Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association

3 SCC 1Reported decision1992#303 most cited

What is Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association authority for?

If an issue has been decided by a competent court or bench, and that decision remains undisturbed by a higher court, subsequent appeals on the same issue can be dismissed as being covered by the earlier judgment, underscoring judicial discipline.

266

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2003 to 2026.

Also referred to as

Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association · 3 SCC 1 · 1992 · dismissal of appeal · covered by previous judgment · judicial discipline · finality of orders · precedential value of judgments · Section 261 · effect of SLP dismissal · Kunhayammed

Sections most often in play

Section 143(3)Section 144C(13)Section 153(1)Section 153(4)Section 144BSection 153Section 158ABSection 144C

Issues it is cited on

section 158absection 261section 144cofsection 22(1)stay of demandsection 11(3)section 153(4)section 140section 144c(4)section 9(1)(ii)reference to tposection 153(1)

Judgments citing Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Iron and Steel Ltd

Accordingly, the same are dismissed along with pending applications

ITA/361/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…ITA Nos.358-368/2022 Page 1 of 13 $~43 & 45 to 53 * IN THE HIGH COURT OF DELHI AT NEW DELHI 43 + ITA 358/2022 & CM APPL. 42277/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. versus M/S JPM TOOLS LTD. ..... Respondent Through: Mr. Salil Aggarwal, Sr. Advocate with Mr. Madhur Aggarwal & Mr. Mahir Aggarwal, Advocates. 45 + ITA 360/2022 & CM APPL. 42279/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. v…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Iron and Steel Ltd

Accordingly, the same are dismissed along with pending applications

ITA/364/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…ITA Nos.358-368/2022 Page 1 of 13 $~43 & 45 to 53 * IN THE HIGH COURT OF DELHI AT NEW DELHI 43 + ITA 358/2022 & CM APPL. 42277/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. versus M/S JPM TOOLS LTD. ..... Respondent Through: Mr. Salil Aggarwal, Sr. Advocate with Mr. Madhur Aggarwal & Mr. Mahir Aggarwal, Advocates. 45 + ITA 360/2022 & CM APPL. 42279/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. v…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jpm Tools Ltd

Accordingly, the same are dismissed along with pending applications

ITA/358/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…ITA Nos.358-368/2022 Page 1 of 13 $~43 & 45 to 53 * IN THE HIGH COURT OF DELHI AT NEW DELHI 43 + ITA 358/2022 & CM APPL. 42277/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. versus M/S JPM TOOLS LTD. ..... Respondent Through: Mr. Salil Aggarwal, Sr. Advocate with Mr. Madhur Aggarwal & Mr. Mahir Aggarwal, Advocates. 45 + ITA 360/2022 & CM APPL. 42279/2022 PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 ..... Appellant Through: Mr. Sanjay Kumar, Sr. Standing Counsel for Revenue with Ms. Easha Kadian, Advocate. v…

Pr. Commissioner of Income Tax (Central)-2 vs. G.R. Goenka Education Society

ITA/350/2022HC Delhi22 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

Section 11Section 13(1)(c)Section 13(3)Section 40(2)

…ll date. 7. Consequently, in view of the judgments of the Supreme Court in Kunhayammed and Others Vs. State of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is covered by the judgment passed by the learned predecessor Division Bench. 8. Accordingly, no substantial question of law arises for consideration in the present appeal and the same is dismissed. 9. However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the…

Commissioner of Income Tax (International Taxation)-2 vs. M/S. Nagravision S.A

ITA/348/2022HC Delhi21 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

Section 9

…te of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003800 ITA No.348/2022 Page 3 of 3 Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is covered by the judgment of the Supreme Court in Engineering Analysis (supra). 7. Accordingly, no substantial question of law arises for consideration in the present appeal and the same is dismissed. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J SEPTEMBER 21, 2022 KA This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DH…

Commissioner of Income Tax (International Taxation)-2 vs. Intelsat Corporation

ITA/347/2022HC Delhi21 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

Section 9Section 9(1)(vi)

…ll date. 6. Consequently, in view of the judgments of the Supreme Court in Kunhayammed and Others Vs. State of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the issues raised in the present appeals are covered by the judgment passed by the learned predecessor Division Bench. 7. Accordingly, no substantial question of law arises for consideration in the present appeals and the same are dismissed. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J SEPTEMBER 21, 2022 KA This is a digitally signed Judgement. NEUTRAL…

Commissioner of Income Tax (International Taxation)-2 vs. Intelsat Corporation

ITA/346/2022HC Delhi21 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

Section 9Section 9(1)(vi)

…ll date. 6. Consequently, in view of the judgments of the Supreme Court in Kunhayammed and Others Vs. State of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the issues raised in the present appeals are covered by the judgment passed by the learned predecessor Division Bench. 7. Accordingly, no substantial question of law arises for consideration in the present appeals and the same are dismissed. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J SEPTEMBER 21, 2022 KA This is a digitally signed Judgement. NEUTRAL…

