What is Madras Industrial Investment Corporation Ltd. v. CIT authority for?

Expenditure that provides an enduring benefit should be amortized over its useful life, not allowed as a deduction in a single year, to prevent a distorted picture of profits. Specifically, premium paid on debentures for their issue should be amortized on a straight-line method over the life of the debentures.

Which sections of the Income Tax Act does Madras Industrial Investment Corporation Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 37(1), Section 153A, Section 147, Section 153C, Section 132.

Madras Industrial Investment Corporation Ltd. v. CIT (225 ITR 802)

Q: How many judgments cite Madras Industrial Investment Corporation Ltd. v. CIT?

568 judgments on BharatTax cite Madras Industrial Investment Corporation Ltd. v. CIT (225 ITR 802), spanning 2008 to 2026.

M/S. Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

In the result, all the five appeals of the assessee stand

ITA 3112/DEL/2013[2004-05]Status: DisposedITAT Delhi19 Nov 2018AY 2004-05

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2001-02 Assessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2005-06 Assessment Year: 2006-07

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Pradeep Singh Gautam, Sr.DR

Section 143(3)

…cture of profits in a particular year. While making the disallowance, the Assessing Officer has also placed reliance on the judgment of the Hon’ble Apex Court in the case of Madras Industrial Investment Corporation vs. Commissioner of Income Tax reported in 225 ITR 802 (SC). The Ld. Commissioner of Income Tax (A), while upholding the disallowance, also seconded the view taken by the Assessing Officer. Thus, apart from observing that the impugned fees gave an enduring benefit to the assessee company and, therefore, the allowability of expenditure had to be spread over 5 years, the lower authorities have not gi…

M/S. Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

In the result, all the five appeals of the assessee stand

ITA 3111/DEL/2013[2003-04]Status: DisposedITAT Delhi19 Nov 2018AY 2003-04

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2001-02 Assessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2005-06 Assessment Year: 2006-07

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Pradeep Singh Gautam, Sr.DR

Section 143(3)

…cture of profits in a particular year. While making the disallowance, the Assessing Officer has also placed reliance on the judgment of the Hon’ble Apex Court in the case of Madras Industrial Investment Corporation vs. Commissioner of Income Tax reported in 225 ITR 802 (SC). The Ld. Commissioner of Income Tax (A), while upholding the disallowance, also seconded the view taken by the Assessing Officer. Thus, apart from observing that the impugned fees gave an enduring benefit to the assessee company and, therefore, the allowability of expenditure had to be spread over 5 years, the lower authorities have not gi…

M/S Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

In the result, all the five appeals of the assessee stand

ITA 5847/DEL/2010[2001-02]Status: DisposedITAT Delhi19 Nov 2018AY 2001-02

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2001-02 Assessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2005-06 Assessment Year: 2006-07

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Pradeep Singh Gautam, Sr.DR

Section 143(3)

…cture of profits in a particular year. While making the disallowance, the Assessing Officer has also placed reliance on the judgment of the Hon’ble Apex Court in the case of Madras Industrial Investment Corporation vs. Commissioner of Income Tax reported in 225 ITR 802 (SC). The Ld. Commissioner of Income Tax (A), while upholding the disallowance, also seconded the view taken by the Assessing Officer. Thus, apart from observing that the impugned fees gave an enduring benefit to the assessee company and, therefore, the allowability of expenditure had to be spread over 5 years, the lower authorities have not gi…

M/S Kanoria Chemicals & Industries Ltd., Kolkata vs. DCIT, Cir-10, Kolkata

ITA 238/KOL/2015[2010-2011]Status: DisposedITAT Kolkata16 Nov 2018AY 2010-2011

Bench: Sri J. Sudhakar Reddy & Smt. Madhumita Roy]

Section 250

…held that, the actual payment need to be done on the redemption of these FCCBs and entries need not be made every year. He applied the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. Commissioner of Income-tax 225 ITR 802 SC and upheld the claim of the assessee. He pointed out that tax has been deducted at source in the year of redemption of bonds and hence was of the view that no tax need be deducted every year. He held that the assessee was entitled to deduction of the premium on yearly basis by relying on the order of the Bangalore Bench of the Tribunal in the…

