Taparia Tools Ltd. v. JCIT

372 ITR 605Supreme Court of India2015#225 most cited

What is Taparia Tools Ltd. v. JCIT authority for?

An expenditure does not automatically become capital in nature merely because it results in some enduring benefit for the assessee; it can be treated as revenue expenditure if incurred for genuine business purposes.

330

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

Taparia Tools Ltd. v. JCIT · 372 ITR 605 · SC · 2015 · section 37(1) · revenue expenditure · capital expenditure · enduring benefit test · deferred revenue expenditure · expenditure disallowance · business expenditure · allowability of expenditure

Also reported as

55 Taxmann.com 361276 CTR 1231 Taxmann 5

Sections most often in play

Section 143(3)Section 37(1)Section 40(a)(ia)Section 263Section 271(1)(c)Section 148Section 14ASection 115JB

Issues it is cited on

section 50(1)section 80absection 54esection 80msection 10(33)section 10(15)section 14a(1)section 54eclong-term capital assetsection 36(1)(viii)mat creditdisallowance of interest expenditure

Judgments citing Taparia Tools Ltd. v. JCIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI JAGADISH (ACCOUNTANT MEMBER) I.T.A. No. 3680/Mum/2017 Assessment Year: 2010-11 State Bank of India Vs. The Assistant Commissioner of Financial Reporting & Taxation Income-tax, Circle-2(2)(1), Dept. Mumbai 3rd Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai - 400021 [PAN: AAACS8577K] (Appellant) (Respondent) I.T.A. No. 3882/Mum/2017 Assessment Year: 2010-11 The Assistant Commissioner Vs. State Bank of India of Income-tax, Circle-2(2)(1), Financial Reporting & Taxation Mumbai Dept. 3rd Floor, Corpor…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI JAGADISH (ACCOUNTANT MEMBER) I.T.A. No. 3680/Mum/2017 Assessment Year: 2010-11 State Bank of India Vs. The Assistant Commissioner of Financial Reporting & Taxation Income-tax, Circle-2(2)(1), Dept. Mumbai 3rd Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai - 400021 [PAN: AAACS8577K] (Appellant) (Respondent) I.T.A. No. 3882/Mum/2017 Assessment Year: 2010-11 The Assistant Commissioner Vs. State Bank of India of Income-tax, Circle-2(2)(1), Financial Reporting & Taxation Mumbai Dept. 3rd Floor, Corpor…

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER Reliance Retail Limited ACIT Circle- 3rd Floor, Court House, 8(1)(1), Lokmanya Tilak Marg, Vs. Room No. 670, 6th Dhobi Talao, Mumbai- floor, Aayakar 400 002 Bhavan, Maharshi Karve Road, Mumbai-400 020 PAN/GIR No. AABCR1718E (Applicant) (Respondent) & ACIT Circle-8(1)(1), Reliance Retail Room No. 670, 6th Limited floor, Aayakar Vs. 3rd Floor, Court House, Bhavan, Maharshi Lokmanya Tilak Marg, Karve Road, Dhobi Talao, Mumbai- Mumbai-400 020 400 002 (Applicant) (Respond…

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL "D" BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 3510/Mum/2025 (Assessment Year: 2019-20) Reliance Retail Limited 3rd Floor, Court House, Lokmanya Tilak Marg, Dhobi Talao, Mumbai- 400 002 ACIT Circle- 8(1)(1), Vs. Room No. 670, 6th floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400 020 PAN/GIR No. AABCR1718E (Applicant) (Respondent) & ITA No. 4244/Mum/2025 (Assessment Year: 2019-20) ACIT Circle-8(1)(1), Room No. 670, 6th floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400 020 (Applicant) Reliance Reta…

ACIT, NEW DELHI vs. M/S. THHYSSENKRUPP ELEVATOR (INDIA) PVT. LTD.,, DELHI

In the result, appeal of the Assessee in ITA 3015/Del/2017 is

ITA 3658/DEL/2017[2011-12]Status: DisposedITAT Delhi11 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltk Elevator Private Limited Vs Deputy Commissioner Of (Earlier Known As Income Tax, Circle- 25(1), Thyssenkrupp Elevator C. R. Building, New Delhi (India) Pvt. Ltd.) Plot No. 429, Functional Industrial Estate, Patparganj, Delhi Pan: Aabct6921F Appellant Respondent Assistant Commissioner Of Vs Tk Elevator Private Limited Income Tax, Circle- 25(1), (Earlier Known As Room No. 192A C. R. Thyssenkrupp Elevator Building, New Delhi (India) Pvt. Ltd.) Plot No. 429, Functional Industrial Estate, Patparganj, Delhi Pan: Aabct6921F Appellant Respondent Assessee By Ms. Shashi M. Kapila, Adv& Sh. Sushil Kumar, Adv Revenue By Sh. S. K. Jadhav, Cit (Dr) Date Of Hearing 08/01/2026 Date Of Pronouncement 11/02/2026

