How many judgments cite S.A. Builders Ltd. v. CIT?

1,449 judgments on BharatTax cite S.A. Builders Ltd. v. CIT (288 ITR 1), spanning 2008 to 2026.

Which sections of the Income Tax Act does S.A. Builders Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 36(1)(iii), Section 14A, Section 1961, Section 148, Section 147.

S.A. Builders Ltd. v. CIT

288 ITR 1Supreme Court of India2007#26 most cited

What is S.A. Builders Ltd. v. CIT authority for?

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

1,449

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2026.

Also referred to as

S.A. Builders Ltd. v. CIT · 288 ITR 1 · Section 36(1)(iii) · commercial expediency · business expediency · interest-free advances · disallowance of interest · onus to prove business purpose · borrowed funds · Revenue interference

Also reported as

158 Taxmann 74158 Taxmann.com 74

Sections most often in play

Section 143(3)Section 36(1)(iii)Section 14A Section 1961 Section 148 Section 147 Section 40(a)(ia)Section 142(1)

Issues it is cited on

commercial expediency interest free advances section 36(1)(iii)business expediency disallowance of interest expenditure section 36(1)section 36 revenue expenditure section 37(1)section 37 capital expenditure section 14a

Judgments citing S.A. Builders Ltd. v. CIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…ing funds larger than the investments made in tax-free securities then in such cases, disallowance under section 14A cannot be made. 21. On behalf of Revenue Mr. Arijit Prasad, the learned Senior Advocate refers to SA Builders Ltd. v. CIT [2007] 158 Taxman 74/288 ITR 1 (SC), where this Court ruled on issue of disallowance in relation to funds lent to sister concern out of mixed funds. The issue in SA Builders is pending consideration before the larger bench of this Court in Addl. CIT v. Tulip Star Hotels Ltd. [SLP (C) No. 14729 of 2012, dated 7-2-2019]. The counsel therefore, argues that there is no finality on t…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

FAIRCHEM ORGANICS LTD.,,AHMEDABAD vs. ACIT, CIR-15(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6143/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Mar 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarfairchem Organics Acit Circle - Limited 15(1)(1), 253/P & 312, Village Vs. Aayakar Bhawan, M. Chekhala, Sanand K. Road, Churchgate, Kadi Highway, Taluka Mumbai-400 020 Sanand, Distt Ahmedabad, Gujarat – 382 115. Pan/Gir No. Aadcf6900E (Applicant) (Respondent) Assessee By Shri Saurabh Soparkar, Ld. Ar Revenue By Shri Ankit Tiwari, Ld. Dr Date Of Hearing 04.03.2026 Date Of Pronouncement 20.03.2026

Section 115JSection 143(3)Section 250Section 36(1)(iii)

…rcial expediency in granting such advances and also failed to establish nexus between own funds and advances. Relying upon the provisions of section 36(1)(iii) and the decision of the Hon’ble Supreme Court in the case of S.A. Builders vs. CIT (Appeals) [2007] 288 ITR 1 (SC), the Assessing Officer held that interest on borrowed funds is allowable only when such funds are used for the purposes of business. Accordingly, the Assessing Officer computed proportionate disallowance of interest at Rs. 68,14,949/- and added the same to the total income of the assessee. 6. Aggrieved by the said assessment order, the assesse…

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

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

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

…ncome tax department or revenue official cannot guide a businessman in which manner risk has to be undertaken. Such an approach of the revenue has been judicially frowned by the Hon'ble Apex Court on several occasions, for instance in the case of SA Builders, 288 ITR 1 (SC)and CIT vs. Panipat Woollen and General Mills Company Ltd., 103 ITR 66 (SC). The Courts have held that Income Tax Department cannot sit in the armchair of businessman to decide what is profitable and how the business should be carried out. Commercial expediency has to be seen from the point of view of businessman. Here in this case if the inves…

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

ITA 886/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Mar 2026AY 2021-22

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Sh. Pankaj Bhalla, CAFor Respondent: Sh. Manav Mangal, CIT DR

Section 143(3)Section 144BSection 250(6)Section 69C

…pted and the sales were not disputed, the AO was not justified in making an ad-hoc disallowance of 80% of the commission expenditure without rejecting the books of account. Reliance was placed on several judicial precedents including SA Builders Ltd. vs. CIT (288 ITR 1, SC) and other decisions of the Hon’ble Supreme Court and various High Courts to contend that the Assessing Officer cannot sit in the armchair of the businessman and decide the reasonableness of business expenditure. 53. The Ld. Departmental Representative, on the other hand, relied upon the findings recorded by the lower authorities and submitted…

