Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT

242 ITR 450Supreme Court of India2002#639 most cited

What is Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT authority for?

Expenditure incurred by an assessee operating a composite business that generates both taxable and non-taxable income is fully allowable without apportionment. This position led to the subsequent insertion of Section 14A, which disallowed expenditure related to earning exempt income.

154

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2009 to 2025.

Also referred to as

Maharashtra Sugar Mills Ltd · Rajasthan State Warehousing Corporation · Section 14A · expenditure allowance · composite business · taxable income · non-taxable income · apportionment of expenditure · exempt income · disallowance of expenditure

Sections most often in play

Section 14ASection 143(3)Section 8DSection 36(1)(vii)Section 115JBSection 1961Section 37(1)Section 4

Issues it is cited on

strategic investmentsection 144adisallowance under section 14adisallowance u/s 14asection 14asection 115jrevenue expendituresection 115jbnon-residentsection 37previous yearsection 19

Judgments citing Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/1114/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/1060/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/683/2008HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/57/2008HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/702/2008HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/112/2010HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/932/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/217/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/687/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/389/2010HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/853/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/805/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

M/S Eicher Goodearth Ltd

The appeals stand disposed of as above

ITA/77/2009HC Delhi18 Nov 2011
For Appellant: Mr Ajay Vohra with Ms Kavita Jha, Ms Akanksha Aggarwal andFor Respondent: Mr Sanjeev Sabharwal with Ms P. L. Bansal and Ms Sonia Mathur

…rior to insertion of Section 14A 12. Prior to the introduction of section 14A in the said Act, the position in law was as laid down by the Supreme Court in CIT v. Maharashtra Sugar Mills Ltd: 82 ITR 452 (SC) and Rajasthan State Warehousing Corporation v. CIT: 242 ITR 450 (SC). In Maharashtra sugar Mills Ltd (supra) the assessee’s business comprised of two parts, namely, (1) cultivation of sugar cane and (2) the manufacture of sugar. The revenue had contended that as the income from the cultivation of sugar cane, being the result of an agricultural operation, was not exigible to tax, therefore, any expenditure inc…

Commissioner of Income Tax Delhi II vs. Leo Financial Services Ltd

ITA - 79 / 2008HC Delhi03 Aug 2009
Section 37

…tions and restricted the addition to Rs.2,00,000/- on ITA No.79 of 2008 Page 1 of 9 while doing so, the CIT(A) referred to the principles laid down by the Supreme Court in the case of *Rajasthan State Warehousing*Corporation Vs. Commissioner of Income Tax, 242 ITR 450 and inter alia observed as under: "In computing 'profits and business or profession' when an assessee is carrying on business in various ventures and same among the yield taxable income and the others do not, the question of allowabilities of the expenditure under Section 37 will depend on: (a) fulfillment of requirements of that provision; (b)…