DCIT, Circle-10, Kolkata vs. M/S. Kanoria Chemicals & Industries Ltd., Kolkata

ITA 2086/KOL/2014[2009-2010]Status: DisposedITAT Kolkata16 Nov 2018AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Smt. Madhumita Roy]

Section 250

…held that, the actual payment need to be done on the redemption of these FCCBs and entries need not be made every year. He applied the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. Commissioner of Income-tax 225 ITR 802 SC and upheld the claim of the assessee. He pointed out that tax has been deducted at source in the year of redemption of bonds and hence was of the view that no tax need be deducted every year. He held that the assessee was entitled to deduction of the premium on yearly basis by relying on the order of the Bangalore Bench of the Tribunal in the…

M/S. Kanoria Chemicals & Industries Ltd., Kolkata vs. Addl. CIT, Range-10, Kolkata

ITA 1880/KOL/2014[2009-2010]Status: DisposedITAT Kolkata16 Nov 2018AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Smt. Madhumita Roy]

Section 250

…held that, the actual payment need to be done on the redemption of these FCCBs and entries need not be made every year. He applied the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. Commissioner of Income-tax 225 ITR 802 SC and upheld the claim of the assessee. He pointed out that tax has been deducted at source in the year of redemption of bonds and hence was of the view that no tax need be deducted every year. He held that the assessee was entitled to deduction of the premium on yearly basis by relying on the order of the Bangalore Bench of the Tribunal in the…

DCIT, Cir-10(1), Kolkata vs. Kanoria Chemicals & Industries Ltd., Kolkata

ITA 271/KOL/2015[2010-2011]Status: DisposedITAT Kolkata16 Nov 2018AY 2010-2011

Bench: Sri J. Sudhakar Reddy & Smt. Madhumita Roy]

Section 250

…held that, the actual payment need to be done on the redemption of these FCCBs and entries need not be made every year. He applied the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. Commissioner of Income-tax 225 ITR 802 SC and upheld the claim of the assessee. He pointed out that tax has been deducted at source in the year of redemption of bonds and hence was of the view that no tax need be deducted every year. He held that the assessee was entitled to deduction of the premium on yearly basis by relying on the order of the Bangalore Bench of the Tribunal in the…

Ecof Industries P Ltd., Chennai vs. DCIT Corporate Circle 2(1), Chennai

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

ITA 2358/CHNY/2017[2007-08]Status: DisposedITAT Chennai31 Oct 2018AY 2007-08

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.2358/Chny/2017 िनधा"रण वष"/Assessment Year:2007-2008 M/S. Ecof Industries P. Ltd., The Deputy Commissioner Of New No. 3, Old No. 46, Bheema Vs. Income Tax, Garden Street, Abhiramapuram, Corporate Circle 2(1), Chennai 600 016. Chennai. [Pan:Aaace2287Q] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 23.10.2018 घोषणा की तारीख /Date Of Pronouncement : 31.10.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai Dated 18.08.2017 Relevant To The Assessment Year 2007-08. In This Appeal, The Assessee Has Raised Three Effective Grounds Viz., (I) The Ld. Cit(A) Has Erred In Confirming The Addition Of ₹.20,69,570/- Made Under Section 14A R.W. Rule 8D & (Ii) The Ld. Cit(A) Has Erred In Confirming The Addition Of Notional Interest At 2

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri AR.V. Sreenivasan, JCIT

Section 143(3)Section 14A

…आयकर अपीलीय अिधकरण, “ए” "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी अ"ाहम पी. जॉज", लेखा सद" एवं "ी धु"ु" आर.एल रे"ी, "ाियक सद" के सम" Before Shri Abraham P. George, Accountant Member & Shri Duvvuru RL Reddy, Judicial Member आयकर अपील सं./I.T.A.No.2358/Chny/2017 िनधा"रण वष"/Assessment Year:2007-2008 M/s. ECOF Industries P. Ltd., The Deputy Commissioner of New No. 3, Old No. 46, Bheema Vs. Income Tax, Garden Street, Abhiramapuram, Corporate Circle 2(1), Chennai 600 016. Chennai. [PAN:AAACE2287Q] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri S. Sridhar, Ad…

