Page 32 of 66 CIT, (1954) 26 ITR 27 (SC), CIT v. Ashokbhai Chaamanbhai

56 ITR 42Supreme Court of India1965#1639 most cited

What is Page 32 of 66 CIT, (1954) 26 ITR 27 (SC), CIT v. Ashokbhai Chaamanbhai authority for?

Income accrues or arises to an assessee when the right to receive it vests with the assessee, not necessarily upon actual receipt.

69

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Ashokbhai Chimanbhai · 56 ITR 42 · SC · income accrues or arises · right to receive · vesting of income

Sections most often in play

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 5(1)Section 143(3)Section 2(47)

Issues it is cited on

right to receivejdaprincipal officermercantile system of accountingsection 254(1)section 5(1)liable to taxsection 254income from other sourcessection 43section 37(1)levy of penalty

Judgments citing Page 32 of 66 CIT, (1954) 26 ITR 27 (SC), CIT v. Ashokbhai Chaamanbhai

M/S. Nokia Corporation (Formerly Nokia Networks Oy), New Delhi vs. ACIT, New Delhi

In the result, appeals of the assessee on the grounds- a

ITA 1006/DEL/2010[2004-05]Status: DisposedITAT Delhi02 Sept 2019AY 2004-05

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 1006/Del/2010 : Asstt. Year : 2004-05 Ita No. 1007/Del/2010 : Asstt. Year : 2005-06 Ita No. 1008/Del/2010 : Asstt. Year : 2006-07 Ita No. 5819/Del/2010 : Asstt. Year : 2007-08 Nokia Corporation Vs Asstt. Director Of Income Tax, Circle-2(1), International Taxation, (Formerly Nokia Networks Oy) New Delhi C/O Tarandeep Singh, F-99, Lajpat Nagar-Ii, New Delhi-110024 (Appellant) (Respondent) Pan No. Aabcn3748E Ita No. 1236/Del/2010 : Asstt. Year : 2004-05 Ita No. 1237/Del/2010 : Asstt. Year : 2005-06 Ita No. 1238/Del/2010 : Asstt. Year : 2006-07

For Appellant: Ms. Rashmi Chopra, AdvFor Respondent: Sh. G. K. Dhall, CIT DR

…somebody it cannot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by Hon'ble Supreme Court in the case of E.D. Sassoon Co. Ltd. v. CIT [1954] 26 ITR 27, CIT v. Ashokbhai Chaamanbhai [1965] 56 ITR 42, CIT v. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 and Godhara Electricity Co. Ltd. v. CIT, [1997] 225 ITR 746/91 Taxman 351. Further, the judgment of Hon'ble Supreme Court in the case of ITA Nos. 1006 to 1008, 1236 42 to 1238 & 5819/Del/2010 Nokia Corporation State Bank of Travancore, (supra) which has been relied upon by the ld. CIT (A), has…

M/S Volvo India Pvt. Ltd vs. ACIT, Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 1537/BANG/2012[2008-09]Status: DisposedITAT Bangalore08 May 2019AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 139Section 143Section 143(3)Section 144Section 153(1)Section 18

…relevant orders are at pages 603-604 of the PB – Vol 1 / pages 2817- 2818 of the PB – Vol 4), and therefore as per the law laid down by the Supreme court in the case of E.D. Sasoon :26 ITR 27, Shoorji Vallabhdas and Co. : 46 ITR 144 and Ashokbhai Chimanbhai : 56 ITR 42 , in absence of right to receive such income on account of SAD does not accrue in the relevant previous year. 24. The assessing officer, however, rejected the plea of the Assessee and held that (i) the assessee had right to receive the said income and had accounted the SAD refund as income in the books of accounts, and has not treated this as inco…

