN: AAACT4050C (Appellant) (Respondent) Assessee Represented by : Shri J.D. Mistry Shri Madhur Agrawal & Shri Fenil Bhat Department Represented by : Shri K.C. Selvamani Date of Conclusion of Hearing : 26 & 27.09.2023 Date of Pronouncement : 24.11.2023 O R…

Addl. CIT-(08), New Delhi vs. Sopra India Pvt. Ltd., New Delhi

In the result, appeal of the Revenue thus is dismissed

ITA 1175/DEL/2019[2012-13]Status: DisposedITAT Delhi16 Oct 2023AY 2012-13
Section 143(3)Section 145

…esent but only contingent, cannot bear the ACIT vs. Sopra India Pvt. Ltd. 5 character of expenses till the liability becomes real. He also referred to the decision of Bank of Bahrain & Kuwait BSE the Hon'ble Supreme Court in the case of Indian Molasses' case (37 ITR 66), wherein also, it was held that where the liability is contingent, the same is not allowable. The Hon'ble Supreme Court observed as under:- "The expenditure which is deductible for income tax purposes is one which is towards a liability actually existing at the time, but the putting aside of money which may become expenditure on the happening of…

Leariningmate Solutions Private Limited, Mumbai vs. Ld Principle Commissioner of Income Tax-2, Mumbai

ITA 1696/MUM/2023[2018-2019]Status: DisposedITAT Mumbai31 Jul 2023AY 2018-2019
For Appellant: Shri Karthik NatarajanFor Respondent: MS N. V. Nadkarni
Section 143Section 143(1)Section 143(3)Section 263Section 263(1)Section 37(1)

…IT formed a view that the order passed by the Assessing Officer was erroneous in so far as it is prejudicial to the interest of Revenue by placing reliance on the judgment of the Hon‟ble Supreme Court in the case of Indian Molasses Co. (P.) Ltd. v. CIT [1959] 37 ITR 66 (SC) and the decision of the Delhi Bench of the Tribunal in the case of Ranbaxy Laboratories Ltd. Vs. Additional Commissioner of Income Tax: [2010] 39 SOT 17 (Delhi) (URO) without appreciating that both the aforesaid decisions were considered by the Special Bench of the Tribunal in the case of Biocon Ltd. Vs. Deputy Commissioner of Income Tax – LTU…

Asst CIT Cir 2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 4564/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…ccounting on the ground of diminished hope of recovery. Furthermore, any liability de 11stopp is not an ascertained liability in praesenti and cannot be allowed as deduction under the Income-tax Act as held in the case of Indian Molasses Co. Pvt. Ltd. vs. CIT 37 ITR 66 (SC) and Standard Mills Co. Ltd. Vs.CIT 229 ITR 366(Bom). Hence, no such ad hoc deduction could be allowed against the amount receivable on redemption of securities which had matured and become due for payment before the close of the accounting year. This ground therefore fails.” 39. The findings of the CIT(A) is based the on the various decisions…

State Bank of India, Mumbai vs. Addl CIT RG 2(2), Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 3645/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…ccounting on the ground of diminished hope of recovery. Furthermore, any liability de 11stopp is not an ascertained liability in praesenti and cannot be allowed as deduction under the Income-tax Act as held in the case of Indian Molasses Co. Pvt. Ltd. vs. CIT 37 ITR 66 (SC) and Standard Mills Co. Ltd. Vs.CIT 229 ITR 366(Bom). Hence, no such ad hoc deduction could be allowed against the amount receivable on redemption of securities which had matured and become due for payment before the close of the accounting year. This ground therefore fails.” 39. The findings of the CIT(A) is based the on the various decisions…

L & T Mhps Boilers Private Limited, Mumbai vs. ACIT 2(2)(1), Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 4765/MUM/2017[2011-12]Status: DisposedITAT Mumbai02 Jun 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm L & T Mhps Boilers Private Limited Acit-2(2)(1) 2Nd Floor, L & T House, Mumbai Vs. N. M. Marg, Ballard Estate, Fort, Mumbai-400 001 Pan/Gir No. Aabcl 2635 C (Appellant) : (Respondent) &

For Appellant: Shri Nitesh JoshiFor Respondent: Smt. Shailja Rai &
Section 143(3)Section 37(1)

…was incurred for carrying on the business and as the same has not been crystallized during the year, it was not an allowable deduction. The ld. A.O. relied on the decision of the Hon'ble Apex Court in the case of Indian Molasses Co. Pvt. Ltd. vs. CIT [1959] 37 ITR 66 (SC) and Shree Sajjan Mills Ltd. vs. CIT [1985] 156 ITR 585 (SC), wherein it was held that only expenditures which was incurred or which was existing was liable for deduction and not any future expenses anticipated to be expended. The ld. A.O. relied on the tests laid down by the Hon'ble Apex Court in the above mentioned case and held that the ass…

