Snam Progetti S.P.A v. Additional Commissioner of Income Tax, New Delhi

132 ITR 70High Court1981#4787 most cited

What is Snam Progetti S.P.A v. Additional Commissioner of Income Tax, New Delhi authority for?

Brought forward business loss can be set off against interest earned from bank deposits in a subsequent year if the interest can be attributed to a business activity, even if assessed under 'income from other sources'. However, interest on parked surplus funds generally qualifies as income from other sources and not business income, particularly in the context of Section 80HHC.

24

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2007 to 2026.

Also referred to as

Snam Progetti S.P.A. v. Additional Commissioner of Income Tax · business loss set off · interest income · bank deposit interest · income from other sources · business activity · Section 80HHC · parked surplus funds

Issues it is cited on

businessinterest

Judgments citing Snam Progetti S.P.A v. Additional Commissioner of Income Tax, New Delhi

Commissioner of Income Tax vs. Jaypee Dsc Ventures Ltd

Accordingly, the same stands dismissed

ITA/357/2010HC Delhi11 Mar 2011

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 143(3)Section 260A

…TA 357/2010 Page 9 of 18 12. In Snam Progetti S.P.A. v. Additional Commissioner of Income-Tax, New Delhi-II and others, [1981] 132 ITR 70 (Delhi), it was held that nexus with the activities cannot be overlooked more so where the income is attributable to or derived from the targeted activity. 13. In Tuticorin Alkali Chemicals and Fertilizers Ltd (supra), a three- judge Bench of the Apex Court was dealing with the issue where the company had surplus funds in its hands and in o…

CIT vs. Delhi Brass & Metal Works Ltd

In the result, the impugned judgment of the Tribunal is set aside

ITA - 653 / 2007HC Delhi21 Nov 2008
For Appellant: Ms Prem Lata BansalFor Respondent: None
Section 143Section 260ASection 80

…e context of section 80 HHC itself, we are unable to accept the contention of the assessees based on Snam Proghetti [1981] 132 ITR 70 (Delhi) that interest earned on parked surplus funds should qualify as business income. Clearly, Snam Proghetti [1981] 132 ITR 70 (Delhi) was not rendered in the context of section 80 HHC and cannot but be confined to the facts of that case. Circular No. 564, dated July 5, 1990 (see [1990] 184 ITR (St.) 137), can also not help in interpreting section 80 HHC which is a “stand alone” provision. We are, therefore, of the view that where surplus funds are parked with the…

Commissioner of Income Tax

In the result, the impugned judgment of the Tribunal is set aside

ITA/653/2007HC Delhi21 Nov 2008
For Appellant: Ms Prem Lata BansalFor Respondent: None
Section 143Section 260ASection 80

…e context of section 80 HHC itself, we are unable to accept the contention of the assessees based on Snam Proghetti [1981] 132 ITR 70 (Delhi) that interest earned on parked surplus funds should qualify as business income. Clearly, Snam Proghetti [1981] 132 ITR 70 (Delhi) was not rendered in the context of section 80 HHC and cannot but be confined to the facts of that case. Circular No. 564, dated July 5, 1990 (see [1990] 184 ITR (St.) 137), can also not help in interpreting section 80 HHC which is a “stand alone” provision. We are, therefore, of the view that where surplus funds are parked with the…

Commissioner of Income Tax-V N vs. Damanjit Singh

ITA/166/2000HC Delhi12 Jan 2007

…IN THE HIGH COURT OF DELHI AT NEW DELHI SUBJECT : INCOME TAX MATTER Date of Reserve : November 29, 2006 Date of decision : January 12, 2007 ITA 166/2000 with ITA.Nos. 29/2004, 39/2004, 56/2004 COMMISSIONER OF INCOME TAX DELHI ..... Appellant Through Ms. Prem Lata Bansal, Sr. Standing Counsel with Mr.Vishnu Sharma, Advocate. versus SHRI RAM HONDA POWER EQUIP ..... Respondent Through Mr. Saubhagya Aggarwal with Mr. A.K. Dash, Advs. ITA 78/2002 COMMR.OF INCOME TAX ..... Appellant…