Steelco Gujarat Ltd. v. ACIT

33 SOT 407Income Tax Appellate Tribunal2018#9219 most cited

What is Steelco Gujarat Ltd. v. ACIT authority for?

The waiver of a loan does not equate to reimbursement for the cost of capital assets, and therefore, Explanation (10) to section 43(1) concerning cost met by others does not apply.

12

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2018 to 2023.

Also referred to as

Steelco Gujarat Ltd. v. ACIT · 33 SOT 407 · section 43(1) · Explanation (10) to section 43(1) · actual cost · waiver of loan · reimbursement of cost of assets · capital assets

Also reported as

92 Taxmann.com 27

Issues it is cited on

section 41(1)(a)waiver of loan section 43(6)(c)section 43(b)section 43(6)section 43(1)section 155 written down value section 41(1)section 41 section 30 profits and gains of business or profession

Judgments citing Steelco Gujarat Ltd. v. ACIT

S T I India Ltd., Indore vs. ACIT-5(1), Indore

Appeals are disposed of as under:

ITA 850/IND/2019[2013-14]Status: DisposedITAT Indore24 Aug 2023AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

ACIT-5(1), Indore vs. S T I India Ltd., Indore

Appeals are disposed of as under:

ITA 784/IND/2019[2013-14]Status: DisposedITAT Indore24 Aug 2023AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

ACIT-5(1), Indore vs. S T I India Ltd., Indore

Appeals are disposed of as under:

ITA 24/IND/2019[2015-16]Status: DisposedITAT Indore24 Aug 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

ACIT-5(1), Indore vs. S T I India Ltd., Indore

Appeals are disposed of as under:

ITA 23/IND/2019[2014-15]Status: DisposedITAT Indore24 Aug 2023AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

ACIT-5(1), Indore vs. S T I India Ltd., Indore

Appeals are disposed of as under:

ITA 22/IND/2019[2012-13]Status: DisposedITAT Indore24 Aug 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

S T I India Ltd., Indore vs. ACIT-5(1), Indore

Appeals are disposed of as under:

ITA 13/IND/2019[2015-16]Status: DisposedITAT Indore24 Aug 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

S T I India Ltd., Indore vs. ACIT-5(1), Indore

Appeals are disposed of as under:

ITA 12/IND/2019[2014-15]Status: DisposedITAT Indore24 Aug 2023AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

S T I India Ltd., Indore vs. ACIT-5(1), Indore

Appeals are disposed of as under:

ITA 11/IND/2019[2012-13]Status: DisposedITAT Indore24 Aug 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

…ant for meeting cost of part of plant & machinery. The learned AR relied upon the judgment of the Hon’ble High Court of Kerala in CIT Vs. Kochin Co. P. Ltd., 184 ITR 230 (Ker.) and also that of the ITAT, Ahmedabad in the case of Steelco Gujarat Ltd. Vs. ACIT, 33 SOT 407. After considering the submissions of the assessee, the CIT(A) held as under:- “5.2 I have considered the submissions and also the judgments as relied upon. Explanation (10) to s. 43(1) provides that “ actual cost means the actual cost of the assets to the assessee, reduced by the portion of the cost thereof, if any, as has been met directly or i…

M/S. Bajaj Foods Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(2), Ahmedabad

Appeal of the assessee is allowed for statistical purposes

ITA 1647/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad25 Feb 2022AY 2009-10

For Appellant: Shri Parimalsigh Parmar, A.RFor Respondent: Shri Dinesh Singh, Sr. D.R