DCIT, Cir-11(1), Kolkata vs. M/S Haldia Petrochemicals Ltd., Kolkata

In the result, this appeal of the revenue is dismissed

ITA 1976/KOL/2016[2003-04]Status: DisposedITAT Kolkata30 Oct 2018AY 2003-04

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi) Assessment Year: 2003-04 Deputy Commissioner Of Income Tax, Circle-11(1), Kolkata.……......………..…..................Appellant Vs. M/S. Haldia Petrochemicals.....……………...........…………..……………………...……..….…….......Respondent Bengal Eco Intelligent Park (Techno) Tower-1, Block-Em Plot No. 3 Salt Lake City Sector-V, 3Rd Floor Kolkata -91 [Pan : Aaach 7360 R]

Section 250

…evenue expenditure in the act and assessee can claim the deduction of the amount incurred before the commencement of commercial production over a number of years. Hon'ble Supreme Court in case of Madras Industrial Investment Corporation Limited vs. CIT [1997] 225 ITR 802 (SC) has also upheld the principle of deferred revenue expenses. The ld. AR also pleaded that the deferred revenue expenses can also be allowed to be capitalized under section 32 of the Act. 17. From the aforesaid discussion, we find that the assessee has incurred expenses prior to the commencement of business and classified as deferred revenue e…

S.Arjun, Chennai vs. ACIT Non Corporate Ward 20(1), Chennai

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

ITA 2220/CHNY/2018[2010-11]Status: DisposedITAT Chennai23 Oct 2018AY 2010-11

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

For Appellant: Shri. Saroj Kumar Parida, Advocate

Section 36(2)

…which is a " loss" even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court has been approved by this court in the case of Madras Industrial Investment Corporation Ltd. v. CIT reported in [1997] 225 ITR 802 . According to the Law and Practice of Income Tax by Kanga and Palkhivala, section 37(1) is a residuary section extending the allowance to items of business expenditure not covered by sections 30 to 36. This section, according to the learned author, covers cases of business expenditure only, and not of business losses which are, however, deductib…

JCIT, Rang-2, Kota vs. Chambal Fertilisers and Chemicals Limited, Kota

In the result, respective grounds of appeal are allowed for statistical purposes

ITA 575/JPR/2015[2011-12]Status: DisposedITAT Jaipur17 Oct 2018AY 2011-12

For Appellant: Shri Percy Pardiwala (Adv.)For Respondent: Shri Varinder Mehta (CIT)

Section 14A

…assessment year in question, it was even quantified and discharged as well in that very accounting year. M/s Chambal Fertilizers & Chemicals Ltd. Vs. ACIT 16) Judgment in Madras Industrial Investment Corporation Limited v. Commissioner of Income Tax, (1997) 4 SCC 666 was cited by the learned counsel for the Revenue to justify the decision taken by the courts below. We find that the Court categorically held even in that case that the general principle is that ordinarily revenue expenditure incurred wholly and exclusively for the purpose of business is to be allowed in the year in which it is incurred. However, s…

Chambal Fertilisers and Chemicals Limited, Kota vs. JCIT, Kota

In the result, respective grounds of appeal are allowed for statistical purposes

ITA 461/JPR/2015[2011-12]Status: DisposedITAT Jaipur17 Oct 2018AY 2011-12

For Appellant: Shri Percy Pardiwala (Adv.)For Respondent: Shri Varinder Mehta (CIT)

Section 14A

…assessment year in question, it was even quantified and discharged as well in that very accounting year. M/s Chambal Fertilizers & Chemicals Ltd. Vs. ACIT 16) Judgment in Madras Industrial Investment Corporation Limited v. Commissioner of Income Tax, (1997) 4 SCC 666 was cited by the learned counsel for the Revenue to justify the decision taken by the courts below. We find that the Court categorically held even in that case that the general principle is that ordinarily revenue expenditure incurred wholly and exclusively for the purpose of business is to be allowed in the year in which it is incurred. However, s…