Section 143(3)Section 144Section 144C(3)Section 234ASection 92C

…of the Tribunal have been affirmed by the Jurisdictional High Court, wherein accepted the accounting treatment given by the Assessee to ‘advance received from customers’ by relying on the principal determined in the case of Taparia Tools Ltd. (SC) (2015) 55 Taxmann.com 361. Thus, sought for dismissal of the Appeal of the Revenue. 14. We have heard both the parties and perused the material available on record. The issue involved in the Revenue’s Appeal has been decided in Assessee’s own case for Assessment Year 2005-06 to 2007-08 in ITA No. 1214/2018, ITA No. 1233/2018 and ITA No. 1269/2018 by the Hon'ble H…

THYSSENKRUPP ELEVATOR (INDIA) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee in ITA 3015/Del/2017 is

ITA 3015/DEL/2017[2011-12]Status: DisposedITAT Delhi11 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltk Elevator Private Limited Vs Deputy Commissioner Of (Earlier Known As Income Tax, Circle- 25(1), Thyssenkrupp Elevator C. R. Building, New Delhi (India) Pvt. Ltd.) Plot No. 429, Functional Industrial Estate, Patparganj, Delhi Pan: Aabct6921F Appellant Respondent Assistant Commissioner Of Vs Tk Elevator Private Limited Income Tax, Circle- 25(1), (Earlier Known As Room No. 192A C. R. Thyssenkrupp Elevator Building, New Delhi (India) Pvt. Ltd.) Plot No. 429, Functional Industrial Estate, Patparganj, Delhi Pan: Aabct6921F Appellant Respondent Assessee By Ms. Shashi M. Kapila, Adv& Sh. Sushil Kumar, Adv Revenue By Sh. S. K. Jadhav, Cit (Dr) Date Of Hearing 08/01/2026 Date Of Pronouncement 11/02/2026

Section 143(3)Section 144Section 144C(3)Section 234ASection 92C

…of the Tribunal have been affirmed by the Jurisdictional High Court, wherein accepted the accounting treatment given by the Assessee to ‘advance received from customers’ by relying on the principal determined in the case of Taparia Tools Ltd. (SC) (2015) 55 Taxmann.com 361. Thus, sought for dismissal of the Appeal of the Revenue. 14. We have heard both the parties and perused the material available on record. The issue involved in the Revenue’s Appeal has been decided in Assessee’s own case for Assessment Year 2005-06 to 2007-08 in ITA No. 1214/2018, ITA No. 1233/2018 and ITA No. 1269/2018 by the Hon'ble H…

DCIT, MUMBAI vs. TRENT LIMITED, MUMBAI

In the result, these grounds of appeal are

ITA 5242/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

Section 115JSection 143(3)Section 153Section 254(1)Section 40A(2)Section 92BSection 92C

…re amount of ₹ 1000 received is being offered to tax by the assessee in the year when in which it is underutilised. To support his submission the learned AR of the assessee relied upon decision of honourable Supreme Court in case of Taparia Tools Ltd. (2015) 372 ITR 605 (SC), wherein it was held that though the entire expenditure was incurred in that year, it was the assessee who wanted to spread over. It was noted by Apex Court that they are conscious of the principle that normally revenue expenditure is to be allowed in the same year in which it is incurred, but at the instance of assessee, who wanted spreadi…

TRENT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(3)(1), MUMBAI

In the result, these grounds of appeal are

ITA 5166/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

Section 115JSection 143(3)Section 153Section 254(1)Section 40A(2)Section 92BSection 92C

…re amount of ₹ 1000 received is being offered to tax by the assessee in the year when in which it is underutilised. To support his submission the learned AR of the assessee relied upon decision of honourable Supreme Court in case of Taparia Tools Ltd. (2015) 372 ITR 605 (SC), wherein it was held that though the entire expenditure was incurred in that year, it was the assessee who wanted to spread over. It was noted by Apex Court that they are conscious of the principle that normally revenue expenditure is to be allowed in the same year in which it is incurred, but at the instance of assessee, who wanted spreadi…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 26/BANG/2024[2018-19]Status: DisposedITAT Bangalore31 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon'ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 25/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Respondent: Shri. A. Shankar, Sr. Advocate
Section 132Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon'ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 24/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Oct 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon’ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX OFFICER, CENTRAL CIRCLE-2(2), BENGALURU

ITA 23/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon'ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 22/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Oct 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon’ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 21/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…ts that, if the appellant had claimed the entire sum as revenue expenditure, the same would have been allowed as expenditure in the first year itself in accordance with the decision of the Hon’ble Supreme Court in the case of Taparia Tools Ltd. v. JCIT (2015) 372 ITR 605 (SC). In the instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount…

SPANDANA SPHOORTY FINANCIAL LIMITED,HYDERABAD vs. ACIT., CIRCLE 3(2), HYDERABAD

Accordingly, the addition of Rs.11,44,51,818/- (supra) made by the\nAO, which, thereafter, had been sustained by the CIT(A), is vacated.\nThe Grounds of appeal Nos.3.1 to 3.4 are allowed in terms o...

