What is Munjal Sales Corporation v. CIT authority for?

The Supreme Court approves the mixed fund theory, holding that no interest disallowance is warranted under section 36(1)(iii) if investments or advances are made from the assessee's own non-interest bearing funds, even when mixed funds are available. This presumption applies when non-interest bearing funds are sufficient to meet the investments.

How many judgments cite Munjal Sales Corporation v. CIT?

191 judgments on BharatTax cite Munjal Sales Corporation v. CIT (298 ITR 298), spanning 2010 to 2026.

Which sections of the Income Tax Act does Munjal Sales Corporation v. CIT come up under?

It is most often cited in judgments turning on Section 36(1)(iii), Section 143(3), Section 14A, Section 250, Section 32(1)(ii), Section 11.

Munjal Sales Corporation v. CIT (298 ITR 298)

Shapoorji Pallanji and Company P.Ltd, Mumbai vs. Addl CIT RG 3(3), Mumbai

The appeal of the assessee is partly allowed

ITA 3053/MUM/2015[2011-12]Status: DisposedITAT Mumbai03 Mar 2017AY 2011-12

Bench: Shri Joginder Singh & Shri Manoj Kumar Aggarwalassessment Year: 2011-12 M/S Shapoorji Pallonji & Co. Dcit, Ltd. Circle-3(3), बनाम/ Shapporji Pallonji Centre, Room No.609, 6Th Floor, Vs. 41/44 Minoo Desai Marg, Aayakar Bhavan, M.K.Road, Colaba Mumbai-400020 Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aaacs6994C

Section 143(3)Section 14A

…as advanced Rs.43.50 crores to Shri Nilesh J Thakur for the purpose of aggregating land in terms of appointment letter dated 16/07/2007. In view of the same and also keeping reliance on the decision of Apex Court in the case of Munjal Sales Corporation v CIT (298 ITR 298) and the decision of the Hon'ble Bombay High Court in the case of CIT v Reliance Utilities and Power Ltd. [313 ITR 340] & also the jurisdictional ITA T, Mumbai in the case of Reliance Industries Ltd. v DCIT (ITA No. 3082/Mum/2006 dated 28/05/2012), I consider it proper and appropriate to hold that the disallowance made by the A.O. u/s 36(1)(iii)…

M/S. Chhaganlal Kishanlal & Co., Burhanpur vs. The ACIT, Khandwa

In the result, the appeal of the assessee stands allowed

ITA 646/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M. Garg & Shri O.P. Meena

…ended that the onus on the revenue to show that interest bearing fund alone were invested in investment on which no income was earned. The Ld. A.R. further relied on the decision of Hon`ble Supreme Court in the case Munjal Sales Corporation vs. CIT (2008) 298 ITR 298 (SC) wherein it was held that where assessee had sufficient profits in the current year then interest free advances can be considered flowing from such profits. 1.3.2. The Ld. A.R. also place reliance on the judgement of Hon`ble Bombay High Court in the case of CIT vs. Reliance Utilities & Power Ltd. (2009) 313 ITR 340(Bom) wherein it was held…

M/S. Rahul Developers Pvt. Ltd., Burhanpur vs. The ACIT, Khandwa

In the result, the appeal of the assessee stands allowed

ITA 645/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M.Garg & Shri O.P. Meena

…ended that the onus on the revenue to show that interest bearing fund alone were invested in investment on which no income was earned. The Ld. A.R. further relied on the decision of Hon`ble Supreme Court in the case Munjal Sales Corporation vs. CIT (2008) 298 ITR 298 (SC) wherein it was held that where assessee had sufficient profits in the current year then interest free advances can be considered flowing from such profits. 1.3.2. The Ld. A.R. also place reliance on the judgement of Hon`ble Bombay High Court in the case of CIT vs. Reliance Utilities & Power Ltd. (2009) 313 ITR 340(Bom) wherein it was held…

M/S. Narendra Industries, Burhanpur vs. The ACIT, Khandwa

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

ITA 644/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri C.M.Garg & Shri O.P. Meena

…ended that the onus on the revenue to show that interest bearing fund alone were invested in investment on which no income was earned. The Ld. A.R. further relied on the decision of Hon`ble Supreme Court in the case Munjal Sales Corporation vs. CIT (2008) 298 ITR 298 (SC) wherein it was held that where assessee had sufficient profits in the current year then interest free advances can be considered flowing from such profits. 1.3.2. The Ld. A.R. also place reliance on the judgement of Hon`ble Bombay High Court in the case of CIT vs. Reliance Utilities & Power Ltd. (2009) 313 ITR 340(Bom) wherein it was held…

