Sarabhai Management Corporation Ltd. v. CIT

102 ITR 25High Court1976#3761 most cited

What is Sarabhai Management Corporation Ltd. v. CIT authority for?

Business commencement is marked by the first activity undertaken to acquire immovable property, and expenses incurred during the interval between business setup and commencement are deductible.

31

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2024.

Also referred to as

Sarabhai Management Corporation Ltd. v. CIT · business commencement · acquisition of immovable property · expenses during interval · deductible expenses · Gujarat High Court

Judgments citing Sarabhai Management Corporation Ltd. v. CIT

DIVYANIDHI BUILDCON PRIVATE LIMITED,JAIPUR vs. DCIT CIRCLE 6, JAIPUR, JAIPUR

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

ITA 616/JPR/2023[2017-18]Status: DisposedITAT Jaipur03 Jun 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri V.K. Jain (C.A.)For Respondent: Smt. A.S. Nehra (Addl.CIT)
Section 142(1)Section 143(2)Section 143(3)Section 45(3)

…aranpura Collieries Ltd. 201 ITR 498 iii) C.I.T. vs. L VE. Vairavan Chettiar 72 ITR 114. iv) Arkaaye Builders & Developers Pvt. Ltd. vs. ITO, Ward-2(1), (ITA No. 3552/Del/2011) DELHI BENCH "SMC": NEW DELHI In the case of Sarabhai Management Corpn. Ltd. [1976] 102 ITR 25 (Guj.), the Hon'ble Gujarat High Court has held that the business commences with the first activity for acquiring by purchase or otherwise immovable property. There may be an interval between the setting up of the business and the commencement of the business. All expenses incurred during that interval are also permissible for deduction. The decis…

DCIT, CIRCLE- 11(1), NEW DELHI vs. HMS REAL ESTATE PVT. LTD., NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 4190/DEL/2018[2014-15]Status: DisposedITAT Delhi16 Mar 2023AY 2014-15

Bench: Shri Kul Bharat & Shri O.P. Kantassessment Year: 2014-15

Section 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘C’ NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER Assessment Year: 2014-15 DCIT Vs. HMS Real Estate Pvt. Circle -11 (1) Ltd. 1, AD, Vandhana New Delhi Building, 11, Tolstoy Marg, New Delhi PAN No.AACCH0745G (Appellant) (Respondent) Appellant by Sh. Anuj Garg, Sr. DR Respondent by Ms. Ananya Kapoor, Advocate Date of hearing 16.03.2023 Date of 16.03.2023 pronouncement ORDER PER O.P. KANT, AM: This appeal by the revenue is directed against order dated 28/03/2018 passed by the Learned Commissioner of income-tax (Appea…

DCIT CIR 6(3)(2), MUMBAI vs. KARJAT GOLF CLUB P.LTD, MUMBAI

In the result, the appeal of the Revenue in ITA

ITA 638/MUM/2016[2010-11]Status: DisposedITAT Pune23 Nov 2022AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.638/Mum/2016 िनधा"रण वष" / Assessment Year: 2010-11 Dcit, Circle-6(3)(2), Vs. Karjat Golf Club P. Ltd., Mumbai. Tower, 1502 B One India Bulls Centre, 841 Jupier Mills, Off Senapati Bpat Marg, Lower Parel, Mumbai- 400013 Pan : Aadck0915A Appellant Respondent C.O. No.236/Mum/2017 (Arising Out Of Ita No.638/Mum/2016) िनधा"रण वष" / Assessment Year: 2010-11 Karjat Golf Club P. Ltd., Vs. Dcit, Circle-6(3)(2), Tower, 1502 B One India Mumbai. Bulls Centre, 841 Jupier Mills, Off Senapati Bpat Marg, Lower Parel, Mumbai- 400013 Pan : Aadck0915A Appellant Respondent Revenue By : Shri Keyur Patel Assessee By : Shri Vilesh Dalya Date Of Hearing : 15.11.2022 Date Of Pronouncement : 23.11.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 12, Mumbai

For Appellant: Shri Vilesh DalyaFor Respondent: Shri Keyur Patel
Section 143(3)

