Thiru Arooran Sugars Ltd. v. CIT

227 ITR 432Supreme Court of India1997#2080 most cited

What is Thiru Arooran Sugars Ltd. v. CIT authority for?

When an assessee engages in activities involving both agricultural and manufacturing components, or internal production and consumption, the income must be apportioned. To determine the taxable business income, the value of the self-produced raw material or input consumed internally is to be deducted at its prevalent market value.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2024.

Also referred to as

Thiru Arooran Sugars Ltd v CIT · agricultural income apportionment · market value self-consumed produce · mixed income valuation · captive consumption market price · sugar manufacturing income tax · exempt income calculation · business income from agricultural operations · Section 14A applicability · valuation of raw material · income separation principle

Also reported as

142 CTR 9

Sections most often in play

Section 14ASection 41(1)

Issues it is cited on

written down valuesection 41(1)section 41book profitssection 2(24)section 115jliable to taxsection 115jbdisallowance u/s 14asection 43commissioner (appeals)section 14a

Judgments citing Thiru Arooran Sugars Ltd. v. CIT

Dy. C.I.T. 1(2), Raipur (Cg) vs. M/S Hira Ferro Alloys Ltd., Raipur

In the result, appeal filed for assessment year 2010-11 is dismissed

ITA 360/BIL/2014[2011-12]Status: DisposedITAT Raipur18 Jan 2018AY 2011-12

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

…ls Ltd. (Formerly Chhattisgarh Electricity Co. Ltd.) Vs ACTT-U2), Uaipur the Hon'ble IT. A. T. "E" Bench, Mumhai (IT A No.248/Nag/2QOS for the A.Y.2003-04) 5. DCTT-Cir-8, Kol Vs M/s ITC Limited in l.T.A.18 (Kol) of 2006 6. Thiru Anooran Sugars Limited Vs CIT [227 ITR 432 (SC)] 7.CIT Vs Orient Paper Mills Ltd [176 ITR 110 (SC)] Grindwell Norton [2 SOT 52] 8. West Coast Paper Mills Ltd Vs JCIT reported in 100 TTJ 833 9. CIT vs. Sipla Ltd., (2005) 2 SOT 617 (Mum) 10, Assam Carbon Products Ltd. Vs AC1T 100 TO 224 (Kol ITAT) Assessment Years : 2009-10, 2010-2011& 2011-12 6. After considering the submissions of the as…

Dy. C.I.T. 1(2), Raipur (Cg) vs. M/S Hira Ferro Alloys Ltd., Raipur

In the result, appeal filed for assessment year 2010-11 is dismissed

ITA 359/BIL/2014[2010-11]Status: DisposedITAT Raipur18 Jan 2018AY 2010-11

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

…ls Ltd. (Formerly Chhattisgarh Electricity Co. Ltd.) Vs ACTT-U2), Uaipur the Hon'ble IT. A. T. "E" Bench, Mumhai (IT A No.248/Nag/2QOS for the A.Y.2003-04) 5. DCTT-Cir-8, Kol Vs M/s ITC Limited in l.T.A.18 (Kol) of 2006 6. Thiru Anooran Sugars Limited Vs CIT [227 ITR 432 (SC)] 7.CIT Vs Orient Paper Mills Ltd [176 ITR 110 (SC)] Grindwell Norton [2 SOT 52] 8. West Coast Paper Mills Ltd Vs JCIT reported in 100 TTJ 833 9. CIT vs. Sipla Ltd., (2005) 2 SOT 617 (Mum) 10, Assam Carbon Products Ltd. Vs AC1T 100 TO 224 (Kol ITAT) Assessment Years : 2009-10, 2010-2011& 2011-12 6. After considering the submissions of the as…

