Pandian Chemicals Ltd. v. Commissioner of Income Tax, Madurai

5 SCC 590Reported decision1999#3391 most cited
35

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2011 to 2025.

Sections most often in play

Section 10(34)Section 139(5)Section 143(2)Section 143(3)Section 148Section 14ASection 194QSection 69C

Issues it is cited on

section 80abretention moneysection 10(33)section 253(3)section 80ia(4)initial assessment yearsection 80cextension of limitationdeduction u/s 80iasection 80aeligible businesssection 80ia

Judgments citing Pandian Chemicals Ltd. v. Commissioner of Income Tax, Madurai

National Cooperative Development Corporation vs. Assistant Commissioner of Income Tax

C.A. No.-004612-004612 - 2014Supreme Court10 Dec 2025

Bench: HON'BLE MR. JUSTICE PAMIDIGHANTAM SRI NARASIMHA

Section 36(1)(viii)

…ncome and the specified business activity. It is judicially settled that "derived from" is narrower than "attributable to", this distinction was lucidly clarified by this Court in Cambay Electric Supply 1 (2016) 6 SCC 747. 2 (1999) 4 SCC 98. 3 (2003) 5 SCC 590. 4 (2009) 9 SCC 328. 11 Industrial Co. Ltd. v. CIT5, where it was held that the legislature uses "derived from" when it intends to give a restricted meaning. The relevant part of the judgment is extracted hereunder: "8. As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attrib…

Asstt. Commissioner of Income Tax, CC-1, Lucknow, Aayakar Bhawan, Ashok Marg vs. Apco Infratech Pvt. Ltd., Vibhuti Khand Gomti Nagar Lko

In the result, appeals vide

ITA 623/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restriction on taking into account income fro…

M/S Apco Infratech Pvt. Ltd., Lucknow vs. D/ACIT-1, Central-1, Lucknow

In the result, appeals vide

ITA 17/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restriction on taking into account income fro…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 454/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restriction on taking into account income fro…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-I, Lucknow

In the result, appeals vide I

ITA 357/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restriction on taking into account income fro…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-1, Lucknow

In the result, appeals vide

ITA 356/LKW/2020[2016-17]Status: DisposedITAT Lucknow02 Apr 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restriction on taking into account income fro…

The Commissioner of Income Tax - International Taxation -3 vs. Umw Sher (L) Ltd

ITA/57/2025HC Delhi07 Mar 2025

Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE CHIEF JUSTICE DEVENDRA KUMAR UPADHYAYA

Section 138Section 142Section 311

…12. Undisputedly, even the evidence of accused (DW-1) stands concluded and the matter is listed for final arguments, and it is at this stage, the accused wishes to re-call the complainant. In Indian Bank Association & Ors. v. Union Bank of India: (2014) 5 SCC 590, inter alia, it was observed by the Hon‘ble Supreme Court that the Court concerned must ensure that examination-in-chief, cross-examination and re-examination of the complainant be conducted within three months of assigning the case; the Court has the option of accepting affidavits of the witnesses, instead of examining them in Court; the wit…

Pr. Commissioner of Income Tax-Central vs. Ms. Harshita Maheshwari

ITA/94/2020HC Rajasthan21 Feb 2024

Bench: AVNEESH JHINGAN,SHUBHA MEHTA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Shah Originals vs. Commissioner of Income Tax 24 Mumbai

C.A. No.-002664-002664 - 2011Supreme Court21 Nov 2023

Bench: HON'BLE MR. JUSTICE S.V.N. BHATTI

Section 80

…r of profits of the business of the assessee from exports and can the gain be included in the computation of deduction under profits of the business of the assessee under Section 80 HHC of the Act?” 4 (2003) 5 SCC 590. 11 6.1 The admitted circumstances are that the assessee is a 100% EOU of garments. In the subject financial year, the assessee recorded the turnover of exports and the profits from the export of goods and merchandise outside India. It is also admitted that the assessee, without delay, received the consideration against the goods expor…

M/S Fingrowth Cooperative Bank Limited vs. Assistant Commissioner of Income Tax

ITA/9/2020HC Rajasthan24 Aug 2023

Bench: AUGUSTINE GEORGE MASIH,SAMEER JAIN

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-2, Kolkata vs. M/S. Century Enka Limited

ITA/7/2020HC Calcutta27 Feb 2023

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-4, Kolkata vs. M/S V2 Retail Ltd

ITAT/18/2020HC Calcutta28 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-4, Kolkata vs. M/S. Jagannath Banwarilal Texofabs Pvt Ltd

ITAT/9/2020HC Calcutta27 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-4, Kolkata vs. M/S. J.J.Exporters Ltd

ITAT/5/2020HC Calcutta26 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-5, Kolkata vs. L D S City Projects Pvt Ltd

ITAT/3/2020HC Calcutta21 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-4, Kolkata vs. M/S. Tcg Lifesciences Ltd

ITAT/10/2020HC Calcutta08 Apr 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax (Central-1), Kolkata vs. M/S. Rungta Mines Ltd

ITA/13/2020HC Calcutta08 Apr 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-2, Kolkata vs. M/S the Calcutta Tramways Company (1978) Ltd

ITAT/20/2020HC Calcutta04 Mar 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal Commissioner of Income Tax-1, Kolkata vs. M/S. Height Insurance Services Ltd

ITAT/4/2020HC Calcutta16 Dec 2021

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…

Principal CIT-14, Kolkata vs. Shri Vishwanath Gupta

ITA/21/2020HC Calcutta07 Dec 2021

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

…hts and powers of a general administrator. APL is legal representative of the deceased and the estate vests with them as such. In this regard, 84 AIR 1924 Cal 600 85 (2010) 10 SCC 422 86 (1999) 5 SCC 590 87 (2005) 1 SCC 787 88 (2005) 7 SCC 190 (APO NOS. 89, 90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 161 of 300 reference was made to Section 211 of the Indian Succession Act. The following decisions were referred to support such contention:  Nirod Barani Debi Versus Chamatkarini Debi89  Panduran…