ITA 821/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18
Section 143(3)Section 145Section 69A

…ift in the method of\naccounting, i.e., recognizing the ancillary borrowing costs by the\nassessee company was permissible as per the mandate of law, had\nrelied upon the judgment of the Hon'ble Supreme Court in the case of\nTaparia Tools Ltd. vs. JCIT (2015) 372 ITR 605 (SC) and that of the\nHon'ble High Court of Delhi in the case of CIT v. Citi Financial\nConsumer Fin. Ltd (2011) 335 ITR 29 (Delhi). Also, the Ld. AR had\npressed into service the order of the coordinate Bench of the Tribunal,\ni.e., ITAT, Kolkata in the case of Magma Fincorp Limited vs. DCIT,\nCircle-8(1), Kolkata (2017) 82 taxmann.com 481 (Kolk…

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

…ntained in the Income Tax Act. The relevant findings of the Hon'ble Supreme Court in the case of M/s. Taparia Tools Ltd. (supra) and the decision in the case of M/s.Kedarnath Jute Manufacturing Co.Ltd (supra) are as under:- “ Taparia Tools Ltd. Vs.JCIT (2015) 372 ITR 605(SC): Section 36(1)(iii) of Income Tax Act, 1961 – Interest on borrowed capital (Upfront interest charges) – assessment year 1996-97 – Assessee company issued debentures for a period of 5 ears – Apart from option of half yearly periodical interest, debenture holders were given another option to accept one time upfront discounted interest payment –…

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

…ntained in the Income Tax Act. The relevant findings of the Hon'ble Supreme Court in the case of M/s. Taparia Tools Ltd. (supra) and the decision in the case of M/s.Kedarnath Jute Manufacturing Co.Ltd (supra) are as under:- “ Taparia Tools Ltd. Vs.JCIT (2015) 372 ITR 605(SC): Section 36(1)(iii) of Income Tax Act, 1961 – Interest on borrowed capital (Upfront interest charges) – assessment year 1996-97 – Assessee company issued debentures for a period of 5 ears – Apart from option of half yearly periodical interest, debenture holders were given another option to accept one time upfront discounted interest payment –…

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

…ntained in the Income Tax Act. The relevant findings of the Hon'ble Supreme Court in the case of M/s. Taparia Tools Ltd. (supra) and the decision in the case of M/s.Kedarnath Jute Manufacturing Co.Ltd (supra) are as under:- “ Taparia Tools Ltd. Vs.JCIT (2015) 372 ITR 605(SC): Section 36(1)(iii) of Income Tax Act, 1961 – Interest on borrowed capital (Upfront interest charges) – assessment year 1996-97 – Assessee company issued debentures for a period of 5 ears – Apart from option of half yearly periodical interest, debenture holders were given another option to accept one time upfront discounted interest payment –…

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

…ntained in the Income Tax Act. The relevant findings of the Hon'ble Supreme Court in the case of M/s. Taparia Tools Ltd. (supra) and the decision in the case of M/s.Kedarnath Jute Manufacturing Co.Ltd (supra) are as under:- “ Taparia Tools Ltd. Vs.JCIT (2015) 372 ITR 605(SC): Section 36(1)(iii) of Income Tax Act, 1961 – Interest on borrowed capital (Upfront interest charges) – assessment year 1996-97 – Assessee company issued debentures for a period of 5 ears – Apart from option of half yearly periodical interest, debenture holders were given another option to accept one time upfront discounted interest payment –…

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

…ntained in the Income Tax Act. The relevant findings of the Hon'ble Supreme Court in the case of M/s. Taparia Tools Ltd. (supra) and the decision in the case of M/s.Kedarnath Jute Manufacturing Co.Ltd (supra) are as under:- “ Taparia Tools Ltd. Vs.JCIT (2015) 372 ITR 605(SC): Section 36(1)(iii) of Income Tax Act, 1961 – Interest on borrowed capital (Upfront interest charges) – assessment year 1996-97 – Assessee company issued debentures for a period of 5 ears – Apart from option of half yearly periodical interest, debenture holders were given another option to accept one time upfront discounted interest payment –…

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