D.C.C.T., Circle-3(1), Kolkata vs. M/S Narsingh Ispat Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1513/KOL/2019[2011-12]Status: HeardITAT Kolkata18 Apr 2023AY 2011-12

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No. 1513/Kol/2019 Assessment Year: 2011-2012 Deputy Commissioner Of Income Tax,.........Appellant Circle-3(1), Kolkata, Aayakar Bhawan, 4Th Floor, Room No. 19, P-7, Chowringhee Square, Kolkata-700069 -Vs.- M/S. Narsingh Ispat Limited,....................Respondent 16, Strand Road, Fairly Place, 15Th Floor, Diamond Heritage, Unit-1512, Kolkata-700001 [Pan: Aaccn0208J] Appearances By: Shri P.P. Barman, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Shri Miraj D. Shah, A.R., Appeared On Behalf Of The Assessee Date Of Concluding The Hearing : April 05, 2023 Date Of Pronouncing The Order : April 18, 2023 O R D E R

Section 132Section 133ASection 143(1)Section 143(3)Section 148Section 68Section 69C

…ITA No. 1513/KOL/2019 Assessment Year: 2011-2012 M/s. Narsingh Ispat Limited IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH, KOLKATA Before Shri Sanjay Garg, Judicial Member & Dr. Manish Borad, Accountant Member I.T.A. No. 1513/KOL/2019 Assessment Year: 2011-2012 Deputy Commissioner of Income Tax,.........Appellant Circle-3(1), Kolkata, Aayakar Bhawan, 4th Floor, Room No. 19, P-7, Chowringhee Square, Kolkata-700069 -Vs.- M/s. Narsingh Ispat Limited,....................Respondent 16, Strand Road, Fairly Place, 15th Floor, Diamond Heritage, Unit-1512, Kolkata-700001 [PAN: AACCN0208J] Appearances by: Shri P.P.…

Bsc C&C Kurali Toll Road Ltd., New Delhi vs. ACIT Circle-5(1), New Delhi

In the result appeal of the assessee is partly allowed

ITA 3141/DEL/2019[2014-15]Status: DisposedITAT Delhi13 Feb 2023AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri B.R.R. Kumar

For Appellant: Shri Amarjit Singh, CAFor Respondent: Shri P. Praveen Sidharth, CIT DR
Section 32(1)(ii)

…not filed any proof if any of the same.) The liability created by the agreement has not crystallized and the quantified in the previous year. A provision for a contingent liability is not allowable as a deduction (Indian Molasses Co. Pvt. Ltd. vs. CIT (1959) 37 ITR 66 (SC). I find that the appellant has quoted the decision of Hon'ble SC in the case of M/s. Rotork Controls in support of its contention. However, the facts of the case is not similar to that of the appellant hence I find the reliance of the above decision as ill founded. The appellant has tried to justify its argument by stating that it has obligat…

Umesh A Mishra, Mumbai vs. ITO 8(2)(4), Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 870/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Oct 2022AY 2009-10
Section 143Section 250Section 28Section 30Section 37

…tures which are not covered by section 30 to 36. The learned CIT(A) has also relied on the decision of the P a g e | 5 ITA NO. ITA NO.870/MUM/2014 (A.Y.2009-10) MR. UMESH A. MISHRA Hon’ble Apex Court in the case of Indian Molasses Co. (P) Ltd. Vs. CIT (1959) 37 ITR 66 (SC) which has elaborated upon the term ‘expenditure’ and ‘expense’ and has also differentiated the liability which is contingent and liability which arises upon a contingency. 6. Upon considering the above facts we are of the considered opinion that the assessee had failed to substantiate his claim that the impugned expenses pertains to the runnin…

Idea Cellular Ltd, Mumbai vs. DCIT 3(2), Mumbai

In the result, appeal of the Revenue in ITA No

ITA 2285/MUM/2014[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09
Section 143(3)Section 194HSection 40

…he assessee incurs any expenditure, which thereafter satisfies the requisite conditions of the sub-section (1). He submitted that the word "expenditure" has been described by the Hon'ble Supreme Court in the case of Indian Molasses Co. (P.) Ltd. v. CIT [1959] 37 ITR 66 as denoting spending or paying out, i.e. something going out of the coffers of the assessee. It was put forth that by issuing shares at discounted premium, nothing is paid out by the company. Once there is no "paying out or away", the same cannot constitute an expenditure and resultantly section 37(1), which applies to only expenditure, cannot be a…

DCIT 3(2), Mumbai vs. Idea Cellular Ltd, Mumbai

In the result, appeal of the Revenue in ITA No

ITA 2273/MUM/2014[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09
Section 143(3)Section 194HSection 40

…he assessee incurs any expenditure, which thereafter satisfies the requisite conditions of the sub-section (1). He submitted that the word "expenditure" has been described by the Hon'ble Supreme Court in the case of Indian Molasses Co. (P.) Ltd. v. CIT [1959] 37 ITR 66 as denoting spending or paying out, i.e. something going out of the coffers of the assessee. It was put forth that by issuing shares at discounted premium, nothing is paid out by the company. Once there is no "paying out or away", the same cannot constitute an expenditure and resultantly section 37(1), which applies to only expenditure, cannot be a…

