Rao Bahadur Ravulu Subba Rao v. Commissioner of Income

30 ITR 163Supreme Court of India1956#11496 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2022.

Judgments citing Rao Bahadur Ravulu Subba Rao v. Commissioner of Income

COMMISSIONER OF CENTRAL EXCISE RAIPUR vs. M/S SEPCO ELECTRIC POWER CONSTRUCTION CORPORATION

C.A. No.-004928 - 2018Supreme Court11 Jul 2022

Bench: HON'BLE MR. JUSTICE M.R. SHAH

Section 65Section 73Section 75Section 76Section 77Section 78

…e. It is all the more so because the Finance Act is one consolidating and amending the law relating to income-tax, super tax, service tax, etc. To support this proposition, we may derive inspiration from Rao Bahadur Ravulu Subba Rao v. CIT, [1956] 30 ITR 163 (SC) at page 169. Therefore, the natural not the legal or technical meaning of the word “firm” is to be given. Section 65(13): Firm: Natural meaning: 24. Having read the provisions in the context it is used and the scheme in which it is intended to be used and the object and purpose of enacting the statute and the absence of any intelli…

AIRPORT AUTHORITY OF INDIA,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are allowed

ITA 5163/DEL/2012[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi04 May 2021

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5162/Del/2012 : Asstt. Year : 2010-11 Ita No. 5163/Del/2012 : Asstt. Year : 2011-12 Airports Authority Of India, Vs Income Tax Officer(Tds), Rajiv Gandhi Bhavan, Safdarjung Ward-1(1), Airport, New Delhi-110003 New Delhi (Appellant) (Respondent) Pan No. Aaaca6412D Assessee By : Sh. Ashish Gupta, Adv. Revenue By : Sh. Sohail Malik, Sr. Dr Date Of Hearing: 24.02.2021 Date Of Pronouncement: 04.05.2021

For Appellant: Sh. Ashish Gupta, AdvFor Respondent: Sh. Sohail Malik, Sr. DR
Section 10Section 10(6)(ii)Section 115A

…ax. There also the principle of reciprocity is embodied and excludes the business or professional activities of such persons.  It is well settled legal position that the Act is a self contained code. In the case of Rao Bahadur Ravulu Subba Rao vs CIT [1956] 30 ITR 163 (SC)  Although the applicant has presented a picture that the two agreements are separate and, therefore, each has to be viewed in isolation to the other, However, the crucial fact that the applicant failed to mention initially is that these agreements are infact appendices/ annexures to the memorandum of agreement number NATT-4407 entered into…

AIRPORT AUTHORITY OF INDIA,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are allowed

ITA 5162/DEL/2012[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Delhi04 May 2021

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5162/Del/2012 : Asstt. Year : 2010-11 Ita No. 5163/Del/2012 : Asstt. Year : 2011-12 Airports Authority Of India, Vs Income Tax Officer(Tds), Rajiv Gandhi Bhavan, Safdarjung Ward-1(1), Airport, New Delhi-110003 New Delhi (Appellant) (Respondent) Pan No. Aaaca6412D Assessee By : Sh. Ashish Gupta, Adv. Revenue By : Sh. Sohail Malik, Sr. Dr Date Of Hearing: 24.02.2021 Date Of Pronouncement: 04.05.2021

For Appellant: Sh. Ashish Gupta, AdvFor Respondent: Sh. Sohail Malik, Sr. DR
Section 10Section 10(6)(ii)Section 115A

…ax. There also the principle of reciprocity is embodied and excludes the business or professional activities of such persons.  It is well settled legal position that the Act is a self contained code. In the case of Rao Bahadur Ravulu Subba Rao vs CIT [1956] 30 ITR 163 (SC)  Although the applicant has presented a picture that the two agreements are separate and, therefore, each has to be viewed in isolation to the other, However, the crucial fact that the applicant failed to mention initially is that these agreements are infact appendices/ annexures to the memorandum of agreement number NATT-4407 entered into…

TRENT LTD,MUMBAI vs. ADDL. C.I.T.-2(3), MUMBAI

ITA 5775/MUM/2011[2007-08]Status: DisposedITAT Mumbai15 Jul 2020AY 2007-08

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Trent Ltd., V. Add. Cit – 2(3) Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent) Addl. Cit – 2(3) V. M/S. Trent Ltd., Room No. 556, 5Th Floor Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai - 400 020 Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent) M/S. Trent Ltd., V. Dy. Cit – 2(3) Bombay House, 2Nd Floor, 24 Aayakar Bhavan, M.K. Road Homi Mody Street, Fort Mumbai Mumbai – 400 001 Pan: Aaacl1838J (Appellant) (Respondent)

Section 14ASection 35DSection 37(1)