Assistant Commissioner of Income Tax, Central Circle-3(1), Chennai vs. M/S. Bgr Energy Systems, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 29/CHNY/2021[2016-17]Status: DisposedITAT Chennai21 Sept 2022AY 2016-17

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.28 & 29/Chny/2021 िनधा"रण वष"/Assessment Years: 2014-15 & 2016-17 The Assistant Commissioner Of Vs. M/S. Bgr Energy Systems Limited, Income Tax, Corporate Office, Guna Complex, Central Circle 3(1), 433, Anna Salai, Teynampet, Chennai. Chennai 600 018. [Pan:Aabcg2202J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Johanson, Addl. Cit : ""थ" की ओर से/Respondent By Mrs. Sandhyaarti, T., Fca : सुनवाई की तारीख/ Date Of Hearing 13.09.2022 : घोषणा की तारीख /Date Of Pronouncement : 21.09.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 14.09.2020 Relevant To The Assessment Years 2014-15 & 2016-17. 2. Both The Appeals Filed By The Assessee Are Delayed By 55 Days In Filing The Appeal Before The Tribunal Due To Outbreak Of Covid-19

Section 115JSection 143(3)Section 14ASection 3

…ate. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in PCIT vs. IL & FS Energy Development Company Ltd (supra) and Cheminvest Limited vs. Commissioner of Income Tax-VI, (2015) 378 ITR 33. 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passe…

Assistant Commissioner of Income Tax, Central Circle-3(1), Chennai vs. M/S. Bgr Energy Systems, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 28/CHNY/2021[2014-15]Status: DisposedITAT Chennai21 Sept 2022AY 2014-15

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.28 & 29/Chny/2021 िनधा"रण वष"/Assessment Years: 2014-15 & 2016-17 The Assistant Commissioner Of Vs. M/S. Bgr Energy Systems Limited, Income Tax, Corporate Office, Guna Complex, Central Circle 3(1), 433, Anna Salai, Teynampet, Chennai. Chennai 600 018. [Pan:Aabcg2202J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Johanson, Addl. Cit : ""थ" की ओर से/Respondent By Mrs. Sandhyaarti, T., Fca : सुनवाई की तारीख/ Date Of Hearing 13.09.2022 : घोषणा की तारीख /Date Of Pronouncement : 21.09.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 14.09.2020 Relevant To The Assessment Years 2014-15 & 2016-17. 2. Both The Appeals Filed By The Assessee Are Delayed By 55 Days In Filing The Appeal Before The Tribunal Due To Outbreak Of Covid-19

Section 115JSection 143(3)Section 14ASection 3

…ate. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in PCIT vs. IL & FS Energy Development Company Ltd (supra) and Cheminvest Limited vs. Commissioner of Income Tax-VI, (2015) 378 ITR 33. 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passe…

Commissioner of Income Tax (International Taxation)-2 vs. Intelsat Corporation

ITA - 347 / 2022HC Delhi21 Sept 2022
Section 9Section 9(1)(vi)

…ll date. 6. Consequently, in view of the judgments of the Supreme Court in Kunhayammed and Others Vs. State of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the issues raised in the present appeals are covered by the judgment passed by the learned predecessor Division Bench. 7. Accordingly, no substantial question of law arises for consideration in the present appeals and the same are dismissed. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J SEPTEMBER 21, 2022 KA 2022:DHC:3803-DB…

Commissioner of Income Tax (International Taxation)-2 vs. M/S. Nagravision S.A

ITA - 348 / 2022HC Delhi21 Sept 2022
Section 9

…nts of the Supreme Court in Kunhayammed and Others Vs. State of Kerala And Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India 2022:DHC:3800-DB ITA No.348/2022 Page 3 of 3 Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is covered by the judgment of the Supreme Court in Engineering Analysis (supra). 7. Accordingly, no substantial question of law arises for consideration in the present appeal and the same is dismissed. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J SEPTEMBER 21, 2022 KA 2022:DHC:3800-DB…

Royal Orchid Hotels Ltd, Bengaluru vs. Assisstant Commissioner of Income Tax, Circle-5(1)(1), Bengaluru

