How many judgments cite Liberty India v. CIT?

571 judgments on BharatTax cite Liberty India v. CIT (317 ITR 218), spanning 2009 to 2026.

Which sections of the Income Tax Act does Liberty India v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 14A, Section 10B, Section 80IB, Section 147, Section 80IA.

Liberty India v. CIT

317 ITR 218Supreme Court of India2009#109 most cited

What is Liberty India v. CIT authority for?

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

571

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2009 to 2026.

Also referred to as

Liberty India v. CIT · 317 ITR 218 · section 10B · section 80IA · section 80IB · profits derived from · direct nexus · eligible business · export undertaking deduction · sale of scrips income · interest income deduction

Also reported as

183 Taxmann 349

Sections most often in play

Section 143(3)Section 14A Section 10B Section 80IB Section 147 Section 80IA Section 1961 Section 250

Read the full judgment

Issues it is cited on

section 75 section 80h section 80hh section 80hhc section 80ic section 80ib eligible business deduction under section 80ia section 80i section 80ia disallowance u/s 14a gross total income

Judgments citing Liberty India v. CIT

ACIT, New Delhi vs. M/S. Nanda Maint & Pine Chamicals Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5063/DEL/2011[2008-09]Status: DisposedITAT Delhi08 Apr 2016AY 2008-09

Bench: Smt. Diva Singh & Sh. O.P. Kantassessment Year: 2009-10 M/S. Nanda Mint & Pine Vs. Asstt. Commissioner Of Income Tax, Chemicals Ltd., 1/10, Munshi Circle-13(1), New Delhi Niketan, Asaf Ali Road, Near Kamala Market, New Delhi Gir/Pan : Aaccn0965G (Appellant) (Respondent) Appellant By S/Sh. K. Sampath & Raj Kumar, Advocates Respondent By Sh. P. Dam Kanunjna, Sr.Dr & Assessment Year: 2008-09 Asstt. Commissioner Of Income Vs. M/S. Nanda Mint & Pine Chemicals Tax, Circle-13(1), Room No. 406, Ltd., 1/10, Munshi Niketan, Asaf Ali C.R. Building, I.P. Estate, New Road, Near Kamala Market, New Delhi Delhi Gir/Pan : Aaccn0965G (Appellant) (Respondent) Appellant By Smt. Parmita M. Biswas, Cit(Dr) Respondent By S/Sh. K. Sampath & Raj Kumar, Advocates Date Of Hearing 09.03.2016 Date Of Pronouncement 08.04.2016 Order Per O.P. Kant, A.M.: These Two Appeals Of The Revenue & The Assessee Are Preferred Against Two Separate Orders Dated 08.07.2011 & 14.11.2012 Of The Commissioner Of Income-Tax( Appeals)-Xvi, New Delhi For Assessment Year 2008-09 & 2009- Ays: 2008-09 & 2009-10 10 Respectively. Since The Common Issue Of Deduction Under Section 80Ib Of The Income-Tax Act, 1961 Is Involved In Both The Appeals, These Appeals Are Heard Together & Disposed Of By This Consolidated Order.

Section 143(2)Section 80Section 80I

…granted by the government and not part of the profit derived from the Industrial Undertaking and, therefore, it was not eligible for deduction under section 80-IB of the Act as held by the Hon’ble Apex Court in the case of Liberty India versus CIT reported in 317 ITR 218. 6.2 Before us, the ld. AR of the assessee relying on the submission made before the Ld. Commissioner of Income-tax(Appeals) submitted that the excise duty was part of the sale receipt and thus derived from the business of manufacturing activity. He further relied on the judgment of the Hon’ble Jurisdictional High Court in the case of CIT versus…

DCIT, Bangalore vs. M/S Keane International (India) Pvt. Ltd., Bangalore

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

ITA 1496/BANG/2013[2005-06]Status: DisposedITAT Bangalore06 Apr 2016AY 2005-06

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Chavali Narayan, CAFor Respondent: Shri G.R.Reddy, CIT(DR)