Dy. C.I.T. 1(2), Raipur (Cg) vs. M/S Hira Ferro Alloys Ltd., Raipur

In the result, appeal filed for assessment year 2010-11 is dismissed

ITA 358/BIL/2014[2009-10]Status: DisposedITAT Raipur18 Jan 2018AY 2009-10

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

…ls Ltd. (Formerly Chhattisgarh Electricity Co. Ltd.) Vs ACTT-U2), Uaipur the Hon'ble IT. A. T. "E" Bench, Mumhai (IT A No.248/Nag/2QOS for the A.Y.2003-04) 5. DCTT-Cir-8, Kol Vs M/s ITC Limited in l.T.A.18 (Kol) of 2006 6. Thiru Anooran Sugars Limited Vs CIT [227 ITR 432 (SC)] 7.CIT Vs Orient Paper Mills Ltd [176 ITR 110 (SC)] Grindwell Norton [2 SOT 52] 8. West Coast Paper Mills Ltd Vs JCIT reported in 100 TTJ 833 9. CIT vs. Sipla Ltd., (2005) 2 SOT 617 (Mum) 10, Assam Carbon Products Ltd. Vs AC1T 100 TO 224 (Kol ITAT) Assessment Years : 2009-10, 2010-2011& 2011-12 6. After considering the submissions of the as…

DCIT Cen Cir 40, Mumbai vs. Saf Yeast Co. P. Ltd, Mumbai

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

ITA 1780/MUM/2014[2008-09]Status: DisposedITAT Mumbai24 Nov 2017AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

DCIT Cen Cir 40, Mumbai vs. Saf Yeast Co. P. Ltd, Mumbai

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

ITA 1778/MUM/2014[2006-07]Status: DisposedITAT Mumbai24 Nov 2017AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

DCIT Cen Cir 40, Mumbai vs. Saf Yeast Co. P. Ltd, Mumbai

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

ITA 1777/MUM/2014[2005-06]Status: DisposedITAT Mumbai24 Nov 2017AY 2005-06

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

Saf Yeast Company P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

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

ITA 1637/MUM/2014[2008-09]Status: DisposedITAT Mumbai24 Nov 2017AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

Saf Yeast Company P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

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

ITA 1636/MUM/2014[2007-08]Status: DisposedITAT Mumbai24 Nov 2017AY 2007-08

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

Saf Yeast Company P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

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

ITA 1635/MUM/2014[2006-07]Status: DisposedITAT Mumbai24 Nov 2017AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

Saf Yeast Company P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

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

ITA 1634/MUM/2014[2005-06]Status: DisposedITAT Mumbai24 Nov 2017AY 2005-06

Bench: Sri Mahavir Singh, Jm & Sri N.K. Pradhan, Am

For Appellant: J.P. Bairagra, ARFor Respondent: B.C.S. Naik, CIT-DR
Section 143(3)Section 80I

…was Rs. 3.50 per unit, it had to be taken into account while computing amount of eligible profit available for deduction under section 80-IA - Held, yes [In favour of assessee].” Further, Hon’ble Supreme Court in the case of Thiru Arooran Sugars Ltd vs. CIT (227 ITR 432) held: “Section 2(1A) of the Income-tax Act, 1961, read with rule 7(2) of the Income-tax Rules, 1962 - Agricultural income - Assessment years 1962-63 to 1967-68 - Whether formula contained in clause (b) of rule 7(2) will apply only in cases where agricultural produce is not ordinarily sold in market in its raw state or after any process applied…

Addl CIT Large Tax Payer Unit, Mumbai vs. Reliance Industries Ltd, Mumbai

In the result, appeals of the Revenue are dismissed whereas appeals of the assessee are allowed in part in terms indicated hereinabove

ITA 4361/MUM/2012[2007-08]Status: DisposedITAT Mumbai12 Apr 2017AY 2007-08

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm Addl. Commissioner Of Vs. M/S. Reliance Industries Ltd.,3Rd Income Tax, Large Tax Floor, Maker Payer Unit, Mumbai Chamber-Iv, 222, Nariman Point, Mumbai – 400 021 Pan/Gir No. Aaacr5055K Appellant) .. Respondent) M/S. Reliance Industries Vs. Addl. Commissioner Of Income Ltd.,3Rd Floor, Maker Tax, Large Tax Payer Unit, Chamber-Iv, 222, Mumbai Nariman Point, Mumbai – 400 021 Pan/Gir No. Aaacr5055K Appellant) .. Respondent) M/S. Reliance Industries Vs. Asst. Commissioner Of Income Ltd.,3Rd Floor, Maker Tax, Large Tax Payer Unit, Chamber-Iv, 222, Mumbai Nariman Point, Mumbai – 400 021 Pan/Gir No. Aaacr5055K Appellant) .. Respondent) Asst. Commissioner Of Vs. M/S. Reliance Industries Ltd.,3Rd Income Tax, Large Tax Floor, Maker Payer Unit, Mumbai Chamber-Iv, 222, Nariman Point, Mumbai – 400 021 Pan/Gir No. Aaacr5055K Appellant) .. Respondent) M/S. Reliance Industries Vs. Asst. Commissioner Of Income Ltd.,3Rd Floor, Maker Tax, Large Tax Payer Unit

