What is Joint Commissioner of Income Tax v. Mukund Ltd. (15.02 authority for?

Amortisation of premium paid for leasehold land is a capital expenditure and not deductible.

Which sections of the Income Tax Act does Joint Commissioner of Income Tax v. Mukund Ltd. (15.02 come up under?

It is most often cited in judgments turning on Section 139, Section 142(1), Section 143(3), Section 147, Section 148.

Joint Commissioner of Income Tax v. Mukund Ltd. (15.02 (106 ITD 231)

Q: How many judgments cite Joint Commissioner of Income Tax v. Mukund Ltd. (15.02?

34 judgments on BharatTax cite Joint Commissioner of Income Tax v. Mukund Ltd. (15.02 (106 ITD 231), spanning 2015 to 2025.

Wheels India Ltd., Chennai vs. ACIT Ltu-1, Chennai

In the result, appeal filed by the assessee is allowed

ITA 696/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Aug 2025AY 2012-13

Bench: Ms. Padmavathy. S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.696/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. M/S. Wheels India Ltd., The Acit, No.21, Annasalai Patullos Road, Large Taxpayer Unit-1, Chennai-600 002. Chennai. [Pan: Aaacw 0315 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 115JSection 142(1)Section 143(2)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘बी’ "यायपीठ, चे"नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI एमएस। प"ावती एस, लेखा सद" एवं एवं एवं एवं "ी मनु कुमार िग"र, "ाियक सद" के सम" BEFORE MS. PADMAVATHY. S, ACCOUNTANT MEMBER AND SHRI MANU KUMAR GIRI, JUDICIAL MEMBER आयकर अपील सं./ITA No.696/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 v. M/s. Wheels India Ltd., The ACIT, No.21, Annasalai Patullos Road, Large Taxpayer Unit-1, Chennai-600 002. Chennai. [PAN: AAACW 0315 K] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant by Mr.R. Vijayaraghavan, Advocate : ""यथ" क" ओर से /Respondent by Ms. Gautham…

The Principal Officer, Sarda Mines Pvt. Ltd., Keonjhar vs. ACIT(TDS)-II, Bhubaneswar

In the result, appeals filed by the assessee are allowed

ITA 298/CTK/2017[2009-10]Status: DisposedITAT Cuttack31 Aug 2018AY 2009-10

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Shri Bhagban Panda/D.K.Mohanty, ARFor Respondent: Shri Subhendu Datta, DR

Section 194Section 201(1)

…in true character and purport of the payment the court has to go by the substance of transaction and not by manner in which the assessee allocates the items for accounting purposes. 15. The Special Bench of Mumbai Tribunal in the case of JCIT v. Mukund Ltd. 106 ITD 231 wherein the issue was whether the premium paid for acquiring leasehold right in land is revenue or capital, has held that the same is capital expenditure. P a g e 14 | 24 ITA Nos. 296, 297 & 298/CT K/ 2017 Asse ssment Years : 2 007 -08 , 20 08- 09 & 200 9-2 010 16. Thus, in the absence of any material on record to show Rs.9,45,43,340/- was pa…

The Principal Officer, Sarda Mines Pvt. Ltd., Keonjhar vs. ACIT(TDS)-II, Bhubaneswar

In the result, appeals filed by the assessee are allowed

ITA 297/CTK/2017[2008-09]Status: DisposedITAT Cuttack31 Aug 2018AY 2008-09

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Shri Bhagban Panda/D.K.Mohanty, ARFor Respondent: Shri Subhendu Datta, DR

Section 194Section 201(1)

…in true character and purport of the payment the court has to go by the substance of transaction and not by manner in which the assessee allocates the items for accounting purposes. 15. The Special Bench of Mumbai Tribunal in the case of JCIT v. Mukund Ltd. 106 ITD 231 wherein the issue was whether the premium paid for acquiring leasehold right in land is revenue or capital, has held that the same is capital expenditure. P a g e 14 | 24 ITA Nos. 296, 297 & 298/CT K/ 2017 Asse ssment Years : 2 007 -08 , 20 08- 09 & 200 9-2 010 16. Thus, in the absence of any material on record to show Rs.9,45,43,340/- was pa…

DCIT Cir - 3(1), Mumbai vs. M/S. Gujarat Ambuja Cements Ltd., Mumbai

In the result, Revenue’s appeal is dismissed

ITA 1416/MUM/2007[2003-2004]Status: DisposedITAT Mumbai10 Aug 2018AY 2003-2004

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI N.K. PRADHAN, ACCOUNTANT MEMBER ITA no.7092/Mum./2005 (Assessment Year : 2002–03) Ambuja Cement Ltd. (Earlier known as Gujarat Ambuja Cements Ltd.) 122, Maker Chambers–III ……………. Appellant Nariman Point, Mumbai 400 021 PAN – AAACG0569P v/s Dy. Commissioner of Income Tax ……………. Respondent Range–3(1), Mumbai ITA no.7227/Mum./2005 (Assessment Year : 2002–03) Dy. Commissioner of Income Tax ……………. Appellant Range–3(1), Mumbai v/s Ambuja Cement Ltd. (Earlier known as Gujarat Ambuja Cements Ltd.) 122, Maker Chamber…

M/S. Gujarat Ambuja Cements Ltd., Mumbai vs. DCIT RG. 3(1), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 7092/MUM/2005[2002-2003]Status: DisposedITAT Mumbai10 Aug 2018AY 2002-2003

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI N.K. PRADHAN, ACCOUNTANT MEMBER ITA no.7092/Mum./2005 (Assessment Year : 2002–03) Ambuja Cement Ltd. (Earlier known as Gujarat Ambuja Cements Ltd.) 122, Maker Chambers–III ……………. Appellant Nariman Point, Mumbai 400 021 PAN – AAACG0569P v/s Dy. Commissioner of Income Tax ……………. Respondent Range–3(1), Mumbai ITA no.7227/Mum./2005 (Assessment Year : 2002–03) Dy. Commissioner of Income Tax ……………. Appellant Range–3(1), Mumbai v/s Ambuja Cement Ltd. (Earlier known as Gujarat Ambuja Cements Ltd.) 122, Maker Chamber…

Owens-Corning (India) Private Limited (Formerly Known As Owens-Corning (India) Limited), Mumbai vs. Assistant Commissioner of Income Tax Range 7(3)(1), Mumbai

Appeal of the assessee is partly allowed, as above

ITA 5959/MUM/2017[2013-14]Status: DisposedITAT Mumbai23 Mar 2018AY 2013-14

Bench: Shri G.S. Pannu & Shri Pawan Singh: (A.Y : 2013-14)

For Appellant: Shri Jehangir D. MistryFor Respondent: Shri Jayant Kumar &

Section 143(3)

…tisation of premium paid for leasehold land of Rs.20,14,932/-. It is noticed that the Assessing Officer disallowed the claim by relying on the decision of the Special Bench of the Tribunal in the case of Joint Commissioner of Income Tax vs Mukund Ltd., (2007) 106 ITD 231 (Mum) as also the stand of the assessing authority in assessee’s own case for the earlier assessment years. Before us, it was pointed out that the lead year of dispute on this aspect was Assessment Year 2001-02, wherein the Tribunal in assessee’s own case vide ITA No. 8939/Mum/2004 dated 19.11.2008 decided the issue against the assessee. In Asses…