…e Hon’ble Supreme Court in the case of CIT vs. Ramaraju Surgical Cotton Mills Ltd, 63 ITR 478 (SC) and CIT vs. Sarabhai Management Corpn. Ltd., 192 ITR 151 (SC) followed by the Hon’ble Gujarat High Court in the case of Sarabhai Management Corpn. Ltd. vs. CIT, 102 ITR 25 (Guj.) and also followed by the Hon’ble Bombay High Court in the case of Western India Vegetable Products Ltd. vs. CTI, 26 ITR 151 (Bom.). In the present case, the ld. CIT(A) simply discussed the legal principles without adverting to the material facts on record and had not really decided the issue whether the assessee had set-up a business or not…

MESSUNG SYSTEMS PRIVATE LIMITED,,PUNE vs. INCOME-TAX OFFICER, WARD - 14 (4),, PUNE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 683/PUN/2018[2014-15]Status: DisposedITAT Pune07 Nov 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.683/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Messung Systems Private Vs. Ito, Ward-14(4), Pune. Limited, 501, Lunkad Skyvista, Sr. No.230/A/3/2, Viman Nagar, Pune- 411014. Pan : Aabcm1832E Appellant Respondent Assessee By : Shri Nikhil Pathak Revenue By : Shri M. G. Jasnani Date Of Hearing : 29.08.2022 Date Of Pronouncement : 07.11.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-7, Pune [‘The Cit(A)’] Dated 15.02.2018 For The Assessment Year 2014-15. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Trading Of Programmable Logic Controllers (Plc) & Parts Thereof. The Return Of Income For The Assessment Year 2014-15 Was Filed On 30.09.2014 Declaring Total

For Appellant: Shri Nikhil PathakFor Respondent: Shri M. G. Jasnani
Section 143(3)

…on’ble Supreme Court in the case of CIT vs. Ramaraju Surgical Cotton Mills Ltd, 63 ITR 478 (SC) and CIT vs. Sarabhai Management Corpn. Ltd., 192 ITR 151 (SC) followed by the Hon’ble Gujarat High Court in the case of Sarabhai Management 5 Corpn. Ltd. vs. CIT, 102 ITR 25 (Guj.) and also followed by the Hon’ble Bombay High Court in the case of Western India Vegetable Products Ltd. vs. CTI, 26 ITR 151 (Bom.). In the present case, the Assessing Officer as well as the ld. CIT(A) simply discussed the legal principle without adverting to the material facts on record and had not really decided whether the appellant compa…

VATIKA HOTELS PVT. LTD.,,NEW DELHI vs. DCIT CIRCLE-17(1), NEW DELHI

In the result, the appeal is partly allowed for statistical

ITA 3987/DEL/2019[2008-09]Status: DisposedITAT Delhi29 Jun 2022AY 2008-09

Bench: Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2008-09

Section 147Section 32

…his contention, learned counsel relied upon the following decisions: 1. CIT vs. Dhoomketu Builders & Developments Pvt. Ltd., 216 Taxman 76 (Del.) 2. Western Vegetable Products Ltd. Vs. CIT, 26 ITR 151 (Bom.) 3. Sarabhai Management Corporation Ltd. Vs. CIT, 102 ITR 25 (Guj.) 4. Saurashtra Cement and Chemicals Ltd. 91 ITR 170 (SC) 5. CIT Vs. L.G. Electronics (I) Ltd. 282 ITR 545 (Del.) 6. CIT Vs. Hughes Escorts Communications Ltd., 311 ITR 253 (Del.) 7. Carefour WC & C India P. Ltd. Vs. Dy. CIT [2014] 368 ITR 692 (Delhi); 8. Omniglobe Information Tech India (P.) Ltd. Vs. CIT [2014] 369 ITR 1 (Delhi); 9. Indian R…

M/S BENGAL SHRIRAM HITECH CITY PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(3), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 122/BANG/2019[2014-15]Status: DisposedITAT Bangalore12 Oct 2020AY 2014-15

