Sons Exports (P.) Ltd. v. ITO’, Delhi

102 ITD 311Income Tax Appellate Tribunal#21841 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2017 to 2019.

Judgments citing Sons Exports (P.) Ltd. v. ITO’, Delhi

Shri Shravan Choudhary, Jaipur vs. Assistant Commissioner of Income Tax, Circle-5, Jaipur

In the result, appeal of the assessee is allowed

ITA 517/JPR/2019[2010-11]Status: DisposedITAT Jaipur07 Aug 2019AY 2010-11

Bench: The Date Of Hearing.”

For Appellant: Shri Siddharth Ranka &For Respondent: Shri B.K. Gupta (CIT)
Section 143(3)Section 147Section 148Section 2(22)(e)

…accumulated profits for the purpose of section 2(22)(e), the ld. D/R has submitted that the current year’s profit has to be taken into account. He has relied upon the decision of Mumbai Benches of the Tribunal in case of NCK Sons Exports Pvt. Ltd. vs. ITO, 102 ITD 311 and submitted that the Tribunal after analyzing the history of the provisions right from the Income Tax Act, 1922 and subsequent amendments has held that the accumulated profits has to be worked out on the date of transaction of disbursement which included the current year’s profit. The ld. D/R has also relied upon the decision of Hon’ble Supr…

ACIT Circle-2(1), Gwalior vs. Royal Automobiles P Ltd, Gwalior

In the result, both the appeals of the revenue are dismissed

ITA 122/AGR/2017[2012-13]Status: DisposedITAT Agra07 Dec 2017AY 2012-13

Bench: The Ao.

Section 2(22)(e)

…ya Financial Services Pvt. Ltd. (SESPL).He applied section 2(22)(e) mainly on the ground that there exist common shareholding between the lending and the receiving companies, relying on the order of ITAT, Delhi in the case of NCK Exports Pvt. Ltd, reported as 102 ITD 311. The assessee explained before the AO that it was neither a registered nor a beneficial shareholder in its group concerns. Therefore, the provisions of section 2(22)(e) are not applicable. The AO was not satisfied with the reply of the assessee and the cases of ‘CIT vs. Ankitech Pvt. Ltd and ITA 121 & 122/Agra/2017 4 others’, reported in 340 ITR…

ACIT Circle-2(1), Gwalior vs. Royal Automobiles P Ltd, Gwalior

In the result, both the appeals of the revenue are dismissed

ITA 121/AGR/2017[2011-12]Status: DisposedITAT Agra07 Dec 2017AY 2011-12

Bench: The Ao.

Section 2(22)(e)

…ya Financial Services Pvt. Ltd. (SESPL).He applied section 2(22)(e) mainly on the ground that there exist common shareholding between the lending and the receiving companies, relying on the order of ITAT, Delhi in the case of NCK Exports Pvt. Ltd, reported as 102 ITD 311. The assessee explained before the AO that it was neither a registered nor a beneficial shareholder in its group concerns. Therefore, the provisions of section 2(22)(e) are not applicable. The AO was not satisfied with the reply of the assessee and the cases of ‘CIT vs. Ankitech Pvt. Ltd and ITA 121 & 122/Agra/2017 4 others’, reported in 340 ITR…

Sons Exports (P.) Ltd. v. ITO’, Delhi (102 ITD 311) — Cited in 3 Judgments | BharatTax