Section 92C

…of relief u/s 10A in respect of recruitment fees earned. The ld.CIT(A) upheld the action of the AO in denying deduction u/s 10A in respect of recruitment fees placing reliance on the decision of the Hon’ble Supreme Court in the case of Liberty India vs. CIT (317 ITR 218). The relevant finding of the ld.CIT(A) is as under: “From the abovementioned precedents, it is very clear that a receipt should have direct nexus with export activity, to be eligible for a deduction u/s 10A(1) read with section 10A(4) of the Act. I have considered the facts and circumstances of the case and find that the receipts on account of r…

DCIT 5(2), Mumbai vs. Lahoti Overseas Ltd, Mumbai

In the result, appeal of the assessee company in ITA

ITA 3812/MUM/2012[2003-04]Status: DisposedITAT Mumbai30 Mar 2016AY 2003-04

Bench: Shri Amit Shukla & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 3812/Mum/2012 ("नधा"रण वष" / Assessment Year : 2003-04) Dy. Commissioner Of Income M/S Lahoti Overseas Ltd., बनाम/ Tax , 5(2),Room No. 571, 307, Arun Chambers, V. 5 Th Floor, Tardeo Road, Tardeo, Aayakar Bhavan, Mumbai - 400034. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./Pan : Aaacl2578 H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri Yogesh TharFor Respondent: Shri Ganesh Bare (Sr.DR)

Section 133ASection 143(3)Section 147Section 148Section 151(1)

…ation which is not for generation of electricity but for non-performance of the power equipment and same cannot be allowed as deduction u/s 80IA of the Act. The ld Dr relied upon the decision of Hon’ble Supreme Court in the case of Liberty India Limited(2009) 317 ITR 218(SC) 49. We have considered the rival contentions and also perused the material available on record. We have observed that from the facts which are emerging from the records and orders of the authorities below and submissions made by both the counsels, it is observed that the assessee company has received ITA 3813/M/12, 821/M/14, 93 ITA 3812/M…

Ann Kumar, New Delhi vs. DCIT, New Delhi

ITA 2756/DEL/2015[2005-06]Status: DisposedITAT Delhi30 Mar 2016AY 2005-06

Bench: Shri R.S. Syal & Shri Kuldip Singh

For Appellant: Shri Sanat Kapoor and Ms. Ananya Kapoor, AdvocatesFor Respondent: Shri Deepak Tiwari, Senior DR

Section 10BSection 143Section 143(3)Section 148Section 234B

…arned duty drawback of Rs.3,72,186/- and claimed deduction u/s 10BA at Rs.16,74,971/- which has been allowed after due scrutiny. Finding the explanation of the assessee not tenable and by relying upon the judgment cited as Liberty India vs. CIT reported in 317 ITR 218 (SC) disallowed the deduction of Rs.16,74,971/- earlier allowed by the AO vide order u/s 143(3) of the Act and thereby the assessed the total income of assessee at Rs.10,85,634/-. 3. Assessee carried the matter before the ld. CIT (A) who has dismissed the appeal vide impugned order. Feeling aggrieved, the assessee has come up before the Tribunal…

Commissioner of Income Tax-III vs. M/S Subhash Kabini Power Corporation Limited

ITA/169/2015HC Karnataka29 Mar 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260Section 263Section 80I

…Whether on the facts and in the circumstances of the case, the Tribunal was justified in law in quashing the order under Section 263 of the Income Tax Act without appreciating the judgment of Supreme Court in the case of M/s.Liberty India v. CIT [317 ITR 218] and M/s. Sterling Foods v. CIT [237 ITR 579] that any ancillary profits should be excluded from the meaning of profits derived from the eligible business for the purpose of deduction under Section 80IA and the consideration received from the sale of carbon credits is not derived from the eligible business undertakings? 2. Whethe…

DCIT, New Delhi vs. Global Vantedge Pvt. Ltd., New Delhi

In the result, Appeal filed by the Revenue Stands dismissed

ITA 6105/DEL/2013[2005-06]Status: DisposedITAT Delhi15 Mar 2016AY 2005-06

Bench: Shri H.S. Sidhu & Shri J.S. Reddyassessment Year: 2005-06

For Appellant: Sh. T. Vasanthan, Sr. DRFor Respondent: Sh. Mayank Aggarwal, CA

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI J.S. REDDY, ACCOUNTANT MEMBER Assessment Year: 2005-06 DCIT, CIRCLE 12(1), vs. M/s Global Vantedge Pvt Ltd., New Delhi A-16/9, Vasant Vihar, NEW DELHI – 57 (PAN: AABCR8435J) (APPELLANT) (RESPONDENT) Appellant by : Sh. T. Vasanthan, Sr. DR Respondent by : Sh. Mayank Aggarwal, CA Date of Hearing : 15-03-2016 Date of Order : 15-03-2016 ORDER PER H.S. SIDHU, J.M. This appeal by the Department is directed against the Order dated 05.8.2013 of Ld. CIT(A)-XV, New Delhi pertaining to assessment year 2…