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…er the setting up of the business and before the commencement of the business, all expenses during the interregnum would be permissible deductions under section 10(2). . ." (p. 158) 1.11. In Sarabhai Management Corpn. Ltd. v. Commissioner of Income-tax (1976) 102 ITR 25 (Guj), the Gujarat High Court held that as soon as the company acquired immovable property and carried on various activities for procuring necessary facilities, the business was said to commence even though the actual letting of the property took place in the subsequent previous year. This decision has been approved by the Supreme Court as reporte…

M/S BENGAL SHRIRAM HITECH CITY PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 121/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Oct 2020AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…er the setting up of the business and before the commencement of the business, all expenses during the interregnum would be permissible deductions under section 10(2). . ." (p. 158) 1.11. In Sarabhai Management Corpn. Ltd. v. Commissioner of Income-tax (1976) 102 ITR 25 (Guj), the Gujarat High Court held that as soon as the company acquired immovable property and carried on various activities for procuring necessary facilities, the business was said to commence even though the actual letting of the property took place in the subsequent previous year. This decision has been approved by the Supreme Court as reporte…

BENGAL SHRIRAM HITECH CITY PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 1341/BANG/2017[2012-13]Status: DisposedITAT Bangalore12 Oct 2020AY 2012-13

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…er the setting up of the business and before the commencement of the business, all expenses during the interregnum would be permissible deductions under section 10(2). . ." (p. 158) 1.11. In Sarabhai Management Corpn. Ltd. v. Commissioner of Income-tax (1976) 102 ITR 25 (Guj), the Gujarat High Court held that as soon as the company acquired immovable property and carried on various activities for procuring necessary facilities, the business was said to commence even though the actual letting of the property took place in the subsequent previous year. This decision has been approved by the Supreme Court as reporte…

M/S SAMBHAV INSTITUTIONS (INDIA) PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-12(2), BANGALORE

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 1760/BANG/2018[2010-11]Status: DisposedITAT Bangalore31 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 271(1)(c)

…is the operations for establishment of a unit which ultimately culminate in the setting up of the unit. 3.11. Reference can be made and reliance can be placed on the ruling of the Honourable Court in the case of Sarabhai Management Corpn. Ltd. Vs. CIT [1976] 102 ITR 25 (GUJ.) wherein it was noted that the term setting up should not be interpreted loosely, rather held that being in a position to offer services would be sufficient to state that the business of the assessee is setup and it is not necessary to differ the same till the premises is actually let out (which would amount giving loose interpretation). The…

M/S SAMBHAV INSTITUTIONS (INDIA) PRIVATE LIMITED , BANGALORE vs. INCOME TAX OFFICER WARD-12(2), BANGALORE

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 1759/BANG/2018[2009-10]Status: DisposedITAT Bangalore31 Jul 2019AY 2009-10

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 271(1)(c)

…is the operations for establishment of a unit which ultimately culminate in the setting up of the unit. 3.11. Reference can be made and reliance can be placed on the ruling of the Honourable Court in the case of Sarabhai Management Corpn. Ltd. Vs. CIT [1976] 102 ITR 25 (GUJ.) wherein it was noted that the term setting up should not be interpreted loosely, rather held that being in a position to offer services would be sufficient to state that the business of the assessee is setup and it is not necessary to differ the same till the premises is actually let out (which would amount giving loose interpretation). The…

M/S SAMBHAV INSTITUTIONS (INDIA) PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-12(2), BANGALORE

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 1758/BANG/2018[2008-09]Status: DisposedITAT Bangalore31 Jul 2019AY 2008-09

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 271(1)(c)

…is the operations for establishment of a unit which ultimately culminate in the setting up of the unit. 3.11. Reference can be made and reliance can be placed on the ruling of the Honourable Court in the case of Sarabhai Management Corpn. Ltd. Vs. CIT [1976] 102 ITR 25 (GUJ.) wherein it was noted that the term setting up should not be interpreted loosely, rather held that being in a position to offer services would be sufficient to state that the business of the assessee is setup and it is not necessary to differ the same till the premises is actually let out (which would amount giving loose interpretation). The…

DCIT, CIRCLE- 11(1), NEW DELHI vs. HMS REAL ESTATE PVT. LTD., NEW DELHI

Appeal of the Revenue is dismissed

ITA 3289/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Dec 2018AY 2012-13

Bench: Shri R. K. Panda & Ms Suchitra Kambledcit Vs Hms Real Estate Pvt. Ltd. Circle- 11(1) 1 Ad, Vandhana Building , New Delhi 11, Tolstoy Marg, (Appellant) New Delhi Aacch0745G (Respondent)

