Patson Transformers Ltd. v. DCIT

6 SOT 673Income Tax Appellate Tribunal2006#11922 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 366,416 Indian tax judgments — from 2016 to 2025.

Also reported as

103 TTJ 735

Judgments citing Patson Transformers Ltd. v. DCIT

Godrej Projects North Star LLP, Mumbai vs. Deputy Commissioner of Income Tax Circle41(2)(1), Mumbai

Appeal of the assessee is allowed

ITA 4258/MUM/2025[2024-25]Status: DisposedITAT Mumbai10 Sept 2025AY 2024-25

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 140Section 140ASection 143Section 143(1)Section 234ASection 234BSection 234B(2)Section 250Section 39Section 94

…ficer and given the directions. We do not find any reason to interfere with the orders of the CIT(A). 7. In the result, appeal dismissed." 17. Similarly, in the case of Patson Transformers Ltd. Vs. Deputy Commissioner of Income Tax, Special Range – VII [2006] 6 SOT 673 (AHD), Co-ordinate Bench of the Tribunal had, while examining identical issue in similar facts and circumstances, held as under: “14. In the light of above discussion, we are of the considered view that adjustment towards interest payable under section 234B is to be considered only at the time of filing return of income i.e., when payment of self-a…

Principal Commissioner of Income Tax Faridabad vs. M/S Nhpc Ltd

The appeals stand disposed of

ITA/336/2015HC Punjab & Haryana20 Sept 2019

Bench: MR. JUSTICE AJAY TEWARI,MR. JUSTICE HARNARESH SINGH GILL

Section 115JSection 143(3)Section 2Section 2(24)Section 24Section 260ASection 28

…e. 7. The revenue filed appeal before the ITAT and challenged the order passed by the CIT(A). Dismissing the appeal of the revenue the Tribunal upheld the order of the CIT(A) relying upon the judgment in the case of M/s Patson Transforms Ltd. Vs. DCIT (2006) 6 SOT 673 (Ahd.). It was held by the Tribunal that as per provision of Section 140A of the Act, it is only at the time of filing of return, the issue of computation of interest under various provisions of the Act i.e. 234A, 234B & 234C arise and at that time, if any, interest is payable under these Anuradha 2019.09.25 11:40 I attest to the ac…

Indo Amines Ltd, Dombivali vs. ITO WD 1(5), Kalyan

In the result, appeal of the assessee in ITA

ITA 1389/MUM/2017[2013-14]Status: DisposedITAT Mumbai30 Jan 2019AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri M.N. NandgaonkarFor Respondent: Shri Abi Rama Kartikeyan
Section 143(1)Section 143(3)Section 154Section 234BSection 41(1)

…claim has been sustained by the Ld.CIT(A). Submissions made before the lower authorities have been reiterated before us. Ld. Counsel for the assessee placed reliance on the decision of the Ahmadabad Bench in the case of Patson Transformers Ltd v. DCIT [(2006) 6 SOT 673] and the decision of the Hon’ble Delhi High Court in the case of Dr. Prannoy Roy & Another v. CIT [254 ITR 755]. The calculation sheet is also furnished before us. According to the assessee the interest u/s. 234B of the Act should have been charged considering the amounts paid even after filing of return of income. 5. We have heard the rival submi…

Indo Amines Ltd, Dombivali vs. Asst CIT Cir 1, Kalyan

In the result, appeal of the assessee in ITA

ITA 1388/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jan 2019AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri M.N. NandgaonkarFor Respondent: Shri Abi Rama Kartikeyan
Section 143(1)Section 143(3)Section 154Section 234BSection 41(1)

…claim has been sustained by the Ld.CIT(A). Submissions made before the lower authorities have been reiterated before us. Ld. Counsel for the assessee placed reliance on the decision of the Ahmadabad Bench in the case of Patson Transformers Ltd v. DCIT [(2006) 6 SOT 673] and the decision of the Hon’ble Delhi High Court in the case of Dr. Prannoy Roy & Another v. CIT [254 ITR 755]. The calculation sheet is also furnished before us. According to the assessee the interest u/s. 234B of the Act should have been charged considering the amounts paid even after filing of return of income. 5. We have heard the rival submi…

Indo Amines Ltd, Dombivali vs. Asst CIT Cir 1, Kalyan

In the result, appeal of the assessee in ITA

ITA 1387/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jan 2019AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri M.N. NandgaonkarFor Respondent: Shri Abi Rama Kartikeyan
Section 143(1)Section 143(3)Section 154Section 234BSection 41(1)

