Tata Sons Ltd. v. CIT

18 ITR 460High Court1950#4117 most cited

What is Tata Sons Ltd. v. CIT authority for?

Expenditure claimed by an assessee-company is deductible if it is considered in light of commercial expediency, ordinary commercial trading principles, and whether it was part of the profit-making process.

29

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

Tata Sons Ltd. v. CIT · 18 ITR 460 · commercial expediency · ordinary commercial trading · profit making process · deductibility of expenditure · business expenditure · Income Tax Act

Also reported as

158 Taxmann.com 601

Sections most often in play

Section 115VDSection 115VISection 143(3)Section 153ASection 2(22)(d)Section 40A(3)Section 115VPSection 33AC

Issues it is cited on

section 33acsection 115vscheme of arrangementmanagement feesddtdividend distribution taxtax benefitsection 2(22)section 33deemed dividendsection 80ibput to use

Judgments citing Tata Sons Ltd. v. CIT

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(3) , MUMBAI vs. M/S SAMSON MARITIME LTD, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2344/MUM/2023[2017-18]Status: DisposedITAT Mumbai17 Mar 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(3), MUMBAI vs. M/S SAMSON MARITIME LTD, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2343/MUM/2023[2016-2017]Status: DisposedITAT Mumbai17 Mar 2025AY 2016-2017

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2330/MUM/2023[2017-2018]Status: DisposedITAT Mumbai17 Mar 2025AY 2017-2018

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2329/MUM/2023[2015-16]Status: DisposedITAT Mumbai17 Mar 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2328/MUM/2023[2014-2015]Status: DisposedITAT Mumbai17 Mar 2025AY 2014-2015

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2327/MUM/2023[2013-2014]Status: DisposedITAT Mumbai17 Mar 2025AY 2013-2014

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

DCIT-CC5(3), MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2326/MUM/2023[2012-2013]Status: DisposedITAT Mumbai17 Mar 2025AY 2012-2013

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2263/MUM/2023[2017-2018]Status: DisposedITAT Mumbai17 Mar 2025AY 2017-2018

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2262/MUM/2023[2016-2017]Status: DisposedITAT Mumbai17 Mar 2025AY 2016-2017

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2261/MUM/2023[2015-16]Status: DisposedITAT Mumbai17 Mar 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED,MUMBAI CITY vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2260/MUM/2023[2014-15]Status: DisposedITAT Mumbai17 Mar 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2259/MUM/2023[2013-14]Status: DisposedITAT Mumbai17 Mar 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

ITA 2258/MUM/2023[2012-13]Status: DisposedITAT Mumbai17 Mar 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘G‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No.2258/Mum/2023 to 2263/Mum/2023 (Assessment Year :2012-13 to 2017-18) Samson Maritime Limited Vs. Dy. Commissioner of 201/202, Raheja Xion, Income Tax, Central Near DCP Zone-III, Circle 5(3) Dr. Baba Ambedkar Road, Mumbai- 400 021 Byculla East, Mumbai- 400 027 PAN/GIR No.AAACS9177M (Appellant) .. (Respondent) ITA No.2326/Mum/2023 to 2329/Mum/2023 (Assessment Year :2012-13 to 2015-16) ITA No.2330/Mum/2023 (Assessment Year: 2017-18) & Dy. Commissioner of Vs. Samson Maritime…