Section 37(1)

…ll expenses incurred after the setting up of the business and before the commencement of the business, all expenses during the interregnum would be permissible deductions under section 10(2). . . ." 6.11. In the case of Sarabhai Management Corpn. Ltd. [1976] 102 ITR 25 (Guj.), the Hon'ble Gujarat High Court has held that the business commences with the first activity for acquiring by purchase or otherwise immovable property. There may be an interval between the setting up of the business and the commencement of the business. All expenses incurred during that interval are also permissible for deduction. 16 6.12.…

ASST CIT 27(3), NAVI MUMBAI vs. SKY STAR, MUMBAI

In the result, assessee’s appeals are allowed and the Revenue’s appeals are dismissed

ITA 3103/MUM/2015[2010-11]Status: DisposedITAT Mumbai27 Mar 2018AY 2010-11

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10 Assessment Year: 2010-11

For Appellant: Shri Anuj Kisnadwala, A.RFor Respondent: Shri Aarju Garodia, D.R
Section 43B

…ct while computing the income from the business or profession. The assessee also relied on the decision of Hon’ble Supreme Court and Hon’ble Gujarat High Court in the case of Sarabhai Management Corporation Ltd. vs. CIT reported in 192 ITR 151 (SC) and [1976] 102 ITR 25 (Guj). However, the reply of the assessee did not find favour with the AO and he accordingly allowed only the interest and MC taxes in proportion to the area let out thereby disallowing proportionate interest expenditure of Rs.2,04,11,342/- and municipal taxes of Rs.11,60,281/-. 5. In the appellate proceedings, the Ld. CIT(A) dismissed the appeal…

SKYLINE PRASHASTI,MUMBAI vs. ITO 22(2)(3), MUMBAI

In the result, assessee’s appeals are allowed and the Revenue’s appeals are dismissed

ITA 2416/MUM/2015[2010-11]Status: DisposedITAT Mumbai27 Mar 2018AY 2010-11

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10 Assessment Year: 2010-11

For Appellant: Shri Anuj Kisnadwala, A.RFor Respondent: Shri Aarju Garodia, D.R
Section 43B

…ct while computing the income from the business or profession. The assessee also relied on the decision of Hon’ble Supreme Court and Hon’ble Gujarat High Court in the case of Sarabhai Management Corporation Ltd. vs. CIT reported in 192 ITR 151 (SC) and [1976] 102 ITR 25 (Guj). However, the reply of the assessee did not find favour with the AO and he accordingly allowed only the interest and MC taxes in proportion to the area let out thereby disallowing proportionate interest expenditure of Rs.2,04,11,342/- and municipal taxes of Rs.11,60,281/-. 5. In the appellate proceedings, the Ld. CIT(A) dismissed the appeal…

DCIT 22(2), NAVI MUMBAI vs. SKY STAR, MUMBAI

In the result, assessee’s appeals are allowed and the Revenue’s appeals are dismissed

ITA 69/MUM/2013[2009-10]Status: DisposedITAT Mumbai27 Mar 2018AY 2009-10

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10 Assessment Year: 2010-11

For Appellant: Shri Anuj Kisnadwala, A.RFor Respondent: Shri Aarju Garodia, D.R
Section 43B

…ct while computing the income from the business or profession. The assessee also relied on the decision of Hon’ble Supreme Court and Hon’ble Gujarat High Court in the case of Sarabhai Management Corporation Ltd. vs. CIT reported in 192 ITR 151 (SC) and [1976] 102 ITR 25 (Guj). However, the reply of the assessee did not find favour with the AO and he accordingly allowed only the interest and MC taxes in proportion to the area let out thereby disallowing proportionate interest expenditure of Rs.2,04,11,342/- and municipal taxes of Rs.11,60,281/-. 5. In the appellate proceedings, the Ld. CIT(A) dismissed the appeal…

SKY STAR,MUMBAI vs. DCIT 22(2), MUMBAI

In the result, assessee’s appeals are allowed and the Revenue’s appeals are dismissed