ITO 9(1)(4), Mumbai vs. Gleg Engineers P. Ltd, Mumbai

In the result, appeals for A

ITA 7008/MUM/2013[2003-04]Status: DisposedITAT Mumbai29 Jan 2016AY 2003-04

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri M. SubramanianFor Respondent: Shri Nitin Waghmode

Section 271(1)(c)Section 80I

…laim of deduction under section 80IA(4), by keeping in view the decision of the Bombay High Court in case of CIT v/s ABG Heavy Industries Ltd.,[2010] 322 ITR 323 (Bom.) as well as the decision of the Hon'ble Supreme Court in Liberty India Ltd. v/s CIT, [2009] 317 ITR 218 (SC). He, therefore, submitted as the basis on which the penalty was imposed no longer exist in view of the order passed by the Tribunal, penalty imposed under section 271(1)(c) cannot survive. M/s. Gleg Engineers Pvt. Ltd. 4 4. Learned Departmental Representative has not controverted the fact that the issue in quantum proceedings has been resto…

Addl CIT RG 2(1), Mumbai vs. Aristo Pharmaceuticals P. Ltd, Mumbai

In the result, Revenue’s appeals are partly allowed

ITA 4097/MUM/2009[2005-06]Status: DisposedITAT Mumbai29 Jan 2016AY 2005-06

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri Ajay Kumar RastogiFor Respondent: Shri Amol Kamat

Section 80I

…ered to be having any nexus with the business of new industrial undertaking of the assessee so as to qualify for deduction under section 80IB. For such proposition, he relied upon the decision of the Hon'ble Supreme Court in Liberty India Ltd. v/s CIT, [2009] 317 ITR 218 (SC). Further, he submitted, the information obtained from the bank authorities clearly revealed that the FDR kept as margin money amounted to ` 28.01 crore, therefore, the Assessing Officer following the order of the Tribunal in assessee’s own case in letter and spirit has properly worked out the deduction under section 80IB as far as interest i…

ACIT, Haridwar vs. M/S. Metro Frozen Fruit & Vegetables P Ltd., Roorkee

In the result, the appeal of the revenue is dismissed

ITA 1163/DEL/2013[2009-10]Status: DisposedITAT Delhi28 Jan 2016AY 2009-10

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiin Ita No. 1163/Del/2013 (Assessment Year: 2009-10)

For Appellant: Sh. P.Dam Kanunjna, Sr. DRFor Respondent: Sh.Ajay Wadhwa, Adv

Section 80Section 80I

…ctions are to be liberally construed. It was also one of the arguments that even in the case of Job worker and in the case of Works Contact deduction u/s 80IC is allowed. Regarding the decision of the Hon‟ble Supreme Court in the case of Liberty India Vs. CIT 183 Taxmann 349 (SC) raised in one of the grounds of this appeal that Hon‟ble Supreme Court has answered this issue with respect to claim of DEPB/ duty Drawback are not part of the profit of the industrial undertaking and it held that it is not eligible for deduction. He submitted that in this case the income itself is from the undertaking and therefore has…

ACIT 8(3) (OSD), Mumbai vs. Dodson Lindblom Hydro Power P. Lt, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5932/MUM/2010[2007-08]Status: DisposedITAT Mumbai13 Jan 2016AY 2007-08