M/S. Biotronik Medical Devices India Pvt. Ltd., New Delhi vs. ITO, New Delhi

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

ITA 2427/DEL/2015[2009-10]Status: DisposedITAT Delhi12 Oct 2018AY 2009-10

Bench: Smt. Diva Singh & Shri O.P. Kantassessment Year: 2009-10

Section 133ASection 143(2)Section 143(3)

…mpany’s business, the large sum of expenses incurred on advertisement and sales promotion should be capitalized. The Assessing Officer relied on the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corporation Limited Vs. CIT (225 ITR 820), wherein at the instance of the assessee benefit of spread of expenses over a number of years was allowed. The Ld. CIT(A) also upheld the disallowance keeping in view the above decision of the Hon’ble Supreme Court. 7.1 Before us, the Ld. counsel of the assessee submitted that in the said decision of the Hon’ble Supreme Court in the case of Madr…

Moserbaer India Ltd., New Delhi vs. DCIT, New Delhi

Appeal is dismissed

ITA 1617/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Oct 2018AY 2010-11

Bench: Shri N. K. Saini & Ms Suchitra Kamblemoserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Moserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Astt. Commissioner Of Income Tax Vs Moserbaer India Ltd. Circle 5(1) Tax, 43-A, Okhla Indl Area, New Delhi Phase-Iii New Delhi-110020 (Appellant) Aaam0322J (Respondent) Moserbaer India Ltd. Vs Dcit Tax, 43-A, Okhla Indl Area, Circle 17(1) Phase-Iii New Delhi New Delhi-110020 (Respondent) Aaam0322J (Appellant)

Section 10BSection 143Section 144CSection 14A

…ground that the liability was not ascertainable. The Assessment Order was confirmed by the CIT(A). However, the Tribunal overruled the CIT(A)’s order in view of the judgment of the Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT: 225 ITR 802. On further appeal, the High Court affirmed the decision of the Tribunal by holding that, since, during the relevant assessment year, no as deduction. The Ld. AR also relied upon the following decisions: • CIT vs Shree Rajasthan Syntex Ltd.: 269 ITR 461 (Rajasthan High Court) • CIT vs Torrent Pharmaceuticals Ltd.: 393 ITR 625 (Gujarat High Court)…

M/S. Moserbaer India Ltd., New Delhi vs. ACIT, New Delhi

Appeal is dismissed

ITA 2395/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Oct 2018AY 2009-10

Bench: Shri N. K. Saini & Ms Suchitra Kamblemoserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Moserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Astt. Commissioner Of Income Tax Vs Moserbaer India Ltd. Circle 5(1) Tax, 43-A, Okhla Indl Area, New Delhi Phase-Iii New Delhi-110020 (Appellant) Aaam0322J (Respondent) Moserbaer India Ltd. Vs Dcit Tax, 43-A, Okhla Indl Area, Circle 17(1) Phase-Iii New Delhi New Delhi-110020 (Respondent) Aaam0322J (Appellant)

Section 10BSection 143Section 144CSection 14A

…ground that the liability was not ascertainable. The Assessment Order was confirmed by the CIT(A). However, the Tribunal overruled the CIT(A)’s order in view of the judgment of the Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT: 225 ITR 802. On further appeal, the High Court affirmed the decision of the Tribunal by holding that, since, during the relevant assessment year, no as deduction. The Ld. AR also relied upon the following decisions: • CIT vs Shree Rajasthan Syntex Ltd.: 269 ITR 461 (Rajasthan High Court) • CIT vs Torrent Pharmaceuticals Ltd.: 393 ITR 625 (Gujarat High Court)…

ACIT, New Delhi vs. M/S. Moser Baer India Limited, New Delhi

Appeal is dismissed

ITA 1200/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Oct 2018AY 2009-10

Bench: Shri N. K. Saini & Ms Suchitra Kamblemoserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Moserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Astt. Commissioner Of Income Tax Vs Moserbaer India Ltd. Circle 5(1) Tax, 43-A, Okhla Indl Area, New Delhi Phase-Iii New Delhi-110020 (Appellant) Aaam0322J (Respondent) Moserbaer India Ltd. Vs Dcit Tax, 43-A, Okhla Indl Area, Circle 17(1) Phase-Iii New Delhi New Delhi-110020 (Respondent) Aaam0322J (Appellant)