ITA 7741/MUM/2012[2009-10]Status: DisposedITAT Mumbai27 Mar 2018AY 2009-10

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10 Assessment Year: 2010-11

For Appellant: Shri Anuj Kisnadwala, A.RFor Respondent: Shri Aarju Garodia, D.R
Section 43B

…ct while computing the income from the business or profession. The assessee also relied on the decision of Hon’ble Supreme Court and Hon’ble Gujarat High Court in the case of Sarabhai Management Corporation Ltd. vs. CIT reported in 192 ITR 151 (SC) and [1976] 102 ITR 25 (Guj). However, the reply of the assessee did not find favour with the AO and he accordingly allowed only the interest and MC taxes in proportion to the area let out thereby disallowing proportionate interest expenditure of Rs.2,04,11,342/- and municipal taxes of Rs.11,60,281/-. 5. In the appellate proceedings, the Ld. CIT(A) dismissed the appeal…

A.C.I.T CIR - 30,KOLKATA, KOLKATA vs. M/S TAPASYA ENTERPRISES, KOLKATA

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 2100/KOL/2013[2009-10]Status: DisposedITAT Kolkata13 Oct 2017AY 2009-10

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 143(3)Section 24

…ivities which go to make up a business need not be started simultaneously in order that business may commence. The business would commence when the activity which is first in point of time and which must necessarily precede all other activities is started. In 102 ITR 25 (Guj) took the same view and held that business commences with the fiat acivity for acquiring by purchase or otherwise, immovable property. There may be an interval between the setting up of the business and the commencement of the business. In CIT v. Sarabhai Management Corporation Ltd., 192 ITR 151 (SC), the decision of the Gujarat High Court wa…

A.C.I.T CIR - 30,KOLKATA, KOLKATA vs. M/S TAPASYA ENTERPRISES, KOLKATA

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 2099/KOL/2013[2006-07]Status: DisposedITAT Kolkata13 Oct 2017AY 2006-07

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 143(3)Section 24

…ivities which go to make up a business need not be started simultaneously in order that business may commence. The business would commence when the activity which is first in point of time and which must necessarily precede all other activities is started. In 102 ITR 25 (Guj) took the same view and held that business commences with the fiat acivity for acquiring by purchase or otherwise, immovable property. There may be an interval between the setting up of the business and the commencement of the business. In CIT v. Sarabhai Management Corporation Ltd., 192 ITR 151 (SC), the decision of the Gujarat High Court wa…

A.C.I.T CIR - 30,KOLKATA, KOLKATA vs. M/S TAPASYA ENTERPRISES, KOLKATA

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 2098/KOL/2013[2005-06]Status: DisposedITAT Kolkata13 Oct 2017AY 2005-06

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 143(3)Section 24

…ivities which go to make up a business need not be started simultaneously in order that business may commence. The business would commence when the activity which is first in point of time and which must necessarily precede all other activities is started. In 102 ITR 25 (Guj) took the same view and held that business commences with the fiat acivity for acquiring by purchase or otherwise, immovable property. There may be an interval between the setting up of the business and the commencement of the business. In CIT v. Sarabhai Management Corporation Ltd., 192 ITR 151 (SC), the decision of the Gujarat High Court wa…

A.C.I.T CIR - 30,KOLKATA, KOLKATA vs. M/S TAPASYA ENTERPRISES, KOLKATA

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 2097/KOL/2013[2004-05]Status: DisposedITAT Kolkata13 Oct 2017AY 2004-05

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 143(3)Section 24

…ivities which go to make up a business need not be started simultaneously in order that business may commence. The business would commence when the activity which is first in point of time and which must necessarily precede all other activities is started. In 102 ITR 25 (Guj) took the same view and held that business commences with the fiat acivity for acquiring by purchase or otherwise, immovable property. There may be an interval between the setting up of the business and the commencement of the business. In CIT v. Sarabhai Management Corporation Ltd., 192 ITR 151 (SC), the decision of the Gujarat High Court wa…

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Sarabhai Management Corporation Ltd. v. CIT (102 ITR 25) — Cited in 31 Judgments | BharatTax