M/S. C.K. Cotspin Pvt. Ltd., Burhanpur vs. The DCIT, Khandwa

In the result, the appeal of the assessee is allowed

ITA 816/IND/2014[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri C.M. Garg & Shri O.P. Meena

…M/s. C. K. Cotspin Pvt. Ltd. vs. DCIT-Khandwa/ I.T.A. No.816/Ind/2014/A.Y.:11-12 Page 1 of 23 आयकर अपील"य अ"धकरण ,इ"दौर "यायपीठ ,इ"दौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE "ी सी. एम. गग", "या"यक सद"य तथा "ी ओ.पी.मीना ,लेखा सद"य के सम" BEFORE SHRI C.M. GARG, JUDICIAL MEMBER AND SHRI O.P. MEENA, ACCOUNTANT MEMBER आ.अ.सं /.I.T.A. No.816/Ind/2014 "नधा"रण वष" / Assessment Year:2011-12 M/s. C.K. Cotspin Pvt. vs. DCIT Khandwa Ltd. Badrapur Road Chowk Bazar, Burhanpur (MP) अपीलाथ" / अपीलाथ" /Appellant अपीलाथ" / अपीलाथ" / ""यथ" / ""यथ" /Respondent ""यथ" / ""यथ" / "था.ले.सं./PAN: AAECC 2503 P अपीलाथ…

DCIT, Circle - 10, Kolkata vs. M/S. Stadmed Private Ltd., Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 200/KOL/2010[2005-06]Status: DisposedITAT Kolkata18 Jan 2017AY 2005-06

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 143(2)Section 143(3)

…Hon’ble ITAT in the case of Torrent Financers V. ACIT, 73 TTJ 624 (Ahd.), 2) Hon’ble Allahabad High Court in the case of CIT V. Prem Heavy Engineering Works P. Ltd., 285 ITR 554 (All.), 3) Hon'ble Supreme Court in the case of Munjal Sales Corporation V. CIT, 298 ITR 298 (SC). If we apply the formula laid down in the case of ACIT vs Gopikrishna Murlidhar, (Supra) we find that the assessee has submitted that it has its own funds of Rs. 5,22,90,200.00 as on 31.3.2005. Therefore it is clearly established that the assessee was having its own capital greater than the loans and advances given to the directors. We are,…

Stadmed Private Limited, Kolkata vs. DCIT, Circle - 10, Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 136/KOL/2010[2005-06]Status: DisposedITAT Kolkata18 Jan 2017AY 2005-06

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 143(2)Section 143(3)

…Hon’ble ITAT in the case of Torrent Financers V. ACIT, 73 TTJ 624 (Ahd.), 2) Hon’ble Allahabad High Court in the case of CIT V. Prem Heavy Engineering Works P. Ltd., 285 ITR 554 (All.), 3) Hon'ble Supreme Court in the case of Munjal Sales Corporation V. CIT, 298 ITR 298 (SC). If we apply the formula laid down in the case of ACIT vs Gopikrishna Murlidhar, (Supra) we find that the assessee has submitted that it has its own funds of Rs. 5,22,90,200.00 as on 31.3.2005. Therefore it is clearly established that the assessee was having its own capital greater than the loans and advances given to the directors. We are,…

M/S Fcml Projects, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2522/DEL/2013[2010-11]Status: DisposedITAT Delhi23 Dec 2016AY 2010-11

Bench: Shri S.V. Mehrotra & Shri Rajpal Yadavassessment Year : 2009-10 Fcml Projects, Acit, Circle- 28(1), A-217, Vs. New Delhi. Okhla Indl. Area, Phase-1, New Delhi. Pan : Aaaff 1343 H (Appellant) (Respondent) Assessment Year : 2010-11 Fcml Projects, Acit, Circle- 28(1), A-217, Vs. New Delhi. Okhla Indl. Area, Phase-1, New Delhi. Pan : Aaaff 1343 H (Appellant) (Respondent)