Section 10BSection 143Section 144CSection 14A

…ground that the liability was not ascertainable. The Assessment Order was confirmed by the CIT(A). However, the Tribunal overruled the CIT(A)’s order in view of the judgment of the Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT: 225 ITR 802. On further appeal, the High Court affirmed the decision of the Tribunal by holding that, since, during the relevant assessment year, no as deduction. The Ld. AR also relied upon the following decisions: • CIT vs Shree Rajasthan Syntex Ltd.: 269 ITR 461 (Rajasthan High Court) • CIT vs Torrent Pharmaceuticals Ltd.: 393 ITR 625 (Gujarat High Court)…

Moserbaer India Ltd., New Delhi vs. ACIT, New Delhi

Appeal is dismissed

ITA 6042/DEL/2012[2008-09]Status: DisposedITAT Delhi03 Oct 2018AY 2008-09

Bench: Shri N. K. Saini & Ms Suchitra Kamblemoserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Moserbaer India Ltd. Vs Assistant Commissioner Of Tax, 43-A, Okhla Indl Area, Income Tax Phase-Iii Circle 5(1) New Delhi-110020 New Delhi Aaam0322J (Respondent) (Appellant) Astt. Commissioner Of Income Tax Vs Moserbaer India Ltd. Circle 5(1) Tax, 43-A, Okhla Indl Area, New Delhi Phase-Iii New Delhi-110020 (Appellant) Aaam0322J (Respondent) Moserbaer India Ltd. Vs Dcit Tax, 43-A, Okhla Indl Area, Circle 17(1) Phase-Iii New Delhi New Delhi-110020 (Respondent) Aaam0322J (Appellant)

Section 10BSection 143Section 144CSection 14A

…ground that the liability was not ascertainable. The Assessment Order was confirmed by the CIT(A). However, the Tribunal overruled the CIT(A)’s order in view of the judgment of the Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT: 225 ITR 802. On further appeal, the High Court affirmed the decision of the Tribunal by holding that, since, during the relevant assessment year, no as deduction. The Ld. AR also relied upon the following decisions: • CIT vs Shree Rajasthan Syntex Ltd.: 269 ITR 461 (Rajasthan High Court) • CIT vs Torrent Pharmaceuticals Ltd.: 393 ITR 625 (Gujarat High Court)…

DCIT Corporate Circle 5(1), Chennai vs. Ramaniyam Real Estates P Ltd., Chennai

In the result, both the appeals of the Revenue are 12

ITA 2887/CHNY/2017[2014-15]Status: DisposedITAT Chennai01 Oct 2018AY 2014-15

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. Nos.2886 & 2887/Chny/2017 "नधा"रण वष" /Assessment Years : 2010-11 & 2014-15. The Deputy Commissioner Of Vs. M/S. Ramaniyam Real Estates Income Tax, P. Ltd, Corporate Circle 5(1) No.17/35, Ii Main Road, Chennai-34. Gandhi Nagar, Adyar, Chennai 600 020. [Pan Aaacr 2276A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. Sanath Kumar Raha, JCITFor Respondent: Shri. N. Arjunraj, C.A

Section 14ASection 80Section 80I

…lt with in the same previous year. Thus, by application of the matching concept, in a year where there is no exempt income there cannot be a disallowance of expenditure in relation to such assumed income. (Madras Industrial Investment Corporation Ltd vs. CIT (225 ITR 802)). The language of Sec. 14A(10 should be read in that context and such that it advances the scheme f the Act rather than distort it’’. ITA Nos.2886 & 2887/2017 :- 6 -: In the circumstances, we do not find any infirmity in the order of the ld. Commissioner of Income Tax (Appeals). In the result, both the appeals of the Revenue are 12. dismisse…

