Snow While Food Products 10 Taxman.com 37, CIT v. Neon Solutions Pvt. Ltd.

387 ITR 667High Court2016#12727 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2018 to 2026.

Sections most often in play

Section 143(3)Section 14A Section 37(1)Section 80IA(4)Section 92CA Section 147

Issues it is cited on

mercantile system of accounting section 145 section 14a section 142 reassessment proceedings previous year section 142(1)section 143 section 147 prescribed company section 14

Judgments citing Snow While Food Products 10 Taxman.com 37, CIT v. Neon Solutions Pvt. Ltd.

Maharashtra State Electricity Transmission Company Limited, Mumbai vs. ITO Circle 14(1)(1), Mumbai

ITA 2552/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose

Section 143(3)Section 14A

…missible for assessee to change the method of accounting. 6. On the facts and circumstances of the case and law, the Learned CIT(A) erred in not considering the Calcutta High Court in Snow While Food Products 10 Taxman.com 37, CIT vs. Neon Solutions Pvt. Ltd. 387 ITR 667 of Bombay High Court, CIT vs. Motor Credit Co., CIT vs. Kewal Chand Bagri – Calcutta High Court 1990-53 Taxman536 to the similar effect. 7. On the facts and circumstances of the case and law, the CIT(A) erred in not properly applying the law laid by the Apex Court in CIT vs. Godhra Electricity Co. 225 ITR 746 SC and Andhra Bank case as reported i…

JCIT(OSD)-14(1)(1), Mumbai vs. Maharashtra State Electricity Transmission Co. Ltd., Mumbai

ITA 2093/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose

Section 143(3)Section 14A

Bangalore Beverages Limited, Bangalore vs. Assistant Commissioner of Income Tax (OSD) Ward-1(1)(3), Bangalore

In the result, the appeal filed by the assessee in ITA

ITA 294/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri K.R. Pradeep, A.R. &For Respondent: Ms. Neera Malhotra, D.R

…being met by the assessee, the arbitrary and high pitched addition made by the AO requires to be deleted. The explanation offered by the assessee is supported by the decisions of various courts mentioned hereunder: 1) CIT vs Neon Solutions Pvt Ltd – Bom HC – 387 ITR 667 (Annexure 3) ‘’ Taxability—Notional Interest on debentures—Mercantile system of accounting— Assessee in 2003 subscribed to 2% nonconvertible unsecured debentures of Rs.42 crores issued by one of its group companies ’M’— ‘M’ in response to demand for interest from Assessee requested waiver of interest on debentures as it were facing financial diff…

M/S Bangalore Beverages Pvt Limited, Bangalore vs. The Income Tax Officer Ard-1(1)(1), Bangalore

In the result, the appeal filed by the assessee in ITA

ITA 438/BANG/2018[2013-14]Status: DisposedITAT Bangalore25 May 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri K.R. Pradeep, A.R. &For Respondent: Ms. Neera Malhotra, D.R

Income Tax Officer-3(2)(4), Mumbai vs. M/S. Patodia Systex Limited, Mumbai

ITA 5641/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Jul 2022AY 2010-11

For Appellant: Shri S.L. JainFor Respondent: Shri B.K. Bagchi

Section 143(3)Section 147Section 148

…e Ld.CIT(A) was right in deleting the disallowances of Rs. 29,87,028/- made on account of accrued interest on loan advanced to M/s. Shree Janardhan Mills Ltd. by placing reliance on the decision of Hon'ble Bombay High Court in the case of Neo Solution Pvt Ltd 387 ITR 667 without appreciating that the said decision rendered on different sets of fact and cannot be applied squarely in this case 5. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was right in deleting the disallowances of Rs. 29,87,028/- made on account of accrued interest on loan advanced to M/s. Shree Janardhan…

DCIT Circle 3(3)(2), Mumbai vs. M/S Ravi Dyeware Company P Ltd., Mumbai

In the result, the appeal filed by Revenue is dismissed

ITA 802/MUM/2020[2014-15]Status: DisposedITAT Mumbai01 Jun 2022AY 2014-15

Bench: Shri M. Balaganesh () & Shri Pavan Kumar Gadale () Assessment Year: 2014-15

For Appellant: Mr. Prateek Jain, ARFor Respondent: Mr. Prabhat Kumar Gupta, DR

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 35(1)

…arties? iii. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) was right in deleting the addition of Rs.1,92,96,068/- by placing reliance on the decision of the Hon'ble Bombay High Court in the case of M/s. Neo Solution Pot. Lid. (387 ITR 667) without appreciating that the facts and the circumstances of the case of the assessce different from the fact of the case of M/s. Neo Solution Pot. Ltd.? 3 M/s Ravi Dyeware Company P. Ltd 2. The brief facts of the case are that, the assessee company is engaged in the business of manufacturing, trading and export of dyes & dyes intermediate & ot…

Red Fort Shahjahan Properties Pvt. Ltd., New Delhi vs. DCIT, Circle-21(1), New Delhi

The appeal is allowed with above direction

ITA 7239/DEL/2018[2014-15]Status: DisposedITAT Delhi14 Jun 2019AY 2014-15

Bench: Shri Kuldip Singh & Shri Prashant Maharishired Fort Shahjahan Properties Vs. Dcit, Pvt. Ltd, Circle-21(1), N-226, Lgf, Greater Kailash-1, New Delhi New Delhi Pan: Aadcr6247E (Appellant) (Respondent)

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri H. K. Choudhary, CIT DR

Section 143Section 144Section 144CSection 92C(3)Section 92D

…has made addition to the total income of the assessee holding that the interest income on the above advances accrued to the assessee but it has not been accounted for. An issue arose before Honourable Bombay High court in case of CIT V Neoan Solutions Pvt Ltd 387 ITR 667 where on the facts that the assessee subscribed to 2 per cent. non-convertible unsecured debentures issued by one of its group companies in 2003. As the company, which issued the debentures, was in financial difficulties waiver of interest on the debentures until March 31, 2010 was approved at a meeting of the debenture holders in 2004. A resolut…

Ferari Investments & Trading Co.P.Ltd, Mumbai vs. ITO 5(1)(4), Mumbai

In the result, the appeal of the assessee is party allowed

ITA 357/MUM/2017[2012-13]Status: DisposedITAT Mumbai29 Jun 2018AY 2012-13

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri Sanjay R Parikh, ARFor Respondent: Shri Rajesh Kumar Yadav, DR

Section 143(3)Section 14A

…. Even now before us, the assessee could not substantiate that NMW was facing financial hardship. 10 12. Before us, the learned counsel for the assessee relied on the decision of Hon’ble Bombay High court in the case of CIT vs. Neon solutions Pvt. Ltd (2016) 387 ITR 667 (Bom), but we find that in the case before Hon’ble Bombay High court the board resolution for waiver of interest on debentures was passed on 31-05-2004 and approved by board for waiver of interest for 6 years and including AY 2007-08 and 2009-10. But in the present case before us, the reduction was done after almost 2 years i.e. on 31-07-2012 for…