Small Industries Development Bank of India v. CBDT

440 ITR 80Reported decision#25746 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 115-OSection 237Section 10(44)Section 115BBDSection 9Section 115JBSection 143(2)Section 3

Issues it is cited on

section 237ddtdomestic companydividend distribution taxnon-residentsection 23section 115section 11prescribedcompanyindiatotal income

Judgments citing Small Industries Development Bank of India v. CBDT

POLYCAB INDIA LIMITED,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 5(2), MUMBAI

In the result, all the appeals of the assessee are allowed

ITA 4673/MUM/2023[2018-19]Status: DisposedITAT Mumbai16 Jun 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115Section 237Section 9

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.4672/Mum/2023 (Assessment Year :2019-20) & Polycab India Limited Vs. The Assistant Commissioner 29, The Ruby, 21st Floor of Income Tax, Circle 5(2) Senapati Bapat Marg Mumbai Tulsi Pipe Road Dadar West Maharashtra- 400 028 PAN/GIR No.AAACP6474E (Appellant) .. (Respondent) Assessee by Shri Rajan Vora & Shri Pranay Gandhi and Shri Lekh Mehta Revenue by Shri Krishna Kumar, Sr. DR Date of Hearing 12/06/2025 Date of Pronouncement 16/06/2025 आदेश / O R D E R PER AMIT SHUKLA…

POLYCAB INDIA LIMITED,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 5(2), MUMBAI

In the result, all the appeals of the assessee are allowed

ITA 4671/MUM/2023[2020-21]Status: DisposedITAT Mumbai16 Jun 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115Section 237Section 9

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.4672/Mum/2023 (Assessment Year :2019-20) & Polycab India Limited Vs. The Assistant Commissioner 29, The Ruby, 21st Floor of Income Tax, Circle 5(2) Senapati Bapat Marg Mumbai Tulsi Pipe Road Dadar West Maharashtra- 400 028 PAN/GIR No.AAACP6474E (Appellant) .. (Respondent) Assessee by Shri Rajan Vora & Shri Pranay Gandhi and Shri Lekh Mehta Revenue by Shri Krishna Kumar, Sr. DR Date of Hearing 12/06/2025 Date of Pronouncement 16/06/2025 आदेश / O R D E R PER AMIT SHUKLA…

KNIGHT RIDERS SPORTS PRIVATE LIMITED,MUMBAI vs. ACIT CENTRAL CIRCLE-4(2), MUMBAI

In the result, the appeal of the assessee is dismissed

ITA 5967/MUM/2024[2018-19]Status: DisposedITAT Mumbai04 Feb 2025AY 2018-19

Bench: Shri Amarjit Singh & Shri Anikesh Banerjeeassessment Year 2018-19

For Appellant: Shri Hiten ThakkarFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 115Section 115JSection 143(2)Section 237Section 4

…ofits of the company and not a charge in the hands of the shareholder or tax paid on behalf of the shareholder by the domestic company. The Bench relied on the Hon'ble Bombay High Court ruling in the case of Small Industries Development Bank of India vs CBDT, 440 ITR 80, that charge under section 115-0 of the Act is on the company's profits and not income in the hands of the shareholder. The Hon'ble Special Bench ruled that DDT is paid by the domestic company which is resident in India, and it is a tax on the income of the company and not tax paid on behalf of the shareholder, who is the recipient. Given this jud…