UFX VENTURES PVT. LTD.,CHENNAI vs. ACIT, CORPORATE CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessee are

ITA 2273/CHNY/2025[2014-15]Status: DisposedITAT Chennai11 Mar 2026AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT

Section 143(3)Section 250Section 37

…and submitted that interest paid on capital borrowed for the purpose of business is allowable as deduction. Reliance was also placed on various judicial precedents including the decision of the Hon’ble Supreme Court in the case of S.A. Builders Ltd. vs. CIT (288 ITR 1), the decision of the Hon’ble Punjab & Haryana High Court in Bright Enterprises Pvt. Ltd. vs. CIT, the decision of the Chennai Tribunal in TT Holding & Services Pvt. Ltd. vs. ACIT and other decisions of the Hon’ble High Courts wherein it has been held that interest on borrowed funds cannot be disallowed where advances are made to sister concern…

UFX VENTURES PVT. LTD.,CHENNAI vs. ACIT, CORPORATE CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessee are

ITA 2272/CHNY/2025[2013-14]Status: DisposedITAT Chennai11 Mar 2026AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT

Section 143(3)Section 250Section 37

KAMLA DEVI JAYDAYAL JAIN PRIVATE LIMITED,MUZAFFARPUR vs. ASSISTANT COMMISIONER OF INCOME TAX, MUZAFFARPUR

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

ITA 19/PAT/2025[2016-17]Status: DisposedITAT Patna24 Feb 2026AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 132(1)Section 250

…the case of the AO that there was any suppression of income and thus, the addition is made just on estimate basis and may kindly be deleted. The assessee has relied upon the following judgments: Hon’ble Apex Court in the case of SA Builders Vs CIT reported in 288 ITR 1 (SC) P & H HC in case of CIT v. S.S.P. Pvt ltd reported in (2011) 202 Taxman 386 Patna bench of ITAT in the case of ITO, Ward: -5(1), Patna V. M/s. Rajendra Medical Agency vide ITA No. 502/Pat/04 Delhi ‘B’ bench of ITAT in the case of Shankar Trading Co. Pvt. Ltd. V. ACIT, Circle 8(1) reported in (2006) 152 Taxman 49 Del (Mag) Hon’ble Apex Court in…

NIPUN MALHOTRA,MANDI vs. ITO, WARD, MANDI

In the result, appeal of the assessee is allowed

ITA 81/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh20 Feb 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 81/Chd/2022 "नधा"रण वष" / Assessment Year: 2013-14 Nipun Malhotra, The Ito, 135/A, Jawahar Nagar, Vs Ward, Mandi, Himachal Pradesh. Mandi (Hp). "थायी लेखा सं./Pan No: Ablpm6589N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026 Physical Hearing O R D E R

For Appellant: Shri Ajay Jain, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR

Section 143(3)Section 263

…of purchasing bottles and sales of liquor because this concern is engaged in the manufacturing of liquor. It was an advance to secure the supplies, hence, this aspect is covered by the judgement of Hon'ble Supreme Court in the case of S.A. Builders Pvt. Ltd. 288 ITR 1. No disallowance ought to have been made by the AO. The ld.CIT (Appeals) has erred in confirming the disallowance and ignoring the subsequent judgements cited by the assessee. It is an erroneous approach at the end of ld. First Appellate Authority to rely upon a judgement which has been overruled by the Hon'ble Supreme Court. Therefore, taking into…

DCIT 2(3)(1), MUMBAI vs. TATA STEEL LTD, MUMBAI

In the result, appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 3555/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09

For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR

Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

…the subsidiary for some business purposes, the assessee would, in our opinion, ordinarily be entitled to deduction of interest on its borrowed loans”. This decision was considered by the Hon'ble Supreme Court in its decision of SA Builders Ltd. vs. CIT [2007] 288 ITR 1 (SC) wherein it observed that the transfer of borrowed funds has to be viewed from the point of view of commercial expediency and not from the point of view of whether the amount was advanced for earning profits. These two decisions were off late considered by the Hon'ble Supreme Court in a recent decision in the case of Shark Business System vs. C…

TATA STEEL LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 3294/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09