Bench: Shri D. Karunakara Rao & Shri Sandeep Gosaini.T.A. No.5932/M/2010 (Assessment Year: 2007-2008) फनाभ/ Dcit-8(1), Dodson Lindblom Hydro R.No.210, 2 Nd Floor, Power Pvt Ltd., Vs. Aayakar Bhavan, 6, Shiv Wastu, M.K. Road, Mumbai – 40 020. Tejpal Scheme, Road No.5, Vile Parle (E), Mumbai-57. स्थामी रेखा सं./ Pan : Aaacd7612A (अऩीराथी /Appellant) .. (प्रत्मथी / Respondent) C.O.128/M/11 (Arising Out Of I.T.A. No.5932/M/2010(Ay: 2007-2008) I.T.A. No.7716/M/2011 (Assessment Year: 2008-2009) I.T.A. No.5933/M/2012 (Assessment Year: 2009-2010) Dodson Lindblom Hydro Power फनाभ/ Dcit-8(1), R.No.210, 2 Nd Floor, Pvt Ltd., 6, Shiv Wastu, Vs. Tejpal Scheme, Road No.5, Aayakar Bhavan, Vile Parle (E), Mumbai-57. M.K. Road, Mumbai–400020. स्थामी रेखा सं./ Pan : Aaacd7612A (अऩीराथी /Appellant) .. (प्रत्मथी / Respondent) अऩीराथी की ओय से / Assessee By : Shri Farrokh Irani प्रत्मथी की ओय से/ Revenue By : Shri B.S. Bist, Dr

For Appellant: Shri Farrokh IraniFor Respondent: Shri B.S. Bist, DR

Section 80I

…n in this regard u/s 80IA of the Act in respect of these receipts as these receipts are the integral part of the power generation project. CIT (A) granted the deduction relying on the judgment of the Hon‟ble Supreme Court in the case of Liberty India vs. CIT (317 ITR 218). While grating deduction, CIT (A) held that the carbon credit is a by product of generation of hydro electric power and the same is eligible for deduction u/s 80IA(4) of the Act. The contents of para 1.5 of the CIT (A)‟s order are relevant in this regard. On these facts, both the parties brought our attention to the judgment of the Hon‟ble High…

D.C.I.T. RG.8(3), Mumbai vs. State Street Syntel Services Pvt. Ltd., Mumbai

In the result, the Revenue’s appeal for assessment year 2007-08

ITA 7610/MUM/2011[2007-08]Status: DisposedITAT Mumbai06 Jan 2016AY 2007-08

For Appellant: Shri Vivek OjhaFor Respondent: Shri Dinesh Vyas

Section 10ASection 143(1)Section 143(3)Section 28

…services without appreciating the facts of the case.", 3 "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not appreciating the ratio, of the judgement of the Hon'ble Apex Court in the case of Liberty India Ltd. vs. CIT (317 ITR 218) wherein it is held that certain income may constitute profit from business under section 28 but it cannot be construed as profits derived from Industrial undertaking and the decision of Hon'ble ITAT, 'E' Bench, Mumbai, in the case of Tricom India Limited vs. 'ACIT (36 SOT 302) wherein it is held that interest income is not eligible for deduction…

M/S. Sicgil India Ltd., Chennai vs. ACIT, Chennai

In the result, the appeal of the assessee is dismissed

ITA 877/CHNY/2011[2006-2007]Status: DisposedITAT Chennai18 Dec 2015AY 2006-2007

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri Pathlavath Peerya, CIT

Section 80

…to the extent of `2,08,43,604/-. Referring to the Sales Tax and Central Excise Duty, the Ld.counsel submitted that the Commissioner directed the Assessing Officer to examine the issue in the light of the judgment of Apex Court in Liberty India Ltd. v. CIT (317 ITR 218). According to the Ld. counsel, the Assessing Officer allowed the claim of the assessee after considering the entire facts of the case. In fact, a questionnaire was issued to the assessee and the assessee has filed all the details called for by the Assessing Officer. For the assessment year 2010- 11, an identical issue came before this Tribuna…

Monsanto India Ltd, Mumbai vs. Addl CIT RG 8(2), Mumbai

In the result, appeal of the revenue is dismissed, whereas appeal of the assessee is allowed in part