DCIT Corporate Circle 5(1), Chennai vs. Ramaniyam Real Estates P Ltd., Chennai

In the result, both the appeals of the Revenue are 12

ITA 2886/CHNY/2017[2010-11]Status: DisposedITAT Chennai01 Oct 2018AY 2010-11

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. Nos.2886 & 2887/Chny/2017 "नधा"रण वष" /Assessment Years : 2010-11 & 2014-15. The Deputy Commissioner Of Vs. M/S. Ramaniyam Real Estates Income Tax, P. Ltd, Corporate Circle 5(1) No.17/35, Ii Main Road, Chennai-34. Gandhi Nagar, Adyar, Chennai 600 020. [Pan Aaacr 2276A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. Sanath Kumar Raha, JCITFor Respondent: Shri. N. Arjunraj, C.A

Section 14ASection 80Section 80I

…lt with in the same previous year. Thus, by application of the matching concept, in a year where there is no exempt income there cannot be a disallowance of expenditure in relation to such assumed income. (Madras Industrial Investment Corporation Ltd vs. CIT (225 ITR 802)). The language of Sec. 14A(10 should be read in that context and such that it advances the scheme f the Act rather than distort it’’. ITA Nos.2886 & 2887/2017 :- 6 -: In the circumstances, we do not find any infirmity in the order of the ld. Commissioner of Income Tax (Appeals). In the result, both the appeals of the Revenue are 12. dismisse…

ACIT 3(1)(2), Mumbai vs. Edelweiss Investments Advisors Ltd, Mumbai

In the result, Revenue’s appeal in ITA No

ITA 2638/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Sept 2018AY 2012-13

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri DG Pansari, DRFor Respondent: Shri Ravikant S. Pathak, AR

Section 143(3)Section 154

…e, cover an amount which is a "loss" even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court has been approved by this Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT [1977] 225 ITR 802 . According to the Law and Practice of Income-tax by Kanga and Palkhivala, section 37(1) is a residuary section extending the allowance to items of business expenditure not covered by sections 30 to 36. This section, according to the learned Author, covers cases of business ITA Nos. 2635-2638/Mum/2017 expenditure only, and not of business losse…

Madras Industrial Investment Corporation Ltd. v. CIT

What is Madras Industrial Investment Corporation Ltd. v. CIT authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing Madras Industrial Investment Corporation Ltd. v. CIT

M/S. Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

M/S. Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

M/S Technico Agri Sciences Ltd., Chandigarh vs. ACIT, New Delhi

M/S Kanoria Chemicals & Industries Ltd., Kolkata vs. DCIT, Cir-10, Kolkata

DCIT, Circle-10, Kolkata vs. M/S. Kanoria Chemicals & Industries Ltd., Kolkata

M/S. Kanoria Chemicals & Industries Ltd., Kolkata vs. Addl. CIT, Range-10, Kolkata

DCIT, Cir-10(1), Kolkata vs. Kanoria Chemicals & Industries Ltd., Kolkata

Ecof Industries P Ltd., Chennai vs. DCIT Corporate Circle 2(1), Chennai

DCIT, Cir-11(1), Kolkata vs. M/S Haldia Petrochemicals Ltd., Kolkata

S.Arjun, Chennai vs. ACIT Non Corporate Ward 20(1), Chennai

JCIT, Rang-2, Kota vs. Chambal Fertilisers and Chemicals Limited, Kota

Chambal Fertilisers and Chemicals Limited, Kota vs. JCIT, Kota

M/S. Biotronik Medical Devices India Pvt. Ltd., New Delhi vs. ITO, New Delhi

Moserbaer India Ltd., New Delhi vs. DCIT, New Delhi

M/S. Moserbaer India Ltd., New Delhi vs. ACIT, New Delhi

ACIT, New Delhi vs. M/S. Moser Baer India Limited, New Delhi

Moserbaer India Ltd., New Delhi vs. ACIT, New Delhi

DCIT Corporate Circle 5(1), Chennai vs. Ramaniyam Real Estates P Ltd., Chennai

DCIT Corporate Circle 5(1), Chennai vs. Ramaniyam Real Estates P Ltd., Chennai

ACIT 3(1)(2), Mumbai vs. Edelweiss Investments Advisors Ltd, Mumbai