NIRMAL COMMERCIAL LTD,MUMBAI vs. ITO WD 3(3)(3), MUMBAI

In the result, the appeal filed by the assessee is hereby allowed

ITA 1233/MUM/2017[2013-14]Status: DisposedITAT Mumbai09 Feb 2021AY 2013-14

Bench: Shri M. Balaganesh, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.1233/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2013-14) Shree Nirmal Commercial बिधम/ Income Tax Officer Ward Ltd. 3(3)(3) Vs. 241/242, Nirmal Bldg, Aaykar Bhavan, Mumbai- Backbay Reclamation, 400020. Nariman Point, Mumba- 400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs7533F (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri K. Gopal Ms. Neha Paranjpe Revenue By: Shri Rajendra Joshi (Dr) सुनवाई की तारीख / Date Of Hearing: 02/12/2020 घोषणा की तारीख /Date Of Pronouncement: 09/02/2021 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 28.11.2016 Passed By The Commissioner Of Income Tax (Appeals) -8, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2013- 14. 2. The Assessee Has Raised The Following Grounds: - “1.1 On The Facts & Circumstances Of The Case & In Law The Assessing Officer Has Erred In Considering The Following Expenses As Capital Expenditure Instead Of Revenue Expenditure Out Of The Total Expenses Of Repairs & Maintenance Of Rs. 70,04,835 Debited To Profit & Loss Account & Cit(A) In Confirming The Same. A.Y.2013-14 Name Of Party Rupees M/S. Bagwe Engineering Ltd. 12,17,472 M/S. Kamal Marble 23,62,501 M/S. Vinod Engineering 17,77,716 Total 53,57,689 2.2 The Cit(A) & The Assessing Officer Is Of The View That The Above Expenditures Have Not Been Incurred In Relation To Annual Maintenance Cost For Normal Wear & Tear & The Said Expenditures Are Expected To Give Long Lasting Benefit To The Appellant & Hence, Erred In Considering The Same As Capital Expenditure.

For Appellant: Shri K. GopalFor Respondent: Shri Rajendra Joshi (DR)

…5 (Bom), wherein n annual amount payable to a lender of money which was needed by the assessee was held to be deductible even if it was payable after the entire loan had been repaid. Shri Dastur relied upon the observation made in Tata Sons Ltd. v. CIT [1950] 18 ITR 460, 467 (Bom), wherein it has been observed that "one has to consider the deductibility of the amount claimed by the assessee-company by taking into account commercial expediency and the principles of ordinary commercial trading and whether the expenditure was a part of the process of profit making". He also relied upon the observations made in Easte…

M/S BENGAL SHRIRAM HITECH CITY PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(3), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 122/BANG/2019[2014-15]Status: DisposedITAT Bangalore12 Oct 2020AY 2014-15

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…few cases are cited in this regard:  Eastern Investments Ltd. Vs. CIT (20 ITR 1) (SC)  J.R. Patel & Sons Pvt. Ltd. 69 ITR 782 (Guj)  Raipur Mfg. Co. Ltd. (84 !TR 508,516) (Guj)  Security Printers of India Pvt. Ltd. (78 ITR 766,774) (All)  Tatasons Ltd. (18 ITR 460,467) (Born)  Walchand & Co. P. Ltd.(65 ITR 381, 385) (SC)  J.K. Woolen Manufactures (72 ITR 612) (SC)  Aluminium Corp. of India Ltd. (86 ITR 11, 17) (SC)  Orissa Cement Ltd. (73 ITR 14, 17) (Del)  CIT vs IBC Knowledge Park Pvt Ltd [2016] 385 ITR 346 (Kar) 1.8. It is also decided principle of law that once the business is set, all the expense…

M/S BENGAL SHRIRAM HITECH CITY PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 121/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Oct 2020AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…few cases are cited in this regard:  Eastern Investments Ltd. Vs. CIT (20 ITR 1) (SC)  J.R. Patel & Sons Pvt. Ltd. 69 ITR 782 (Guj)  Raipur Mfg. Co. Ltd. (84 !TR 508,516) (Guj)  Security Printers of India Pvt. Ltd. (78 ITR 766,774) (All)  Tatasons Ltd. (18 ITR 460,467) (Born)  Walchand & Co. P. Ltd.(65 ITR 381, 385) (SC)  J.K. Woolen Manufactures (72 ITR 612) (SC)  Aluminium Corp. of India Ltd. (86 ITR 11, 17) (SC)  Orissa Cement Ltd. (73 ITR 14, 17) (Del)  CIT vs IBC Knowledge Park Pvt Ltd [2016] 385 ITR 346 (Kar) 1.8. It is also decided principle of law that once the business is set, all the expense…