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Anil Kumar Sharma, Sr.DR

Section 143(3)Section 28Section 30Section 36(1)(iii)Section 40

…n as to how the interest of Rs.60 lakhs was allowable as per the provisions of section 36(1)(iii) r.w.s. 40(b)(iv) of the Act. The Assessing Officer, relying on the decision of the Hon’ble Supreme Court in the case of Munjal Sales Corporation vs. CIT, (2008) 298 ITR 298 (SC), observed that section 40 was a corollary to section 30 to 38 and, therefore, section 40 was not a standalone section, therefore, the limitation of deduction of interest of section 40(b)(iv) will come into play only if the expenditure of interest was allowable u/s 36(1)(iii) of the Act. Ld. CIT(A) confirmed the Assessing Officer’s action.…

M/S. Fcml Projects, New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2959/DEL/2012[2009-10]Status: DisposedITAT Delhi23 Dec 2016AY 2009-10

Bench: Shri S.V. Mehrotra & Shri Rajpal Yadavassessment Year : 2009-10 Fcml Projects, Acit, Circle- 28(1), A-217, Vs. New Delhi. Okhla Indl. Area, Phase-1, New Delhi. Pan : Aaaff 1343 H (Appellant) (Respondent) Assessment Year : 2010-11 Fcml Projects, Acit, Circle- 28(1), A-217, Vs. New Delhi. Okhla Indl. Area, Phase-1, New Delhi. Pan : Aaaff 1343 H (Appellant) (Respondent)

For Appellant: Shri Pradeep Dinodia, CA &For Respondent: Shri Anil Kumar Sharma, Sr.DR

Section 143(3)Section 28Section 30Section 36(1)(iii)Section 40

…n as to how the interest of Rs.60 lakhs was allowable as per the provisions of section 36(1)(iii) r.w.s. 40(b)(iv) of the Act. The Assessing Officer, relying on the decision of the Hon’ble Supreme Court in the case of Munjal Sales Corporation vs. CIT, (2008) 298 ITR 298 (SC), observed that section 40 was a corollary to section 30 to 38 and, therefore, section 40 was not a standalone section, therefore, the limitation of deduction of interest of section 40(b)(iv) will come into play only if the expenditure of interest was allowable u/s 36(1)(iii) of the Act. Ld. CIT(A) confirmed the Assessing Officer’s action.…

DCIT, CC-Xix, Kolkata vs. M/S International Conveyors Pvt. Ltd., Kolkata

In the result, appeals filed by the revenue in IT(SS)A No

ITA 1366/KOL/2014[2008-2009]Status: DisposedITAT Kolkata05 Dec 2016AY 2008-2009

Bench: Dr. A.L.Saini, Am & Shri K. Narasimha Chary, Jm It(Ss)A No.131/Kol/2014 ("नधा"रण वष" / Assessment Year :2008-2009) Dcit, Cc-Xix, Kolkata Vs. M/S.International Conveyors Pvt.Ltd.,10,Middletion Row, Kolkata-700071 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaci 6161 K .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Dcit, Cc-Xix, Kolkata Vs. M/S International Conveyors Pvt.Ltd.,10,Middletion Row, Kolkata-700071 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaci 6161 K .. (अपीलाथ" /Appellant) (""यथ" / Respondent) It(Ss)A No.90/Kol/2014 ("नधा"रण वष" / Assessment Year :2009-2010) Dcit, Cc-Xix, Kolkata Vs. M/S International Conveyors Pvt.Ltd.,10,Middletion Row, Kolkata-700071 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaci 6161 K (अपीलाथ" /Appellant) .. (""यथ" / Respondent) It(Ss)A No.91/Kol/2014 ("नधा"रण वष" / Assessment Year :2010-2011) Dcit, Cc-Xix, Kolkata Vs. M/S International Conveyors Pvt.Ltd.,10,Middletion Row, Kolkata-700071 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaci 6161 K .. (अपीलाथ" /Appellant) (""यथ" / Respondent) It(Ss)A No.92/Kol/2014 ("नधा"रण वष" / Assessment Year :2011-2012) Dcit, Cc-Xix, Kolkata Vs. M/S International Conveyors Pvt.Ltd.,10,Middletion Row, Kolkata-700071 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaci 6161 K .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

For Appellant: Shri A.K.Tibrewal, FCAFor Respondent: Shri Niraj Kumar, CIT DR

Section 14ASection 153Section 153ASection 43BSection 80

…th regard to its claim that where the amount of capital and free reserves were more than the amount of investment in shares then it could be presumed that the investments were made from own funds and not from borrowed funds: Munjal Sales Corpn. v. CIT [2008] 298 ITR 298 (SC). CIT v. Reliance Utilities & Power Ltd. (2009) 178 Taxman 135 (Bom) CIT v. Britannia Industries Ltd. (2006) 280 ITR 525 (Cal) CIT v. Gujrat Narmada Valley Fertilizers Co. Ltd. [2014] 42 taxmann.com 270 (Gujrat) Even otherwise the issue is well covered by the decision of Hon'ble Supreme Court in the case of S.A. Builders Ltd. v. CIT [2007] 2…