ADIT, New Delhi vs. Nokia Corportion, Gurgaon

ITA 1235/DEL/2010[2003-04]Status: DisposedITAT Delhi29 Mar 2019AY 2003-04

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

ADIT, New Delhi vs. Nokia Corportion, Gurgaon

ITA 1234/DEL/2010[2002-03]Status: DisposedITAT Delhi29 Mar 2019AY 2002-03

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

M/S. Nokia Corporation (Formerly Nokia Networks Oy), New Delhi vs. ACIT, New Delhi

ITA 1005/DEL/2010[2003-04]Status: DisposedITAT Delhi29 Mar 2019AY 2003-04

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

M/S. Nokia Corporation (Formerly Nokia Networks Oy), New Delhi vs. ACIT, New Delhi

ITA 1004/DEL/2010[2002-03]Status: DisposedITAT Delhi29 Mar 2019AY 2002-03

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Asstt. Director of I. Tax vs. Nokia Corporation

ITA 2288/DEL/2005[2001-2002]Status: DisposedITAT Delhi29 Mar 2019AY 2001-2002

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Asstt. Director of I. Tax vs. Nokia Corporation

ITA 2287/DEL/2005[2000-2001]Status: DisposedITAT Delhi29 Mar 2019AY 2000-2001

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Asstt. Director of I. Tax vs. Nokia Corporation

ITA 2286/DEL/2005[1999-2000]Status: DisposedITAT Delhi29 Mar 2019AY 1999-2000

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Nokia Corporation vs. ACIT, Circle-2(1)

ITA 2137/DEL/2005[2001-2002]Status: DisposedITAT Delhi29 Mar 2019AY 2001-2002

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Nokia Corporation vs. ACIT, Circle-2(1)

ITA 2136/DEL/2005[2000-2001]Status: DisposedITAT Delhi29 Mar 2019AY 2000-2001

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

Nokia Corporation vs. ACIT, Circle-2(1)

ITA 2135/DEL/2005[1999-2000]Status: DisposedITAT Delhi29 Mar 2019AY 1999-2000

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. G.K.Dhatt, CIT(DR)
Section 44D

…annot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by the hon'ble Supreme Court in the case of E. D. Sassoon and Co. Ltd. v. CIT [1954] 26 ITR 27 (SC), CIT v. Ashokbhai Chimanbhai [1965] 56 ITR 42 (SC), CIT v. Messrs. Shoorji Vallabhdas and Co. [1962] 46 ITR 144 (SC) and Godhra Electricity Co. Ltd. v. CIT [1997] 225 ITR 746 (SC). Further, the judgment of the hon'ble Supreme Court in the case of State Bank of Travancore v. CIT reported in [1986] 158 ITR 102 (SC) which has been relied upon by the learned Commissioner of Income-tax (Appeals), h…

ACIT Cir, 31 (1) Room No. 217, New Delhi vs. Rngs Consortium, New Delhi

In the result ITA No. 153/Del/2009 is dismissed

ITA 2238/DEL/2008[2004-2005]Status: DisposedITAT Delhi20 Dec 2018AY 2004-2005

Bench: Shri Amit Shukla & Shri Prashant Maharishiasst Commissioner Of Income Vs. M/S. Rngs Consortium, Tax, 8, Aradhana Colony, Circle-31(1), Cr Building, Ip Sector-13, Rk Puram, New Estate, New Delhi Delhi (Appellant) (Respondent) Dcit, Vs. M/S. Expotec International Circle-11(1), Ltd, 8, Aradhana Colony, Rk New Delhi Puram, Sector-13, New Delhi (Appellant) (Respondent)

For Appellant: Shri Ajay vohra, Sr. AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 144Section 145(3)Section 44A

…nd CIT vs. Bavla Gopalak Vividh Karyakari Sahakari Mandli Limited: 253 ITR 97 (Guj ) 35.. It was further pointed out by the appellant that in the assessment order at page-6 the assessing officer has placed reliance on the case of CIT vs. Ashokbhai Chimanbhai: 56 ITR 42 (SC)5 that the Apex Court has held that income is said to accrue or arise to an assessee, when the right to receive the same vests with the assessee. The appellant has explained that the assessee in that case was a Hindu undivided family (HUF) consisting of Ashokbhai, the manager, his.wife, and his minor son. Ashokbhai was a partner in a firm namel…