For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR

Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

M/S.RUNWAL COMMERCIAL ASSETS PVT LTD (NOW MERGED WITH WHEELABRATOR ALLOY CASTINGS LIMITED),MUMBAI vs. THE INCOME TAX OFFICER, WARD 15(3)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 7623/MUM/2025[2023-24]Status: DisposedITAT Mumbai18 Feb 2026AY 2023-24

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Runwal Commercial Ito Ward-15(3)(1), Assets Pvt. Ltd. (Now Aayakar Bhavan, Merged With Vs. Maharshi Karve Wheelabrator Alloy Road, New Marine Castings Limited) Lines, Churchgate, Runwal & Omkar Mumbai-400 020 Esquires, 4Th Floor, Off Eastern Exp. Highway Opp. Sion Chuan Bhatti Signal, Sion East, Mumbai-400 022 Pan/Gir No. Aajcr7366J (Applicant) (Respondent) Assessee By Shri Rakesh Joshi, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 18.02.2026

Section 115BSection 143(3)Section 144BSection 250Section 68

…expediency in the conversion of OCDs into equity and the subsequent inter-corporate movement of funds. In this context, the assessee had relied before the lower authorities on the principle laid down by the Hon’ble Supreme Court in S.A. Builders Ltd. v. CIT (288 ITR 1), wherein it has been held that commercial expediency must be viewed from the standpoint of the businessman and not from that of the Revenue authorities. The Court observed that the authorities cannot sit in the armchair of a businessman to decide how much expenditure or investment is reasonable. The said principle has been consistently followed in…

INCOME TAX OFFICER, CHENNAI vs. AVIGNA PRIVATE LIMITED, CHENNAI

In the result, the appeal of the revenue is allowed for statistical purposes

ITA 2930/CHNY/2025[2023-24]Status: DisposedITAT Chennai13 Feb 2026AY 2023-24

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2930/Chny/2025 िनधा$रण वष$ /Assessment Year: 2023-24

For Appellant: Mr. M. Karunakaran, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT

Section 250Section 36(1)(iii)Section 40

…ny documentary evidences in support of the claim of the assessee that the interest bearing funds have been invested in the subsidiaries which have a direct nexus to the business of the assessee. The Hon'ble Supreme Court in the case of SA Builders Ltd vs CIT (288 ITR 1) has laid down the ratio that if the amount advanced to the subsidiaries as a measure of commercial expediency then the interest on amount borrowed towards the said advance is to be considered as for the purpose of business and no disallowance is to be made u/s.36(1)(iii) of the Act. It is relevant to note here that the Hon'ble Supreme Court in the…

JCIT(OSD)-14(1)(1), MUMBAI vs. KUKREJA BUILDERS PVT. LTD., MUMBAI

In the result, the revenue’s appeal is partly allowed in the above terms

ITA 2102/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Dcit – 14(1)(1), Mumbai M/S. Kukreja Builders Room No. 432, 4Th Floor, Pvt. Ltd. Aayakarbhavan, M.K. Road, 4 & 5Th Floor, Sai Mumbai - 400020 Commercial Building, Bks Vs. Devshi Marg., Govandi (E), Mumbai, Maharashtra– 400088 Pan: Aacck5040M (Appellant) (Respondent) Present For: Assessee By : Shri Ajay Singh & Shri Akshay Pawar, Ld. A.R. Revenue By : Shri Hemanshu Joshi, (Sr. D.R.) Date Of Hearing : 12.12.2025 Date Of Pronouncement : 13.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In The Instant Case, The Assessee During The A.Y. Under Consideration Had Declared Its Total Income As Rs. 2,20,00,580/- By Filing Its Return Of Income, Which Was Initially Processed Under Section 143 Of The Act. 2 M/S. Kukreja Builders Pvt. Ltd.

For Appellant: Shri Ajay Singh & Shri AkshayFor Respondent: Shri Hemanshu Joshi, (SR. D.R.)