Sri Girish Ghelani, Kolkata vs. ITO, WD-34(4), Kolkata

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

ITA 519/KOL/2015[2009-2010]Status: DisposedITAT Kolkata18 Nov 2016AY 2009-2010

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

For Appellant: Shri Miraj D. Shah, AdvocateFor Respondent: Sallong Yaden, Addl. CIT

Section 143(3)

…0/-. He placed reliance on the decision of Hon’ble Calcutta High Court in the case of CIT Vs. Britannia Industries Ltd. reported in 280 ITR 525 (Cal) and also on the decision of Hon’ble Supreme Court in the case of Munjal Sales Corporation Vs. CIT reported in 298 ITR 298 wherein it was held that in the event of own funds and borrowed funds being mixed up the presumption has to be in favour of the assessee that the interest free funds were given out of own funds of the assessee provided the own funds are much more than the interest free funds. He pleaded for disallowance of interest on proportionate basis only to…

The Commissioner of Income Tax vs. M/S Brindavan Beverages Pvt Ltd

In the result ground 4 of the revenue is dismissed

ITA/67/2015HC Karnataka26 Oct 2016

Bench: ARAVIND KUMAR,JAYANT PATEL

Section 14ASection 14aSection 260

…& H High Court in Abhishek Industries Ltd., (supra) is concerned, this was followed by the very same High Court, while confirming a similar disallowance in the case of Munilal Sales Corpn. Vs CIT 298 ITP 288. Hon’ble Apex court reversed the latter in 298 ITR 298 and hence judgment in Abhishek Industries Ltd., will not further revenue’s case any way. On the other hand, assessee is well supported by the decision of Hon’ble Mumbai High Court in the case of Reliance Utilities & Power Ltd., (supra) as well as Hon’ble Gujarat High Court in the case of Raghuvir Synthetics Ltd.,(supra). We thus, do no…

D.C.I.T Cir - 12, Kolkata vs. M/S Jct Limited., Kolkata

In the result the appeal by the revenue is dismissed

ITA 1106/KOL/2013[2004-05]Status: DisposedITAT Kolkata19 Oct 2016AY 2004-05

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am] I.T.A Nos. 1106 To 1109/Kol/2013 Assessment Years : 2004-05, 2006-07,2007-08 & 2008-09 D.C.I.T., Circle-12, -Vs.- M/S. J.C.T. Ltd. Kolkata Kolkata [Pan : Aaacj 6733 E] (Appellant) (Respondent) For The Appellant : Shri Angam Shaiza, Cit For The Respondent : Shri A.K.Gupta, Fca

For Appellant: Shri Angam Shaiza, CITFor Respondent: Shri A.K.Gupta, FCA

Section 145Section 145ASection 43B

…urpose of business consideration , interest on such loans & advances will not be disallowed. Reliance was placed on the decision of the Hon’ble Supreme Court in the case of S.A. Builders Ltd. Vs. CIT (Appeals) (2007) 288 ITR 1, Munjal Sales Corporation (2008) 298 ITR 298. The above decision has been followed in the case of CIT vs Rockman Cycle Industries Ltd (2009) 176 Taxman 21 (Punj. & Har). In view of the facts stated above, evidences and the aforementioned decisions, the Assessee pleaded that no interest ought to have been disallowed. 22. The CIT(A) deleted the addition made by AO for the following reason :-…

Shri Gulshan Bathla, Sonepat vs. JCIT, Sonepat

In the result, the appeal of the assessee stands partly

ITA 4100/DEL/2013[2009-10]Status: DisposedITAT Delhi19 Aug 2016AY 2009-10

Bench: Shri S.V. Mehrotra & Shri Chandra Mohan Garg

For Appellant: Shri K. Sampath & Rajkumar, AdvsFor Respondent: Shri Amrit Lal, Sr. DR

Section 36(1)(iii)