ACIT, New Delhi vs. Sh. Sanjay Passi, New Delhi

In the result, the Revenue’s appeal as well as Assessee’s Cross

ITA 1450/DEL/2015[2012-13]Status: DisposedITAT Delhi11 Jul 2018AY 2012-13

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. V.K. Agarwal, A.RFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 127Section 132Section 142(1)Section 143(1)Section 143(2)Section 153ASection 2(22)(e)

…ally held that the accumulated profits do not include the current year's business profit as it accrues at the end of the year. Profit does not accrue on day to day basis. Reliance is placed on the following case laws: - CIT vs. ASHOKBHAI CHIMANBHAI, (1965) 56 ITR 42 (SC) "6. In the gross receipts of a business day after day or from transaction to transaction lies embedded or dormant profit or loss; on such dormant profit or loss undoubtedly taxable profits, if any, of the business will be computed. But dormant profits cannot be equated with profits charged to tax under ss. 3 and 4 of the IT Act. The conc…

Nokia Net Works Nokia Group Finland vs. JCIT, New Delhi

In the result, all the issues which have been remanded back by the Hon'ble High Court to this Tribunal stands decided in favour of the assessee and against the Revenue

ITA 1964/DEL/2001[1998-1999]Status: DisposedITAT Delhi05 Jun 2018AY 1998-1999

Bench: Shri N.K. Saini, Shri Pramod Kumar & Shri Amit Shukla

For Appellant: Shri Deepak Chopra, Amit SrivastavaFor Respondent: Shri T.M. Shiv Kumar, CIT-DR
Section 142(1)Section 3

…t cannot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by Hon'ble Supreme Court in the case of E. D. Sassoon Co. Ltd. Vs. CIT, (1954) 26 ITR 27 (SC), CIT vs. Ashokbhai Chaamanbhai, (1965) 56 ITR 42, CIT vs. Shoorji Vallabhdas and Co, (1962) 46 ITR 144 (SC) and Godhara Electricity Company Ltd. Vs. CIT, 225 ITR 746. Further, the judgment of Hon'ble Supreme Court in the case of State Bank of Travancore, reported in (1986) 158 ITR 102 (SC) which has been relied upon by the ld. CIT (A), has not been treated to be correct enunciation of law by the…

Nokia Net Works Nokia Gruop Finland vs. DCIT, New Delhi

In the result, all the issues which have been remanded back by the Hon'ble High Court to this Tribunal stands decided in favour of the assessee and against the Revenue

ITA 1963/DEL/2001[1997-1998]Status: DisposedITAT Delhi05 Jun 2018AY 1997-1998

Bench: Shri N.K. Saini, Shri Pramod Kumar & Shri Amit Shukla

For Appellant: Shri Deepak Chopra, Amit SrivastavaFor Respondent: Shri T.M. Shiv Kumar, CIT-DR
Section 142(1)Section 3

…t cannot be said that income has accrued to it or it has a right to receive the income. This proposition has been well settled by Hon'ble Supreme Court in the case of E. D. Sassoon Co. Ltd. Vs. CIT, (1954) 26 ITR 27 (SC), CIT vs. Ashokbhai Chaamanbhai, (1965) 56 ITR 42, CIT vs. Shoorji Vallabhdas and Co, (1962) 46 ITR 144 (SC) and Godhara Electricity Company Ltd. Vs. CIT, 225 ITR 746. Further, the judgment of Hon'ble Supreme Court in the case of State Bank of Travancore, reported in (1986) 158 ITR 102 (SC) which has been relied upon by the ld. CIT (A), has not been treated to be correct enunciation of law by the…

M.S. Lakshmi Bai, Hyderabad vs. CIT (Exemptions), Hyderabad

In the result, this appeal is allowed for statistical purposes

ITA 1679/HYD/2016[2007-08]Status: DisposedITAT Hyderabad23 May 2018AY 2007-08

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri D. Prasad Rao, DR
Section 143(3)Section 148