Section 250(6)Section 36Section 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH (Conducted Through Virtual Court) Before: Ms. Annapurna Gupta, Accountant Member And Ms. Suchitra Kamble, Judicial Member Assessment Year 2009-10 M/s. Bajaj Foods Ltd. A- The ITO, Ward-1(2), 401, Samudra Complex, Ahmedabad Nr. Nest Hotel, C.G. road, Vs (Respondent) Ahmedabad PAN No: AAACB6184D (Appellant) Appellant by : Shri Parimalsigh Parmar, A.R. Respondent by : Shri Dinesh Singh, Sr. D.R. Date of hearing : 17-02-2022 Date of pronouncement : 25-02-2022 आदेश/ORDER PER : ANNAPURNA GUPTA, ACCOUNTANT MEMBER:- The present appeal has been filed by…

Gokul Refoils & Solvent Ltd., Ahmedabad vs. The DCIT Inta.Taxa-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 2049/AHD/2018[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2020AY 2016-17

For Appellant: Shri T.P. Hemani, Sr. A.R. &For Respondent: Shri Vinod Tanwani, Sr. D.R

Section 172Section 194CSection 195Section 201Section 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before: Shri Amarjit Singh, Accountant Member And Ms. Madhumita Roy, Judicial Member Assessment Year 2016-17 Gokul Refoils & Solvent The Dy. CIT, Ltd. Gokul House, 43, International Taxation- 205, 2nd Floor Shreemali Co-op Housing Vs Society Ltd. Opp. Shikhar Navjeevan Trust Building, Navrangpura, Building, B/h Gujarat Ahmedabad-9 Vidyapith, Ashram PAN: AAACG8316N Road, Ahmedabad- (Appellant) 380014 (Respondent) Revenue by: Shri Vinod Tanwani, Sr. D.R. Assessee by: Shri T.P. Hemani, Sr. A.R. & Shri Parimal Parmar A.R. Date of hearing : 23-07-2020…

Summit (India) Water Treatment & Services Ltd., Ahmedabad vs. The Pr. CIT-4, Ahmedabad

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

ITA 1338/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad27 May 2019AY 2013-14

For Appellant: Shri Dhinal Shah, A.RFor Respondent: Shri O.P. Sharma, CIT-D.R

Section 115JSection 143(3)Section 263Section 271BSection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “C” BENCH Before: Shri Rajpal Yadav, Judicial Member And Shri Amarjit Singh, Accountant Member Assessment Year 2013-14 Summit India Water The Principal CIT, Treatment & Services Ltd. Circle-4, 305, Kalash-II, Near Jain Vs Ahmedabad Temple, Behind (Respondent) Navrangpura Post Office, Navrangpura, Ahmedabad-380009, Gujarat, India PAN: AAECS6689L (Appellant) Assessee by: Shri Dhinal Shah, A.R. Revenue by: Shri O.P. Sharma, CIT-D.R. Date of hearing : 13-05-2019 Date of pronouncement : 27-05-2019 आदेश/ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBER:- The assessee…

Gmr Tambaram Tindivanam Expressways Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result that the revenue appeals are dismissed

ITA 545/BANG/2018[2013-14]Status: DisposedITAT Bangalore26 Nov 2018AY 2013-14

Bench: Shri. Jason P. Boaz

For Appellant: Shri. Sunil Jain, CAFor Respondent: Dr. P. V. Pradeep Kumar, Addl. CIT

…e for deduction u/s. 80-IA as held in the following decisions: Chennai ITAT in the case of ACIT v Indwell Lianings Pvt. Ltd. (i) Appeal No. : ITA Nos. 1631 & 1632 (Mds.)/2007. Delhi ITAT in the case of Shristi Infrastructure Development (ii) Corporation Ltd. (33 SOT 407).. Hyderabad ITAT in the case of M/s. Koya And Company (iii) Construction Ltd vs, ITO in ITA No 417/Hydi/2013 for AY 2008-09 and ITA Nio.418/Hyd/2013 for AY 2009-10 Mumbai ITAT in the case of Smc Infrastructure P. Ltd, Thane (iv) vs ACIT in ITA No 678 & 679/Mum/2010 for AY 2006-07 Biotech Medicals (P) Ltd., 121 'TTJ 858 (v) B.T.Patil & Sons Belgau…