What is Pandian Chemicals Ltd. v. CIT authority for?

Income eligible for deduction under Section 80IA or 80IC must have a direct nexus with the eligible business activity of the industrial undertaking. Income merely incidental to the business, even if part of the assessee's overall business, is not considered "derived from" the eligible undertaking.

How many judgments cite Pandian Chemicals Ltd. v. CIT?

346 judgments on BharatTax cite Pandian Chemicals Ltd. v. CIT (262 ITR 278), spanning 2007 to 2026.

Which sections of the Income Tax Act does Pandian Chemicals Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 1961, Section 143(3), Section 250, Section 148, Section 115JB, Section 147.

Pandian Chemicals Ltd. v. CIT (262 ITR 278)

ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI vs. K C INDIA LIMITED, NEW DELHI

The appeal of the department is dismissed

ITA 2889/DEL/2025[2018-19]Status: DisposedITAT Delhi08 Apr 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Vs. Kc India Ltd. Room No. 316A, Cr A-6, Nimiri Commercial Building, I.P. Estate, Complex Ashok Vihar, New Delhi – 110002 Phase-Ii, Delhi – 110052 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaack4893N Appellant .. Respondent

For Appellant: Sh. SatyajeetGoel, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr

Section 143(1)Section 143(3)Section 80ISection 8O

…ct. ii. Whether on the facts and circumstances of the case, the Ld. CIT(A) erred in deleting the disallowance of deduction of Rs. 5,64,43,387/- u/s 8OIA of the Act ignoring the decision of the Hon'ble Supreme Court in the case of Pandian Chemicals Ltd. Vs CIT 262 ITR 278 and in the case of Camby Electric Supply Industrial Company Ltd. Vs CIT 113 ITR 84 explicitly held that once expression "derived from" is used by the legislature then only profit from a particular business undertaking are eligible for the deduction and not all kinds of profits are eligible profits. iii. Whether on the facts and circumstances of t…

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 31/DDN/2022[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

Section 143(3)Section 263Section 80Section 80I

…to charge tariff under two components, one of them being capacity charges 7. That the Hon'ble PCIT has erred in holding that capacity charges are not directly linked with sale of energy by placing reliance on the judgement in the case of Pandian Chemicals Ltd 262 ITR 278. That the Appellant craves leave to add, amend, modify or withdraw the above grounds of appeal.” Ground of appeal No.1 is general in nature hence, dismissed. 7. 8. Regarding Grounds of appeal No. 2 to 3.3, before us, Ld.AR for the assessee submits that AO has made due enquiries with respect to the late payment surcharge and has made the addition…

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision of Supreme Court in the case of National Organic Industries Limited (106 STC 467)(1997), Pandian Chemicals (129 Taxmann 539)(2003) and other related decisions on the issue of income derived from the business. Further it was submitted that the deduction u/s 36(1)(viii) should be determined and allowed before the computation of deduction u/s 36(1)(via)( c) of the Act. The assessee relied on the decision in the case of Infrastructure Development Finance Co. Ltd (2016…

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision of Supreme Court in the case of National Organic Industries Limited (106 STC 467)(1997), Pandian Chemicals (129 Taxmann 539)(2003) and other 9 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 related decisions on the issue of income derived from the business. Further it was submitted that the deduction u/s 36(1)(viii) should be determined and allowed before the computation of deduction u/s 36(1)(via)( c) of the Act. The assessee relie…

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision of Supreme Court in the case of National Organic Industries Limited (106 STC 467)(1997), Pandian Chemicals (129 Taxmann 539)(2003) and other related decisions on the issue of income derived from the business. Further it was submitted that the deduction u/s 36(1)(viii) should be determined and allowed before the computation of deduction u/s 36(1)(via)( c) of the Act. The assessee relied on the decision in the case of Infrastructure Development Finance Co. Ltd (2016…

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision of Supreme Court in the case of National Organic Industries Limited (106 STC 467)(1997), Pandian Chemicals (129 Taxmann 539)(2003) and other 9 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 related decisions on the issue of income derived from the business. Further it was submitted that the deduction u/s 36(1)(viii) should be determined and allowed before the computation of deduction u/s 36(1)(via)( c) of the Act. The assessee relie…

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision of Supreme Court in the case of National Organic Industries Limited (106 STC 467)(1997), Pandian Chemicals (129 Taxmann 539)(2003) and other 9 related decisions on the issue of income derived from the business. Further it was submitted that the deduction u/s 36(1)(viii) should be determined and allowed before the computation of deduction u/s 36(1)(via)( c) of the Act. The assessee relied on the decision in the case of Infrastructure Development Finance Co. Ltd (20…

ITO-27(3)(1), MUMBAI, VASHI vs. VIRAL INDUSTRIES, MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 6718/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 143(3)Section 250Section 801BSection 80I

….08.2012 ITAT BANGALORE Dt. We are of the view that the learned CIT(A) has rightly placed reliance on the decisions of the Hon'ble Apex Court in the cases of Petron Engineering Construction (P) Ltd. reported in 175 ITR 523, Pandian Chemicals Ltd. reported in 262 ITR 278, N.C. Budharaja & Co. reported in 204 ITR 412, IPCA Laboratories Ltd. reported in 266 ITR 521 to arrive at the view that the tax incentive by way of deduction. 80 IB of the Act is predominantly for the purpose of augmenting affordable dwelling and ought to be interpreted in that light. In this view 5 Viral Industries, Mumbai. of the matter, the…