In the result, this ground is allowed

ITA 793/BANG/2018[2011-12]Status: DisposedITAT Bangalore20 Sept 2022AY 2011-12

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2011-12

For Appellant: Shri R.B Krishna, AdvocateFor Respondent: Shri Sankar Ganesh, JCIT (DR)
Section 14ASection 194HSection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K. JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment year : 2011-12 Royal Orchid Hotels Ltd., Vs. The Asst. Commissioner of Income No.1, Golf Avenue, Adjoining KGA Tax, Golf Course, Kodihalli, Circle-5(1)(1), Old Airport Road, Bengaluru. Bangalore-560 008. PAN – AABCR 0111 M APPELLANT RESPONDENT Assessment year : 2011-12 The Asst. Commissioner of Income Vs. Royal Orchid Hotels Ltd., Tax, No.1, Golf Avenue, Adjoining KGA Circle-5(1)(1), Golf Course, Kodihalli, Old Airport Road, Bengaluru. Bangalore-560…

M/S. Ukn Properties Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 1739/BANG/2019[2013-14]Status: DisposedITAT Bangalore16 Sept 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 14ASection 56(2)(vii)

…is no stay of the said judgment till date. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed v. State of Kerala (2000] 113 Taxman 470/245 ITR 360 and Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association [1992] 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in IL & FS Energy Development Co. Ltd. (supra) and Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi). 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passed…

Principal Commissioner of Income Tax-4 Delhi vs. Haier Appliances India Pvt Ltd

ITA/331/2022HC Delhi14 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…. 7. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the appeal being ITA No.331/2022 challenging the ITAT Order in ITA 1594/Del./2016 is dismissed being covered by the judgment passed by the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003670 ITA Nos.330-331/2022 Page 3 of 3 learned predecessor Division Bench in Sony Ericsson Mobile Communication (supra). It is clarified that…

Principal Commissioner of Income Tax-4, Delhi vs. Haier Appliances India Pvt Ltd

ITA/330/2022HC Delhi14 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…. 7. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the appeal being ITA No.331/2022 challenging the ITAT Order in ITA 1594/Del./2016 is dismissed being covered by the judgment passed by the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003670 ITA Nos.330-331/2022 Page 3 of 3 learned predecessor Division Bench in Sony Ericsson Mobile Communication (supra). It is clarified that…

Toyota Tsusho India Private Limited, Ramanagara vs. The Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 175/BANG/2022[2017-18]Status: DisposedITAT Bangalore09 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 14A

…is no stay of the said judgment till date. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed v. State of Kerala (2000] 113 Taxman 470/245 ITR 360 and Shree Chamundi Mopeds Ltd. v. Church of South India Trust Association [1992] 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in IL & FS Energy Development Co. Ltd. (supra) and Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi). 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passed…

Pr. Commissioner of Income Tax -7 vs. Rayban Sun Optics India Ltd

Appeal is dismissed being covered by the judgments passed by the learned predecessor

ITA/291/2022HC Delhi31 Aug 2022

Bench: The Supreme Court. This Is A Digitally Signed Judgement. Neutral Citation No: 2022/Dhc/003391

…te. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras, (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgments passed by the learned predecessor Division Bench in Sony Ericsson (supra) & Bausch & Lomb Eyecare India P. Ltd. (supra). 7. However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the SLP filed in the case of Sony Eri…

Pr. Commissioner of Income Tax -7 vs. Sharp Business Systems (India) Pvt. Ltd

Appeal is dismissed being covered by the judgments passed by the learned predecessor

ITA-292/2022HC Delhi31 Aug 2022

…te. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras, (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgments passed by the learned predecessor Division Bench in Sony Ericsson (supra) & Bausch & Lomb Eyecare India P. Ltd. (supra). However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the SLP filed in the case of Sony Ericss…

Pr. Commissioner of Income Tax -7 vs. Rayban Sun Optics India Ltd

Appeal is dismissed being covered by the judgments passed by the learned predecessor

ITA-291/2022HC Delhi31 Aug 2022

Bench: The Supreme Court. 2022:Dhc:3391-Db

…te. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras, (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgments passed by the learned predecessor Division Bench in Sony Ericsson (supra) & Bausch & Lomb Eyecare India P. Ltd. (supra). 7. However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the SLP filed in the case of Sony Eri…

DCIT, Circle-10(1), New Delhi vs. Genesis Color Pvt. Ltd., Gurgaon

In the result, the appeal filed by the Revenue Department

ITA 6366/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Aug 2022AY 2016-17

Bench: Shri Shamim Yahya & Shri N.K. Choudhryassessment Year: 2016-17

For Appellant: Ms.SangeetaYadav, Ld. Sr.DRFor Respondent: Ms.Supriya Mehta, Ld. CA
Section 143(3)Section 14ASection 250

…ate. Consequently, in view of the judgments passed by the Supreme Court in Kunhayammed and Others vs. State of Kerala and Another, (2000) 6 SCC 359 and Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras (1992) 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in PCIT vs. IL & FS Energy Development Company Ltd (supra) and Cheminvest Limited vs. Commissioner of Income Tax-VI, (2015) 378ITR 33.(highlighted by us) 10. Accordingly, the appeal and application are dismissed. However, it is clarified t…