Section 131Section 133(6)Section 143Section 250Section 68

…oner while relying on the judgments of the Hon’ble Apex Court in the case of Hero Cycles (P) Ltd. vs. CIT (2015) 379 ITR 347 (SC) and in the case of S.A. Builders Ltd. vs. Commissioner of Income Tax (Appeals), Civil Appeal No. 5811 of 2006 [reported in (2007) 288 ITR 1 (SC)] and considering the commercial expediency, deleted the aforesaid addition made on account of disallowance made qua expenditure of interest on loan. 41. We have given thoughtful consideration to the peculiar facts and circumstances of the case. Admittedly, the Ld. Commissioner while deleting the aforesaid addition of Rs.86,99,072/- not only 2…

ZETA BUILDTECH PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-7, DELHI, DELHI

In the result, appeal filed by the assessee is allowed

ITA 3449/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Suresh Kumar Gupta, CAFor Respondent: Ms. Ankush Kalra, Sr.DR

Section 142(1)Section 143(1)(a)Section 143(2)

…s profits. The expediency, legitimacy and the business needs will have to be examined from the assessee's point of view and not from the department's view. To support the above proposition of law, reliance is placed in the following decisions:  S.A. Builders 288 ITR 1 (SC)  CIT v. Walchand & Co. (P) Ltd.[1967] 65 ITR 381 (SC)  CIT Vs. Dhanrajgirji Raja Narasingirji 91 ITR 544 (SC)  J.K. Woollen Manufacturers v. CIT[1969] 72 ITR 612 (SC)  Aluminium Corpn. of India Ltd. v. CIT [1972] 86 ITR 11 (SC)  Dalmia Cement (254 ITR 377) (Del)  Voltamp Transformers Pvt. Ltd. vs. CIT 129 ITR 105 (Guj)  Shaw Wallace Dis…

WARANA INDUSRIES LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1, , KOLHAPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Cross Objection filed by the assessee is dismissed

ITA 1285/PUN/2019[2014-15]Status: DisposedITAT Pune22 Jan 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

For Appellant: None (written submissions filed)For Respondent: Shri Manish Mehta, Addl.CIT

Section 143(3)Section 36(1)Section 36(1)(iii)

….20,38,356/- is concerned, the assessee has filed the following written submissions: 9 CO No.39/PUN/2022 10 CO No.39/PUN/2022 10. The assessee in the written submissions has also relied on the following decisions: i) S.A. Builders Ltd. Vs. CIT & Anr (2007) 288 ITR 1 (SC) ii) PCIT vs. Sesa Resources Ltd. (2018) 404 ITR 707 (Bom) iii) CIT vs. Reliance Industries Ltd. (2019) 102 taxmann.com 52 (SC) iv) PCIT vs. Reebok India Company (2018) 103 CCH 28 (Del) v) M/s. Garuda Plant Product Ltd. Vs. DCIT vide ITA Nos.1539/PUN/2016 and 2966/PUN/2016 order dated 27.06.2019 for assessment years 2012-13 and 2013-14 vi) HDFC…

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

In the result, the appeal of the assessee is partly allowed

ITA 1179/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16

Section 142(1)Section 143(3)Section 201Section 263Section 36(1)(iii)Section 36(1)(va)Section 41(1)Section 68

…the ordinary course of business, the question of disallowance of interest expenditure under Section 36(1)(iii) of the Act does not arise. This legal principle is supported by the decision of the Hon'ble Supreme Court in the case of S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC). 29. In so far as the advance given to M/s. Teja Dal Grading Pvt. Ltd. is concerned, once again, the assessee claims that, the same has been given in the ordinary course of business for purchase of seeds. However, the said advance has become irrecoverable and once the principal itself is bad and irrecoverable, then the question of charging int…

GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

ITA 83/DDN/2025[2022-23]Status: DisposedITAT Dehradun14 Jan 2026AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR

Section 143(3)Section 9(1)(vii)

…. M/s. Chadha Power (ITA No. 3055/Del/2018), the Co-ordinate Bench of the Delhi Tribunal observed and held as under:- “8. Thereafter, the ld. CIT (A) has referred to the principles laid down by Hon'ble Supreme Court in the case of SA Builders Ltd. reported in 288 ITR 1. As regards the applicability of section 40(a)(i), Id. CIT(A) observed that first of all, expenses claimed in computing the income chargeable under the head 'profits and gains of business or profession' towards royalty, fee for technical services or other sum chargeable under the Act which is payable outside India or in India to a non- resident on…

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

ITA 81/DDN/2024[2020-21]Status: DisposedITAT Dehradun14 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR

Section 143(3)Section 9(1)(vii)

GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

ITA 71/DDN/2024[2021-22]Status: DisposedITAT Dehradun14 Jan 2026AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR

Section 143(3)Section 9(1)(vii)

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