Laurids Knudsen Maskinfabrik Ltd Vs ITO (77 ITD 212), SSI Ltd. v. DCIT (

222 ITR 528Reported decision#7342 most cited
15

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2024.

Issues it is cited on

section 10(2a)section 155weighted deductionsection 35(2ab)section 10bcorporate guaranteesection 48book profitsprincipal commissioner of income-taxtransfer pricing adjustmentdisallowance under section 14aassociated enterprise

Judgments citing Laurids Knudsen Maskinfabrik Ltd Vs ITO (77 ITD 212), SSI Ltd. v. DCIT (

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

ITA 118/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2011-12

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

ITA 117/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2006-07

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

ITA 116/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2005-06

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

ITA 113/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2011-12

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

ITA 112/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2009-10

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

ITA 111/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2008-09

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

ITA 110/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2007-08

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

ITA 109/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2006-07

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR

…in forex even if the same has been held for investment purposes. Therefore, such gains have to be treated as capital receipt. For this proposition, we draw support from the decision of the Hon’ble High Court of Bombay in the case of Homi Mehta Sons Pvt. Ltd. 222 ITR 528. We find that the forward contract in respect of investment in Caraco and OFCD in Global are on capital account and any profits received by assessee on cancellation of forward contract would not change its character same being in connection with a capital asset and, therefore, has to be treated as capital receipt. For this proposition, we draw su…

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

In the result, the appeal of the Revenue is partly allowed

ITA 1520/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2013-14

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘D’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMEBR & SHRI WASEEM AHMED, ACCOUNTANT MEMEBR आयकर अपील सं./I.T.A. Nos. 1462 & 1463/Ahd/2018, 1519 & 1520/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2011-12 & 2013-14) Sun Pharmaceutical बनाम/ Assistant Commissioner Industries Ltd. of Income Tax / Deputy Vs. “SPARC”, Tandalja, Commissioner of Vadodara - 390012 Income-tax, Central Circle- 2(1)(1), Vadodara & Deputy Commissioner of M/s. Sun Income Tax, Pharmaceuticals Circle- 2(1)(1), 4th Floor, Industries Ltd. Aaya…

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

In the result, the appeal of the Revenue is partly allowed

ITA 1519/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2011-12

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘D’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMEBR & SHRI WASEEM AHMED, ACCOUNTANT MEMEBR आयकर अपील सं./I.T.A. Nos. 1462 & 1463/Ahd/2018, 1519 & 1520/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2011-12 & 2013-14) Sun Pharmaceutical बनाम/ Assistant Commissioner Industries Ltd. of Income Tax / Deputy Vs. “SPARC”, Tandalja, Commissioner of Vadodara - 390012 Income-tax, Central Circle- 2(1)(1), Vadodara & Deputy Commissioner of M/s. Sun Income Tax, Pharmaceuticals Circle- 2(1)(1), 4th Floor, Industries Ltd. Aaya…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal of the Revenue is partly allowed

ITA 1463/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2013-14

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘D’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMEBR & SHRI WASEEM AHMED, ACCOUNTANT MEMEBR आयकर अपील सं./I.T.A. Nos. 1462 & 1463/Ahd/2018, 1519 & 1520/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2011-12 & 2013-14) Sun Pharmaceutical बनाम/ Assistant Commissioner Industries Ltd. of Income Tax / Deputy Vs. “SPARC”, Tandalja, Commissioner of Vadodara - 390012 Income-tax, Central Circle- 2(1)(1), Vadodara & Deputy Commissioner of M/s. Sun Income Tax, Pharmaceuticals Circle- 2(1)(1), 4th Floor, Industries Ltd. Aaya…

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal of the Revenue is partly allowed

ITA 1462/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2011-12

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘D’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMEBR & SHRI WASEEM AHMED, ACCOUNTANT MEMEBR आयकर अपील सं./I.T.A. Nos. 1462 & 1463/Ahd/2018, 1519 & 1520/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2011-12 & 2013-14) Sun Pharmaceutical बनाम/ Assistant Commissioner Industries Ltd. of Income Tax / Deputy Vs. “SPARC”, Tandalja, Commissioner of Vadodara - 390012 Income-tax, Central Circle- 2(1)(1), Vadodara & Deputy Commissioner of M/s. Sun Income Tax, Pharmaceuticals Circle- 2(1)(1), 4th Floor, Industries Ltd. Aaya…

M/S. HAVELLS INDIA LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee is partly allowed for statistical purpose

ITA 4695/DEL/2012[2008-09]Status: DisposedITAT Delhi10 Nov 2020AY 2008-09

Bench: Shri Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing) Vs Havells India Ltd. Acit 1, Raj Narian Marg, Ltu Civil Lines New Delhi New Delhi Aaach0351E (Respondent) (Appellant)

Section 251Section 40Section 80I

…ion of exchange price is independent of the primary transaction and such profit can be taxed only if the assessee is a dealer in foreign exchange. The Ld. AR relied upon the decision of the Hon’ble Bombay High Court in case of Homi Mehta & Sons P. Ltd. v. CIT 222 ITR 528. In this case, the assessee company was holding certain shares in limited companies in the UK by way of investment. Dividend income earned by the assessee on these shares was kept in a current account in UK. The accumulation in the current account was utilized by the assessee for the purchase of right shares after obtaining the approval of the RB…

STATE BANK OF INDIA,MUMBAI vs. ACIT CIR 2(2),

In the result, appeal of the revenue is dismissed

ITA 4736/MUM/2010[1999-2000]Status: DisposedITAT Mumbai31 Jan 2018AY 1999-2000

Bench: Shri G.S. Pannu & Shri Pawan Singhstate Bank Of India Acit Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent) Acit Circle (2)(2), State Bank Of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent)

For Respondent: Shri R.P. Meena (CIT-DR)
Section 14ASection 195Section 253Section 254(1)Section 36(1)(viia)Section 40Section 43D

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “A”, MUMBAI BEFORE SHRI G.S. PANNU, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER State Bank of India ACIT Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. PAN: AAACS8577K (Appellant) (Respondent) ACIT Circle (2)(2), State Bank of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. PAN: AAACS8577K (Appellant) (Respondent) Assessee by Shri Girish Dave & Urvi : Mehta (AR) Revenue by…

ACIT CIR 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result, appeal of the revenue is dismissed

ITA 4598/MUM/2010[1999-00]Status: DisposedITAT Mumbai31 Jan 2018AY 1999-00

Bench: Shri G.S. Pannu & Shri Pawan Singhstate Bank Of India Acit Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent) Acit Circle (2)(2), State Bank Of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent)

For Respondent: Shri R.P. Meena (CIT-DR)
Section 14ASection 195Section 253Section 254(1)Section 36(1)(viia)Section 40Section 43D

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “A”, MUMBAI BEFORE SHRI G.S. PANNU, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER State Bank of India ACIT Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. PAN: AAACS8577K (Appellant) (Respondent) ACIT Circle (2)(2), State Bank of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. PAN: AAACS8577K (Appellant) (Respondent) Assessee by Shri Girish Dave & Urvi : Mehta (AR) Revenue by…

Laurids Knudsen Maskinfabrik Ltd Vs ITO (77 ITD 212), SSI Ltd. v. DCIT ( (222 ITR 528) — Cited in 15 Judgments | BharatTax