…ied on the decision of the CIT(A) Vs. Abhishek Industries Ltd [2006\ 156 Taxman 257 [P & H] which is not a good law. To this proposition, the ld. AR has placed reliance on the decision of Hon'ble Supreme Court in the case of Munjal Sales Corporation Vs. CIT 298 ITR 298 [SC] and decision of the Hon'ble Punjab High Court in the case of Gurdas Garg Vs. CIT [2015] 63 Taxman.com 289 [P&H]. The ld. AR also submitted that the CIT(A) for A.Y 2011-12 has allowed similar claim of the assessee having similar set of facts and circumstances. 4. Per contra, the ld. DR of the Revenue supported the action of the AO and cont…

M/S Paliwal Overseas Ltd., Panipat vs. ACIT, Panipat

In the result, the appeal of the assessee is partly

ITA 3491/DEL/2011[2001-02]Status: DisposedITAT Delhi30 Jun 2016AY 2001-02

Bench: Shri Sudhanshu Srivastava & Shri L.P. Sahu

Section 80H

…ITA Nos. 3490 TO 3495/Del/2011 Paliwal Overseas Ltd. Page 13 of 47 regard to the circumstances of the case. No businessman can be compelled to maximize his profits.” 5.06 Subsequently, the Hon’ble Apex Court in the case of Munjal Sales Corporation vs. CIT 298 ITR 298 held that no disallowance of interest on borrowed funds could be made when the interest free advances are established to be out of capital or profits of the assessee during the year. Hence, establishment of nexus of borrowed funds with the funds advanced interest free was and still remains a critical condition for making any disallowance of int…

M/S Paliwal Overseas Ltd., Panipat vs. ACIT, Panipat

In the result, the appeal of the assessee is partly

ITA 3490/DEL/2011[2000-01]Status: DisposedITAT Delhi30 Jun 2016AY 2000-01

Bench: Shri Sudhanshu Srivastava & Shri L.P. Sahu

Section 80H

…ITA Nos. 3490 TO 3495/Del/2011 Paliwal Overseas Ltd. Page 13 of 47 regard to the circumstances of the case. No businessman can be compelled to maximize his profits.” 5.06 Subsequently, the Hon’ble Apex Court in the case of Munjal Sales Corporation vs. CIT 298 ITR 298 held that no disallowance of interest on borrowed funds could be made when the interest free advances are established to be out of capital or profits of the assessee during the year. Hence, establishment of nexus of borrowed funds with the funds advanced interest free was and still remains a critical condition for making any disallowance of int…

Adman Advertising, Delhi vs. ACIT, New Delhi

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

ITA 796/DEL/2016[2008-09]Status: DisposedITAT Delhi27 Jun 2016AY 2008-09

Bench: Sh. N. K. Saini

For Appellant: Sanjay Jain, CAFor Respondent: Sh. V. R. Sonbhadra, Sr. DR

Section 143(1)Section 30Section 36Section 40

…t amounts withdrawn are against current year's income is also not correct as no profit or loss accrues from day to day nor there is any such stipulation in the partnership deed. 8.4 Hon'ble Supreme Court in the case of Munjal Sales Corporation vs. CIT & Anr., 298 ITR 298 have held that Section 40(b)(iv) places a limitation of the deduction u/s 30 to 38 and, therefore, Section 40(b)(iv) is not a stand alone section and every Assessee in the first instance has to establish its right to claim deduction u/s 30 to 38 and then it is to be proved that he is not disentitled to claim deduction by reasons of applicability…

DCIT, Circle - 8, Kolkata vs. M/S. Eih Limited, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 348/KOL/2011[2006-07]Status: DisposedITAT Kolkata01 Jun 2016AY 2006-07

Bench: Shri Mahavir Singh, Jm & Shri M. Balaganesh, Am]

For Respondent: Shri Vijay Shankar, CIT, DR

Section 143(3)Section 195Section 40Section 9(1)(vii)

…288 ITR 1 (SC) is very much applicable as on date until the judgement in Tulip Star Hotels Ltd is pronounced by the Supreme Court. 25 ITA Nos.348-314/K/2011 & CO No.23/K/2011 EIH Limited AY 2006-07 g) Munjal Sales Corporation vs CIT and Another reported in 298 ITR 298 (SC) h) CIT vs Reliance Utilities and Power Ltd reported in 313 ITR 340 (BOM) i) Recent decision of the Hon’ble Apex Court in the case of Hero Cycles (P) Ltd vs CIT reported in (2015) 63 taxmann.com 308 (SC) dated 5.11.2015. The operative portion of the aforesaid judgements are not reproduced herein for the sake of brevity. However the principles…