BENGAL SHRIRAM HITECH CITY PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result, all the appeals of the assessee are treated as partly allowed

ITA 1341/BANG/2017[2012-13]Status: DisposedITAT Bangalore12 Oct 2020AY 2012-13

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri S. Ananthan, A.RFor Respondent: Shri Mallikarjuna G., D.R

…few cases are cited in this regard:  Eastern Investments Ltd. Vs. CIT (20 ITR 1) (SC)  J.R. Patel & Sons Pvt. Ltd. 69 ITR 782 (Guj)  Raipur Mfg. Co. Ltd. (84 !TR 508,516) (Guj)  Security Printers of India Pvt. Ltd. (78 ITR 766,774) (All)  Tatasons Ltd. (18 ITR 460,467) (Born)  Walchand & Co. P. Ltd.(65 ITR 381, 385) (SC)  J.K. Woolen Manufactures (72 ITR 612) (SC)  Aluminium Corp. of India Ltd. (86 ITR 11, 17) (SC)  Orissa Cement Ltd. (73 ITR 14, 17) (Del)  CIT vs IBC Knowledge Park Pvt Ltd [2016] 385 ITR 346 (Kar) 1.8. It is also decided principle of law that once the business is set, all the expense…

ACIT, CIRCLE-4(1), , VISAKHAPATNAM vs. SRI VARALAKSHMI JUTE TWINE MILLS PVT. LTD,, RAJAM

In the result, appeals filed by the Revenue in ITA

ITA 458/VIZ/2017[2013-2014]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2013-2014

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…ertaken in the Lease Agreements to continue the services of the existing employees and ensure to take care their interest (d) the assessee had taken steps to ensure continuity of service of employees with the Lessees. 9. In the case of Tata Sons Ltd. vs. CIT (18 ITR 460) it was noted that the assessee, a managing agent company paid voluntarily half share of bonus which the managed company paid to its officers in order to increase efficiency of working of managed company which would result in higher and better profits of manufactured company and which tended to increase the income on profits of the assessee. The r…

SRI VARALAKSHMI JUTE TWINE MILLS PRIVATE LIMITED,,RAJAM vs. DCIT, CIRCLE-4(1),, VISAKHAPATNAM

In the result, appeals filed by the Revenue in ITA

ITA 404/VIZ/2017[2013-2014]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2013-2014

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…ertaken in the Lease Agreements to continue the services of the existing employees and ensure to take care their interest (d) the assessee had taken steps to ensure continuity of service of employees with the Lessees. 9. In the case of Tata Sons Ltd. vs. CIT (18 ITR 460) it was noted that the assessee, a managing agent company paid voluntarily half share of bonus which the managed company paid to its officers in order to increase efficiency of working of managed company which would result in higher and better profits of manufactured company and which tended to increase the income on profits of the assessee. The r…

SRI VARALAKSHMI JUTE TWINE MILLS PVT. LTD.,,RAJAM vs. THE ITO,, SRIKAKULAM

In the result, appeals filed by the Revenue in ITA

ITA 349/VIZ/2016[2012-2013]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…ertaken in the Lease Agreements to continue the services of the existing employees and ensure to take care their interest (d) the assessee had taken steps to ensure continuity of service of employees with the Lessees. 9. In the case of Tata Sons Ltd. vs. CIT (18 ITR 460) it was noted that the assessee, a managing agent company paid voluntarily half share of bonus which the managed company paid to its officers in order to increase efficiency of working of managed company which would result in higher and better profits of manufactured company and which tended to increase the income on profits of the assessee. The r…

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Tata Sons Ltd. v. CIT (18 ITR 460) — Cited in 29 Judgments | BharatTax