ITA 8545/MUM/2010[2006-07]Status: DisposedITAT Mumbai16 Dec 2015AY 2006-07

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm आमकय अऩीर सं./Ita No.8338/Mum/2010 (नििाारण वषा / Assessment Year :2006-2007) Adcit-8(2), Mumbai Vs. M/S Monsanto India Limited, 5Th Floor, Ahura Centre, 96, Mahakali Caves Road, Andheri (East) Mumbai- 400093 स्थामी रेखा सं./ जीआइआय सं./ Pan/Gir No. : Aaacm 2875 L (अऩीराथी /Appellant) (प्रत्मथी / Respondent) .. & आमकय अऩीर सं./Ita No.8545/Mum/2010 (नििाारण वषा / Assessment Year :2006-2007) M/S Monsanto India Limited, 5Th Vs. Acit-8(2), Mumbai Floor, Ahura Centre, 96, Mahakali Caves Road, Andheri (East) Mumbai-400093 स्थामी रेखा सं./ जीआइआय सं./ Pan/Gir No. : Aaacm 2875 L (अऩीराथी /Appellant) (प्रत्मथी / Respondent) .. याजस्व की ओर से /Revenue By : Shri N.P.Singh ननधाारयती की ओर से /Assessee By : Shri Rajan Vora सुनवाई की तायीख / Date Of Hearing : 14/09/2015 घोषणा की तायीख/Date Of Pronouncement 14/12/2015 आदेश / O R D E R Per R.C.Sharma (A.M):

For Appellant: Shri Rajan VoraFor Respondent: Shri N.P.Singh

Section 10(1)Section 145ASection 14ASection 2(1)(a)Section 234BSection 80I

…the deduction u/s. 80IB of Rs.44,89,828/- related to scrap sales as the said receipt was not derived from the industrial undertaking and hence not eligible for deduction u/s. 80IB of the Act, in view of Apex Court's decision in the case of Liberty India Ltd. (317 ITR 218(SC)". 4. The assessee in its appeal has taken following grounds :- 1. On the facts and in the circumstances of the case and in law, the Commissioner of Income-tax (Appeals) erred in upholding the action of the Assessing Officer in allocating 30% of the corporate expenses to. 80-18 units against the allocation of 10% made by the appellant in the r…

Tufropes P.Ltd, Mumbai vs. DCIT Cir 3(3), Mumbai

In the result, both the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 7469/MUM/2012[2008-09]Status: DisposedITAT Mumbai11 Dec 2015AY 2008-09

Bench: Shri N.K. Billaiya & Shri Sanjay Garg

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri K.L. Kanak, D.R

Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “E”, MUMBAI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI SANJAY GARG, JUDICIAL MEMBER ITA Nos.7469 & 7470/M/2012 Assessment Years: 2008-09 & 2009-10 M/s. Tufropes Pvt. Ltd., The Assistant Commissioner of 812-A, Embassy Centre, Income Tax, Circle 3(3), Vs. Nariman Point, Aayakar Bhavan, Mumbai – 400 021 Mumbai - 400020 PAN: AAACT 8968M (Appellant) (Respondent) Present for: Assessee by : Shri Vijay Mehta, A.R. Revenue by : Shri K.L. Kanak, D.R. Date of Hearing : 01.10.2015 Date of Pronouncement : 11.12.2015 O R D E R Per Sanjay Garg, Judicial Member: Th…

Prince Pipe & Fittings P. Ltd, Mumbai vs. DCIT RG 7(1), Mumbai

In the result, appeal of the assessee is dismissed

ITA 7559/MUM/2013[2005-06]Status: DisposedITAT Mumbai09 Dec 2015AY 2005-06

For Appellant: Ms. Mrugakshi JoshiFor Respondent: Shri Durga Dutt

Section 80I

…594/-. AO and the CIT (A) denied the benefit of deduction on such receipts received on account of duty drawback scheme. For this proposition, the AO and the CIT (A) relied on the judgment of the Hon’ble Supreme Court in the case of M/s. Liberty India vs. CIT [317 ITR 218] (SC) and many other precedents in their support. Aggrieved with the above, assessee is in appeal before the Tribunal. 3. During the proceedings before us, at the outset, Ld Counsel for the assessee submitted that in view of the above cited Apex Court judgment in the case of Liberty India (supra), the appeal filed by the assessee is not pressed.…