Raghuleela Builders Pvt Ltd, Mumbai vs. Dict, Circle-1(2), Pune

Appeal is dismissed in above terms

ITA 1885/PUN/2019[2011-12]Status: DisposedITAT Pune07 Oct 2022AY 2011-12

Bench: Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.1885/Pun/2019 िनधा"रण वष" / Assessment Year: 2011-12 Raghuleela Builders Pvt. Vs. Dcit, Circle-1(2), Pune. Ltd., 1401, A-Wing, One Bkc, Plot C-66, G Block, Bandra Kurla Complex, Bandra East, Mumbai- 400051. Pan : Aadcr5942E Appellant Respondent Assessee By : None Revenue By : Shri M. G. Jasnani Date Of Hearing : 28.09.2022 Date Of Pronouncement : 07.10.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2011-12 Arises Against The Cit(A)-13, Pune’S Order Dated 22.07.2019 Passed In Case No. Pn/Cit(A)-13/Dcit Circle-1(2), Pune/623/2014-15/227, Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short “The Act”. Case Called Twice. None Appears At Assessee’S Behest. The Very Factual Position Had Existed On 30.05.2022 & 21.07.2022 As Well. We Thus Proceed Ex-Parte Against The Assessee.

For Appellant: NoneFor Respondent: Shri M. G. Jasnani
Section 143(3)Section 37Section 37(1)

…that the Appellant cannot claim deductions for brokerage for the amount of the provision made towards the brokerage was an accrued liability. The learned AO relied on the decision of Hon’ble Supreme Court in the case of Indian Molasses Co. (P) Ltd Vs CIT (SC) 37 ITR 66 for a preposition that putting aside of money which may become an expenditure on happening of an event is not an allowable expenditure. 3.4 During the course of appellate proceedings, the learned AR for the Appellant submitted before me that out of the total income of Rs. 1,83,71,068/-, provision for commission was of Rs, 96,25,991/- and this was t…

PCIT, Delhi-7 vs. Ratnagiri Gas and Power Pvt. Ltd

ITA/264/2022HC Delhi29 Aug 2022

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MS. JUSTICE TARA VITASTA GANJU

…ITA 264/2022 Page 1 of 11 $~39 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 29.8.2022 + ITA 264/2022 PCIT, DELHI-7 ......Appellant Through: Mr Sunil Agarwal, Sr Standing Counsel with Mr Tushar Gupta and Mr Utkarsh Tiwari, Advs. versus RATNAGIRI GAS AND POWER PVT. LTD. ......Respondent Through: Mr Ved Kumar Jain with Mr Nischay Kantoor and Ms Richa Mishra, Advs. CORAM: HON'BLE MR JUSTICE RAJIV SHAKDHER HON'BLE MS JUSTICE TARA VITASTA GANJU [Physical Court Hearing/Hybrid Hearing (as per request]…

Eit Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 210/BANG/2021[2016-17]Status: DisposedITAT Bangalore22 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Praveen Karanth, D.R
Section 133(6)Section 143(3)Section 92D

…ssued against assets/technical know-how cannot be claimed as revenue expenditure. 20.12 Ld. DRP relied on the following case laws while issuing the directions to the Learned AO: - Eimco KCP Ltd. Vs CIT 242 ITR 659 (SC); - Indian Mollasses Co. Pvt Ltd vs CIT 37 ITR 66; - CIT vs Nainital Bank Ltd 62 ITR 638 20.13 After considering the above points, DRP agreed with the conclusion drawn by the Learned AO and rejected the objections raised by the Appellant against the proposed adjustment. c) Appellant’s Arguments: 20.14 In connection with the above adjustment made by the Learned AO, the Company places its reliance…

Assistant Commissioner of Income Tax Circle-2(3)(1), Mumbai vs. Tata Sons Limited, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 4323/MUM/2017[2011-12]Status: DisposedITAT Mumbai16 Aug 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Ms. Aarti Vissanji a/wFor Respondent: Shri Tejinder Pal Singh
Section 143(2)Section 143(3)Section 250Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRAMOD KUMAR, VICE PRESIDENT AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.4323/Mum./2017 (Assessment Year : 2011–12) Asstt. Commissioner of Income Tax ……………. Appellant Circle–2(3)(1), Mumbai v/s M/s. Tata Sons Limited …………….Respondent 24, Bombay House, Homi Mody Street Fort, Mumbai 400 001 PAN – AAACT4060A ITA No.4221/Mum./2017 (Assessment Year : 2011–12) M/s. Tata Sons Limited ……………. Appellant 24, Bombay House, Homi Mody Street Fort, Mumbai 400 001 PAN – AAACT4060A v/s Asstt. Commissioner of Income Tax …………….Respondent Circle–2(3)(…