…ised is at best a hypothetical income which cannot be brought to tax. He also relied on the following judgments: i. Amiantit International Holding Ltd., AAR [322 ITR 678]; ii. State Bank of Travancore Vs. CIT [158 ITR 102]; iii. CIT Vs. Ashokbhai Chimanbhai [56 ITR 42]; iv. Assam Roller Flour Mills Vs. CIT [227 ITR 43]; for various concepts. Lastly, Ld. Counsel relied on the recent amendment to the Finance Act, 2017 by which new provision of Sub-Section 5A u/s. 45 has been introduced to support the concept of real income. 5.2. With reference to cost of purchase which is also added as ‘unexplained investment’,…

R. Subba Laxmi, Hyderabad vs. ITO, Ward-11(5), Hyderabad

In the result, this appeal is allowed for statistical purposes

ITA 1600/HYD/2016[2007-08]Status: DisposedITAT Hyderabad23 May 2018AY 2007-08

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri D. Prasad Rao, DR
Section 143(3)Section 148

…ised is at best a hypothetical income which cannot be brought to tax. He also relied on the following judgments: i. Amiantit International Holding Ltd., AAR [322 ITR 678]; ii. State Bank of Travancore Vs. CIT [158 ITR 102]; iii. CIT Vs. Ashokbhai Chimanbhai [56 ITR 42]; iv. Assam Roller Flour Mills Vs. CIT [227 ITR 43]; for various concepts. Lastly, Ld. Counsel relied on the recent amendment to the Finance Act, 2017 by which new provision of Sub-Section 5A u/s. 45 has been introduced to support the concept of real income. 5.2. With reference to cost of purchase which is also added as ‘unexplained investment’,…

Viswanatha Reddy Potham, Hyderabad vs. ITO, Ward-11(5), Hyderabad

In the result, this appeal is allowed for statistical purposes

ITA 1599/HYD/2016[2007-08]Status: DisposedITAT Hyderabad23 May 2018AY 2007-08

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri D. Prasad Rao, DR
Section 143(3)Section 148

…ised is at best a hypothetical income which cannot be brought to tax. He also relied on the following judgments: i. Amiantit International Holding Ltd., AAR [322 ITR 678]; ii. State Bank of Travancore Vs. CIT [158 ITR 102]; iii. CIT Vs. Ashokbhai Chimanbhai [56 ITR 42]; iv. Assam Roller Flour Mills Vs. CIT [227 ITR 43]; for various concepts. Lastly, Ld. Counsel relied on the recent amendment to the Finance Act, 2017 by which new provision of Sub-Section 5A u/s. 45 has been introduced to support the concept of real income. 5.2. With reference to cost of purchase which is also added as ‘unexplained investment’,…

Jillela Dasaratha Reddy, Rep by Gpa Holder, J Pedda Venkata Reddy, Hyderabad vs. ITO, Ward-11(5), Hyderabad

In the result, this appeal is allowed for statistical purposes

ITA 1598/HYD/2016[2007-08]Status: DisposedITAT Hyderabad23 May 2018AY 2007-08

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri D. Prasad Rao, DR
Section 143(3)Section 148

…ised is at best a hypothetical income which cannot be brought to tax. He also relied on the following judgments: i. Amiantit International Holding Ltd., AAR [322 ITR 678]; ii. State Bank of Travancore Vs. CIT [158 ITR 102]; iii. CIT Vs. Ashokbhai Chimanbhai [56 ITR 42]; iv. Assam Roller Flour Mills Vs. CIT [227 ITR 43]; for various concepts. Lastly, Ld. Counsel relied on the recent amendment to the Finance Act, 2017 by which new provision of Sub-Section 5A u/s. 45 has been introduced to support the concept of real income. 5.2. With reference to cost of purchase which is also added as ‘unexplained investment’,…