ACIT 21(1), Mumbai vs. Asha K. Ringshia, Mumbai

Appeal of the Revenue is dismissed

ITA 4082/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Dec 2015AY 2009-10

Bench: Shri Joginder Singh & Shri Rajendraassessment Year- 2009-10 The Acit 21(1), Room No. Asha K. Ringshia, 601, 6Th Floor, C-10 3Rd Floor, Pandurang Sadan, बनाम/ Pratyakshakar Bhavan, Hanuman Road, Mumbai- 57 Vs. Bandra Kurla Complex, Bandra(E), Mumbai- 51 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No.Aacpr3758C

Section 80Section 80I

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ,बी,मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “A”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी राजे"", लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri Rajendra, Accountant Member Assessment Year- 2009-10 The ACIT 21(1), Room No. Asha K. Ringshia, 601, 6th Floor, C-10 3rd Floor, Pandurang Sadan, बनाम/ Pratyakshakar Bhavan, Hanuman Road, Mumbai- 57 Vs. Bandra Kurla Complex, Bandra(E), Mumbai- 51 (राज"व /Revenue) ("नधा"रती /Assessee) PAN. No.AACPR3758C राज"व क" ओर से / Revenue by Shri Mohammed Rizwan "नधा"रती क" ओर से / Assessee by Shri Rakes…

J.P. Morgan Services India P.Ltd, Mumbai vs. Asst CIT (OSD) 8(1), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 7822/MUM/2011[2007-08]Status: DisposedITAT Mumbai30 Nov 2015AY 2007-08

Bench: Shri Amit Shukla & Shri Ashwani Tanejaassessment Year: 2006-07 & Assessment Year: 2007-08 J.P. Morgan Services P. Ltd., Dcit (Osd)-8(1) Technopolis Knowledge Park, Mumbai- बनाम/ 3Rd Floor, Mahakali Caves Vs. Road, Chakala Junction, Andheri(E) Mumba-400093 (Assessee) (Revenue) P.A. No.Aabcd0503B

…sessee’s own case for A.Ys. 2004-05 and 2005- 06. On the other hand, Ld. DR has submitted that the interest income cannot be said to be derived from exports. He has placed reliance upon the judgments of Hon’ble Supreme Court in the case of Liberty India Ltd. 317 ITR 218 and Pandian Chemicals Ltd. vs. CIT 262 ITR 278 (SC). He has also read before us provisions of section 10A(1)(iv) for the proposition that legislature has used the expression ‘derive’ and Supreme Court has carefully considered scope and meaning of this expression in the case of Liberty India Ltd., (supra). He further submitted that the object of t…

J.P . Morgan Services India P. Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 8987/MUM/2010[2006-07]Status: DisposedITAT Mumbai30 Nov 2015AY 2006-07

M/S. Procter & Gamble Hygiene & Health Care Ltd vs. The Dy CIT Cir 7(1)

In the result, both the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1500/MUM/2005[2001-2002]Status: DisposedITAT Mumbai27 Nov 2015AY 2001-2002

Bench: S/Shri D. Karunakara Rao & Sanjay Gargसव"ी डी. क"णाकर राव, लेखा सद"य एवं संजय गग", "या"यक सद"य

For Appellant: Shri G M Doss

Section 80I

…th a direction that the same be decided in the light of decision of jurisdictional High Court in the case of Associated Capsules P Limited V/s Dy.CIT (2011)332 ITR 42(Bom) and the decision of Hon’ble Apex Court in the case of Liberty India V/s CIT reported in 317 ITR 218 (SC). 3. The ld.AR of the assessee, at the outset, has invited our attention to a chart submitted by him, wherein the details of the nature of items of other income have been mentioned which we will deal hereby one by one. The first four items are related to the following interest income: 3 I.T.A. No.1500 /M um /20 05 ITA No.8999 /M /200 4 a)…

M/S. Procter & Gamble Hygiene & Health Care Ltd vs. The Addl CIT RG 7(1)

In the result, both the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 8999/MUM/2004[2000-2001]Status: DisposedITAT Mumbai27 Nov 2015AY 2000-2001

Bench: S/Shri D. Karunakara Rao & Sanjay Gargसव"ी डी. क"णाकर राव, लेखा सद"य एवं संजय गग", "या"यक सद"य

For Appellant: Shri G M Doss

Section 80I