…ould be given to these words "industrial undertaking" must be the natural meaning. It is all the more so because the Income-tax Act is one consolidating and amending the law relating to income-tax and super tax. (See Rao Bahadur Ravulu Subba Rao v. CIT [1956] 30 ITR 163 (SC) at 169). xxx xxx xxx 33 ITA NO.5775/MUM/2011 (A.Y: 2007-08) & Other 12 files M/s. Trent Ltd., The words "industrial undertaking" therefore, should be understood to have been used in section 54D in a wide sense, taking in its fold any project or business a person may undertake. The "running of a lodge", by the assessee, therore, can be said t…

THE COMMISSIONER OF INCOME TAX-II vs. MCKINSEY KNOWLEDGE CENTRE INDIA PVT.LTD.

ITA/217/2014HC Delhi27 Mar 2015

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.K.GAUBA

Section 10ASection 143(1)Section 143(2)Section 260ASection 92C

…e of the services provided by the company in general but the nature of services being exported or transmitted outside of India; and whether or not it falls within the ambit of „services of 1 [1956] 30 ITR 163 (SC) 2 [2000] 243 ITR 143 (SC) ITA 217/2014 Page 5 similar nature‟ within the meaning of Explanation – 2, to Section 10A of the Act. The provision reads as follows: “10A. Special provision in respect of newly established undertakings in free trade zones, etc. (1) Subject to the provisions of this section, a deduction of such pr…

THE COMMISSIONER OF INCOME TAX-II vs. MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD.

ITA-217/2014HC Delhi27 Mar 2015
Section 10ASection 143(1)Section 143(2)Section 260ASection 92C

…e of the services provided by the company in general but the nature of services being exported or transmitted outside of India; and whether or not it falls within the ambit of „services of 1 [1956] 30 ITR 163 (SC) 2 [2000] 243 ITR 143 (SC) 2015:DHC:3029-DB ITA 217/2014 Page 5 similar nature‟ within the meaning of Explanation – 2, to Section 10A of the Act. The provision reads as follows: “10A. Special provision in respect of newly established undertakings in free trade zones, etc. (1) Subject to the provisions of this section, a dedu…

ANSAL HOUSING & CONSTRUCTION LTD vs. C.I.T

ITA/1261/2008HC Delhi30 Oct 2009

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 143(3)Section 260ASection 35

…ITA No. 1261/08, 1278/08, 1287/08 & 1402/08 nsk Page 1 of 16 Reportable * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA No. 1261 of 2008 ITA No. 1278 of 2008 ITA No. 1287 of 2008 ITA No. 1402 of 2008 % Reserved on : September 17, 2009 Pronounced on : October 30, 2009 Ansal Housing & Construction Ltd. . . . Appellant through : Mr. Ajay Vohra with Ms. Kavita Jha and Mr. Sriram Krishna, Advocates VERSUS Commissioner of Income Tax . . . Respondent through : Mr. Subhash Bansal, Advocate CORAM :- THE HON‟BLE MR. JUS…

ANSAL HOUSING & CONSTRUCTION LTD vs. C.I.T

Accordingly, these appeals preferred by the assessee are dismissed with costs of Rs

ITA - 1278 / 2008HC Delhi30 Oct 2009
Section 143(3)Section 260ASection 35

…words "industrial undertaking" must be the natural meaning. It is all the more so because the Income-tax Act is one consolidating and amending the law relating to income-tax and super tax. (See Rao Bahadur Ravulu Subba Rao v. Commissioner of Income tAx (1956) 30 ITR 163 (SC) at 169). - 6. "Undertaking" in common parlance means an "enterprise", "venture", "engagement". It can as well mean "the act of one who undertakes or engages in a project or business" (Webster). An undertaking mentioned in Section 54D must be one maintained by a person for the purpose of carrying on his business. "Undertaking" for the purpos…

ANSAL HOUSING & CONSTRUCTION LTD vs. C.I.T

Accordingly, these appeals preferred by the assessee are dismissed with costs of Rs

ITA - 1287 / 2008HC Delhi30 Oct 2009
Section 35Section 35DSection 8

…words "industrial undertaking" must be the natural meaning. It is all the more so because the Income-tax Act is one consolidating and amending the law relating to income-tax and super tax. (See Rao Bahadur Ravulu Subba Rao v. Commissioner of Income tAx (1956) 30 ITR 163 (SC) at 169). - 6. "Undertaking" in common parlance means an "enterprise", "venture", "engagement". It can as well mean "the act of one who undertakes or engages in a project or business" (Webster). An undertaking mentioned in Section 54D must be one maintained by a person for the purpose of carrying on his business. "Undertaking" for the purpos…

Rao Bahadur Ravulu Subba Rao v. Commissioner of Income (30 ITR 163) — Cited in 9 Judgments | BharatTax