Eih Limited, Kolkata vs. DCIT, Circle - 8, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 314/KOL/2011[2006-07]Status: DisposedITAT Kolkata01 Jun 2016AY 2006-07

Bench: Shri Mahavir Singh, Jm & Shri M. Balaganesh, Am]

For Respondent: Shri Vijay Shankar, CIT, DR

Section 143(3)Section 195Section 40Section 9(1)(vii)

…288 ITR 1 (SC) is very much applicable as on date until the judgement in Tulip Star Hotels Ltd is pronounced by the Supreme Court. 25 ITA Nos.348-314/K/2011 & CO No.23/K/2011 EIH Limited AY 2006-07 g) Munjal Sales Corporation vs CIT and Another reported in 298 ITR 298 (SC) h) CIT vs Reliance Utilities and Power Ltd reported in 313 ITR 340 (BOM) i) Recent decision of the Hon’ble Apex Court in the case of Hero Cycles (P) Ltd vs CIT reported in (2015) 63 taxmann.com 308 (SC) dated 5.11.2015. The operative portion of the aforesaid judgements are not reproduced herein for the sake of brevity. However the principles…

Vayuputra Realty P.Ltd, Mumbai vs. DCIT 8(3), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 5330/MUM/2014[2011-12]Status: DisposedITAT Mumbai04 May 2016AY 2011-12

Bench: Shri Jason P. Boaz, Am & Shri Sandeep Gosain, Jm Vayuputra Realty Pvt. Ltd., Vs. The Dy. Commissioner Of Knowledge House, Shyam Nagar, Income Tax, Ward -8(3), Off. J. V. Link Road, Jogeshwari Aayakar Bhavan, (E), Mumbai 400 060 M. K. Road, Mumbai Pan: Aaccv 5323 Q Appellant .. Respondent

Section 143Section 143(3)Section 14A

…ing of the CIT (appeals) that the total investment made by the assessee in earlier yeas and the sum of Rs.5 lacs invested during the year were out of its own funds and not out of borrowed funds. 11. The Hon’ble Apex Court in Munjal Sales Corporation Vs. CIT [298 ITR 298 (SC)] has reversed the findings of the Hon’ble Punjab & Haryana High Court in that assessee’s case and appeal filed by the Revenue against the assessee reported in 298 ITR 288 & 294 respectively. The Hon’ble Supreme Court have allowed the appeal of the assessee against the disallowance of interest under section 36 (1) (iii) of the Act in view of…

Munjal Sales Corporation v. CIT

What is Munjal Sales Corporation v. CIT authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing Munjal Sales Corporation v. CIT

Shapoorji Pallanji and Company P.Ltd, Mumbai vs. Addl CIT RG 3(3), Mumbai

M/S. Chhaganlal Kishanlal & Co., Burhanpur vs. The ACIT, Khandwa

M/S. Rahul Developers Pvt. Ltd., Burhanpur vs. The ACIT, Khandwa

M/S. Narendra Industries, Burhanpur vs. The ACIT, Khandwa

M/S. C.K. Cotspin Pvt. Ltd., Burhanpur vs. The DCIT, Khandwa

DCIT, Circle - 10, Kolkata vs. M/S. Stadmed Private Ltd., Kolkata

Stadmed Private Limited, Kolkata vs. DCIT, Circle - 10, Kolkata

M/S Fcml Projects, New Delhi vs. ACIT, New Delhi

M/S. Fcml Projects, New Delhi vs. ACIT, New Delhi

DCIT, CC-Xix, Kolkata vs. M/S International Conveyors Pvt. Ltd., Kolkata

Sri Girish Ghelani, Kolkata vs. ITO, WD-34(4), Kolkata

The Commissioner of Income Tax vs. M/S Brindavan Beverages Pvt Ltd

D.C.I.T Cir - 12, Kolkata vs. M/S Jct Limited., Kolkata

Shri Gulshan Bathla, Sonepat vs. JCIT, Sonepat

M/S Paliwal Overseas Ltd., Panipat vs. ACIT, Panipat

M/S Paliwal Overseas Ltd., Panipat vs. ACIT, Panipat

Adman Advertising, Delhi vs. ACIT, New Delhi

DCIT, Circle - 8, Kolkata vs. M/S. Eih Limited, Kolkata

Eih Limited, Kolkata vs. DCIT, Circle - 8, Kolkata

Vayuputra Realty P.Ltd, Mumbai vs. DCIT 8(3), Mumbai