S.S.I Ltd. v. DCIT

293 ITR 146Reported decision2007#1794 most cited

What is S.S.I Ltd. v. DCIT authority for?

The estimation of income for deducting tax at source under Section 192(1) of the Income-tax Act is valid when based on an honest and fair assessment by the assessee, a principle affirmed by the Supreme Court.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2023.

Also referred to as

Infosys Technologies Ltd. v. CIT · 293 ITR 146 · 297 ITR 167 · Section 192(1) income tax · tax deduction at source · TDS estimation · honest and fair estimate · Karnataka High Court judgment · Supreme Court affirmation

Judgments citing S.S.I Ltd. v. DCIT

Va Tech Wabag Limited, Chennai vs. ACIT, Chennai

Appeal is allowed for statistical purposes

ITA 807/CHNY/2016[2011-12]Status: DisposedITAT Chennai31 Aug 2023AY 2011-12

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Respondent: Dr. S. Palanikumar, CIT
Section 143(3)Section 144C(5)Section 92B

…e as per the following court decisions it is held that discount on ESOP is a permitted revenue expenditure. Hence we request you to allow the same as revenue expenditure. S.S.I Ltd. Vs DCIT 2004 85TTJ 1049 Chennai Tribunal CIT Vs. Infosys Technology Ltd. 2007 293 ITR 146, Karnataka High Court.” & C.O No.50/CHNY/2016 35. When these facts were confronted to Ld. CIT-DR, he could not controvert the same, but objected for allowing the claim. 36. After hearing both sides and going through the facts of the case, we set aside this issue to the file of the A.O, who will examine the claim of the assessee in detail and th…

DCIT, Chennai vs. V.A. Tech Wabag Limited, Chennai

Appeal is allowed for statistical purposes

ITA 953/CHNY/2015[2010-11]Status: DisposedITAT Chennai31 Aug 2023AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Respondent: Dr. S. Palanikumar, CIT
Section 143(3)Section 144C(5)Section 92B

…e as per the following court decisions it is held that discount on ESOP is a permitted revenue expenditure. Hence we request you to allow the same as revenue expenditure. S.S.I Ltd. Vs DCIT 2004 85TTJ 1049 Chennai Tribunal CIT Vs. Infosys Technology Ltd. 2007 293 ITR 146, Karnataka High Court.” & C.O No.50/CHNY/2016 35. When these facts were confronted to Ld. CIT-DR, he could not controvert the same, but objected for allowing the claim. 36. After hearing both sides and going through the facts of the case, we set aside this issue to the file of the A.O, who will examine the claim of the assessee in detail and th…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 566/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 565/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 564/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 563/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 562/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 561/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 560/BANG/2020[2013-14]Status: DisposedITAT Bangalore21 Jan 2021AY 2013-14

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 559/BANG/2020[2013-14]Status: DisposedITAT Bangalore21 Jan 2021AY 2013-14

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 558/BANG/2020[2012-13]Status: DisposedITAT Bangalore21 Jan 2021AY 2012-13

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer, (TDS)- Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 557/BANG/2020[2012-13]Status: DisposedITAT Bangalore21 Jan 2021AY 2012-13

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer (TDS) Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 556/BANG/2020[2011-12]Status: DisposedITAT Bangalore21 Jan 2021AY 2011-12

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Chitradurga vs. The Income Tax Officer, (TDS) Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 555/BANG/2020[2011-12]Status: DisposedITAT Bangalore21 Jan 2021AY 2011-12

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 554/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 553/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Jan 2021AY 2016-17

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 552/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 551/BANG/2020[2015-16]Status: DisposedITAT Bangalore21 Jan 2021AY 2015-16

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 550/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…

M/S. Life Insurance Corporation of India, Haveri vs. The Income Tax Officer (TDS) - Ward, Davangere

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

ITA 549/BANG/2020[2014-15]Status: DisposedITAT Bangalore21 Jan 2021AY 2014-15

Bench: Shri B.R Baskaran & Smt. Beena Pillai

For Appellant: Chytanya KK, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)
Section 10Section 133ASection 192Section 201Section 201(1)

…see’s case(referred to herein above) upheld estimation of income under section 192(1) of the Act, which has also been approved by Hon’ble Karnataka High Court in case of Page 70 of 74 ITA No.507 to 566 /Bang/2020 Infosys Technologies Ltd., reported in (2007) 293 ITR 146. This decision of Hon’ble Karnataka High Court has been affirmed by Hon’ble Supreme Court reported in (2008) 297 ITR 167. 6.3.25. Under section 192(1), the assessee is expected to make an honest and fair estimate of income and deduct tax at source. For assessment year 2015-16 and 2016-17, clause (2D) was applicable, however in the absence of spec…