What is R.C. Gupta v. Commissioner of Income Tax authority for?

A contractual liability for purchases is an allowable deduction in the year the liability is incurred, even if the assessee disputes the liability and the payee files a suit for recovery.

How many judgments cite R.C. Gupta v. Commissioner of Income Tax?

34 judgments on BharatTax cite R.C. Gupta v. Commissioner of Income Tax (298 ITR 161), spanning 2011 to 2025.

Which sections of the Income Tax Act does R.C. Gupta v. Commissioner of Income Tax come up under?

It is most often cited in judgments turning on Section 143(3), Section 35ABB, Section 37(1).

R.C. Gupta v. Commissioner of Income Tax (298 ITR 161)

BHARTI TELEMEDIA LIMITED,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 624/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…grant of license would arise in the year in which demand was made by the Railways irrespective of the fact when such enhanced fee was actually paid by assessee. 46. To the same effect is the decision of the Delhi High Court in the case of R.C. Gupta v. CIT: 298 ITR 161, wherein it was held that contractual liability for purchases is allowable deduction in the year in which the assessee had incurred such liability and the payee files suit for recovery, dehors the fact that liability was disputed by the assessee. 47. In the case of National Agricultural Cooperative Marketing Federation of India Ltd. v. CІТ: [2017…

DCIT, CIRCLE 4(2), NEW DELHI vs. M/S BHARTI TELEMEDIA LTD, NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4966/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…grant of license would arise in the year in which demand was made by the Railways irrespective of the fact when such enhanced fee was actually paid by assessee. 46. To the same effect is the decision of the Delhi High Court in the case of R.C. Gupta v. CIT: 298 ITR 161, wherein it was held that contractual liability for purchases is allowable deduction in the year in which the assessee had incurred such liability and the payee files suit for recovery, dehors the fact that liability was disputed by the assessee. 47. In the case of National Agricultural Cooperative Marketing Federation of India Ltd. v. CІТ: [2017…

BHARTI TELEMEDIA LIMITED,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4960/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…grant of license would arise in the year in which demand was made by the Railways irrespective of the fact when such enhanced fee was actually paid by assessee. 46. To the same effect is the decision of the Delhi High Court in the case of R.C. Gupta v. CIT: 298 ITR 161, wherein it was held that contractual liability for purchases is allowable deduction in the year in which the assessee had incurred such liability and the payee files suit for recovery, dehors the fact that liability was disputed by the assessee. 47. In the case of National Agricultural Cooperative Marketing Federation of India Ltd. v. CІТ: [2017…

DCIT, CIRCLE 4(2), NEW DELHI vs. MS BHARTI TELEMEDIA LTD, NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4868/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

…grant of license would arise in the year in which demand was made by the Railways irrespective of the fact when such enhanced fee was actually paid by assessee. 46. To the same effect is the decision of the Delhi High Court in the case of R.C. Gupta v. CIT: 298 ITR 161, wherein it was held that contractual liability for purchases is allowable deduction in the year in which the assessee had incurred such liability and the payee files suit for recovery, dehors the fact that liability was disputed by the assessee. 47. In the case of National Agricultural Cooperative Marketing Federation of India Ltd. v. CІТ: [2017…

HELTI INDIA PVT. LTD.,GURGAON vs. ADDL. CIT, SPECIAL RANGE- 4, NEW DELHI

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

ITA 502/DEL/2018[2013-14]Status: DisposedITAT Delhi14 Feb 2022AY 2013-14

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2013-14 Helti India Pvt. Ltd., Vs Addl. Cit, 6Th Floor, Building 8, Tower C, Special Range-4, Dlf Cyber City, Phase 3, New Delhi. Gurgaon. Pan: Aaach3583Q (Appellant) (Respondent) Assessee By : Shri S.K. Aggarwal, Ca Revenue By : Shri Kumar Padmapani Bora, Sr. Dr Date Of Hearing : 16.11.2021 Date Of Pronouncement : 14.02.2022 Order Per R.K. Panda, Am:

For Appellant: Shri S.K. Aggarwal, CAFor Respondent: Shri Kumar Padmapani Bora, Sr. DR

Section 143(3)Section 37

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : C : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER Assessment Year: 2013-14 Helti India Pvt. Ltd., Vs Addl. CIT, 6th Floor, Building 8, Tower C, Special Range-4, DLF Cyber City, Phase 3, New Delhi. Gurgaon. PAN: AAACH3583Q (Appellant) (Respondent) Assessee by : Shri S.K. Aggarwal, CA Revenue by : Shri Kumar Padmapani Bora, Sr. DR Date of Hearing : 16.11.2021 Date of Pronouncement : 14.02.2022 ORDER PER R.K. PANDA, AM: This appeal filed by the assessee is directed against the order dated 31.10.2017 of the CIT(A)-35,…

DCIT 12(2)(1), MUMBAI vs. FIRST FLIGHT COURIERS P.LTD, MUMBAI

In the result, the appeals for the AY 2011-12 and AY 2012-13 are dismissed

ITA 5399/MUM/2016[2011-12]Status: DisposedITAT Mumbai26 Apr 2018AY 2011-12

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2011-12 & Assessment Year: 2012-13 Dy. Commissioner Of M/S First Flight Couriers Pvt. Income Tax-12(2)(1), Room Vs. Ltd. G 1001/02, Lotus No. 223, 2Nd Floor, Aayakar Corporation Park, Off Jay Coach Bhavan, M.K. Road Flyover, Western Exp. Highway, Mumbai-400020. Graham Firth Steel Comp, Goregaon (East), Mumbai-400064. Pan No. Aaacf0841R (Appellant) (Respondent) Revenue By : Ms. Pooja Swaroop, Dr Assessee By : Mr. Brijmohan Pooranmal Agarwal, Ar Date Of Hearing : 05/04/2018 Date Of Pronouncement: 26/04/2018

For Appellant: Mr. Brijmohan PooranmalFor Respondent: Ms. Pooja Swaroop, DR

Section 143(3)

…on of contingent liability does not arise. Therefore, both the AO and the learned CIT (A) was wrong in treating the liability as contingent liability of the assessee. Our this stand is fortified by the following decisions:- (i) R. C. Gupta Vs CIT, Delhi-VIII, 298 ITR 161 (2008) wherein the Hon’ble Delhi High Court in Para 9 of the order has held as under:- “The liability in the instant case was capable on being estimated with reasonable certainty when a recovery suit was filed by Hindustan Steel Limited against the assessee on 18-8-1978. Merely because the liability was not a statutory one it could not be said th…

FIRST FLIGHT COURIERS LTD,MUMBAI vs. ACIT CIR 4(2), MUMBAI

In the result, assessee’s appeal is partly allowed for statistical

ITA 3436/MUM/2014[2010-11]Status: DisposedITAT Mumbai10 Aug 2016AY 2010-11

Bench: Sri Jason P. Boaz, Am & Sri Sandeep Gosain, Jm M/S. First Flight Couriers Vs. The Asst. Commissioner Of Ltd., 505, Cotton Exchange Income Tax -4(2), Mumbai Building, Kalbadi, Mumbai-2 Pan: Aaacf 0841 R Appellant .. Respondent

Section 115JSection 143Section 143(1)Section 2(24)Section 36(1)

…of contingent liability does not arise. Therefore, both the AO and the learned CIT (A) was wrong in treating the liability as contingent liability of the assessee. Our this stand is fortified by the following decisions:- (i) R. C. Gupta Vs CIT, Delhi-VIII, 298 ITR 161 (2008) wherein the Hon’ble Delhi High Court in Para 9 of the order has held as under:- “The liability in the instant case was capable on being estimated with reasonable certainty when a recovery suit was filed by Hindustan Steel Limited against the assessee on 18-8-1978. Merely because the liability was not a statutory one it could not be said…