…claim has been sustained by the Ld.CIT(A). Submissions made before the lower authorities have been reiterated before us. Ld. Counsel for the assessee placed reliance on the decision of the Ahmadabad Bench in the case of Patson Transformers Ltd v. DCIT [(2006) 6 SOT 673] and the decision of the Hon’ble Delhi High Court in the case of Dr. Prannoy Roy & Another v. CIT [254 ITR 755]. The calculation sheet is also furnished before us. According to the assessee the interest u/s. 234B of the Act should have been charged considering the amounts paid even after filing of return of income. 5. We have heard the rival submi…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 467/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Oct 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…ary to the method prescribed in CBDT Circular No.549 dated 31.10.1989: 182 ITR (St.) 40, which is binding on the Income Tax Department. The Ld. AR relied upon the decision of the Ahmedabad Bench of the Tribunal in the case of Patson Transformers Ltd. v. DCIT: 103 TTJ 735 wherein the Tribunal was considering the similar issue regarding the calculation of interest under section 234B in the light of the Explanation to section 140A of the Act and decided the issue in favour of assessee. The Ld. AR relied upon the decision of the Mumbai Bench of the Tribunal in the case of ACIT v. C.C Chokshi and Co.: ITA No. 7791/Mum…

Rashtriya Chemical Fetilizers Ltd, Mumbai vs. Asst CIT Large Tax Payer Unit, Mumbai

ITA 2239/MUM/2013[1998-99]Status: DisposedITAT Mumbai11 May 2018AY 1998-99
For Appellant: Shri S.E. Dastur and Shri Niraj ShethFor Respondent: Shri R.P. Meena -CIT-DR
Section 140ASection 143Section 234BSection 234B(1)Section 234B(2)

…has to be charged only on the remainder. Learned CIT(A) rejected the plea of the assessee in this regard. 24. We have heard the rival submissions. Similar issue was considered by the ITAT Ahmedabad Bench in the case of Paston Transformer Ltd. Vs. DCIT (2006) 6 SOT 673 (Ahd), wherein it was held as follows :- 2239/M/13-Rashtriya Chemicals & Fertilizers Ltd. "The controversy under consideration related to interpretation of Explanation to sub-section (1) of section 140A, which provides that where the assessee pays only part of the amount due at the time of filing the return such payment shall first be adjusted to…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

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

ITA 6021/DEL/2012[2008-09]Status: DisposedITAT Delhi09 Nov 2017AY 2008-09

Bench: Shri N.K. Saini & Shri K.N. Charry

Section 143(3)Section 144CSection 144C(5)Section 14ASection 35DSection 43BSection 92C

…od prescribed in CBDT Circular No.549 dated 31.10.1989: 182 ITR (St.) 40, which is binding on the Income Tax Department. In this respect he placed reliance on the decision of the Ahmedabad Bench of the Tribunal in the case of Patson Transformers Ltd. v. DCIT: 103 TTJ 735 wherein the Tribunal was considering the similar issue regarding the calculation of interest under section 234B in the light of the Explanation to section 140A of the Act and decided the issue in 129 favour of assessee. Further reliance is placed on the decision of the Mumbai Bench of the Tribunal in the case of ACIT v. C.C Chokshi and Co.: ITA N…

Maruti Suzuki India Ltd., New Delhi vs. Addl. CIT, New Delhi

Appeal is allowed

ITA 5720/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Jul 2016AY 2007-08

Bench: Shri I.C. Sudhir & Shri L.P. Sahu Assessment Year: 2007-08 Assessment Year: 2007-08 Maruti Suzuki India Ltd., Vs. Additional Cit, Plot No.1, Nelson Mandela Road, Range-6, Vasant Road, New Delhi. New Delhi. (Pan: Aaacm0829Q) (Appellant) (Respondent) Assessee By: S/Shri Ajay Vohra, Sr. Adv. Neeraj Jain, Rohit Jain, Adv. Romit Katyal & Ms. Tejasvi Jain, Cas Department By:Shri Amrendra Kumar, Cit(Dr)

For Appellant: S/Shri Ajay Vohra, Sr. Adv. NeerajFor Respondent: Shri Amrendra Kumar, CIT(DR)

…ed in CBDT Circular No.549 dated 31.10.1989, reported in 182 ITR(St.) 1, which is binding on the Income Tax department. Reliance in this regard was placed on the decision of the Ahmedabad Bench of the Tribunal in the case of Patson Transformers Ltd. v. DCIT: 103 TTJ 735 wherein the Tribunal was considering the similar issue regarding the calculation of interest under section 234B in the light of the Explanation to section 140A of the Act and decided the issue in favour of assessee. Reliance is further placed on the decision of the Mumbai Bench of the Tribunal in the case of ACIT v. C.C Chokshi and Co.: ITA No.…

Patson Transformers Ltd. v. DCIT (6 SOT 673) — Cited in 9 Judgments | BharatTax