Section 143(3)Section 14ASection 195Section 40Section 43BSection 80I

…by the assessee and utilized as a raw material in such business shall be deducted at the prevalent market value. This principle has been considered and upheld by the Supreme Court in the case of Thiru Arooran Sugars Ltd. Vs. ClT (1997) -142 CTR (SC) 9; (1997) 227 ITR 432 (SC). Therefore, we direct the assessing authority to work out the profits on the basis of the price of the power generated' by the assessee' at the average of the annual landed cost of electricity 'purchased by the assessee from Karnataka State Electricity Board during the impugned previous year. It may be determined on the basis of 'payment det…

DCIT, Cir-11, Kolkata vs. M/S Graphite India Ltd., Kolkata

In the result, assessee’s appeal is partly allowed

ITA 559/KOL/2008[2003-2004]Status: DisposedITAT Kolkata24 Aug 2016AY 2003-2004

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 154Section 80Section 80HSection 80I

…by the assessee and utilized as a raw material in such business shall be deducted at the prevalent market value. This principle has been considered and upheld by the Supreme Court in the case of Thiru Arooran Sugars Ltd. vs. CIT (1977) 142 CTR 9 (SC); (1997) 227 ITR 432 (SFC). Therefore, we direct the assessing authorit9y to work out the profits on the basis of the price of the power generated by the assessee at the average of the annual landed cost of electricity purchased by the assessee from Karnataka State Electricity Board during the impugned previous year. It may be determined on the basis of payment detai…

Graphite India Ltd., Kolkata vs. ACIT, R-11, Kolkata

In the result, assessee’s appeal is partly allowed

ITA 305/KOL/2008[2003-2004]Status: DisposedITAT Kolkata24 Aug 2016AY 2003-2004

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 154Section 80Section 80HSection 80I

…by the assessee and utilized as a raw material in such business shall be deducted at the prevalent market value. This principle has been considered and upheld by the Supreme Court in the case of Thiru Arooran Sugars Ltd. vs. CIT (1977) 142 CTR 9 (SC); (1997) 227 ITR 432 (SFC). Therefore, we direct the assessing authorit9y to work out the profits on the basis of the price of the power generated by the assessee at the average of the annual landed cost of electricity purchased by the assessee from Karnataka State Electricity Board during the impugned previous year. It may be determined on the basis of payment detai…

Graphite India Ltd., Kolkata vs. ACIT, R-11, Kolkata

In the result, assessee’s appeal is partly allowed

ITA 304/KOL/2008[2003-2004]Status: DisposedITAT Kolkata24 Aug 2016AY 2003-2004

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 154Section 80Section 80HSection 80I

…by the assessee and utilized as a raw material in such business shall be deducted at the prevalent market value. This principle has been considered and upheld by the Supreme Court in the case of Thiru Arooran Sugars Ltd. vs. CIT (1977) 142 CTR 9 (SC); (1997) 227 ITR 432 (SFC). Therefore, we direct the assessing authorit9y to work out the profits on the basis of the price of the power generated by the assessee at the average of the annual landed cost of electricity purchased by the assessee from Karnataka State Electricity Board during the impugned previous year. It may be determined on the basis of payment detai…

Addl CIT RG 1, Mumbai vs. Indian Petrochemicals Corporation Ltd ( Now Merged With Reliance Indl. Ltd), Baroda

In the result, the appeal filed by the assessee for the assessment year 2005-06 is allowed and both the appeals filed by the Revenue are dismissed

ITA 3921/MUM/2009[2005-06]Status: DisposedITAT Mumbai18 Nov 2015AY 2005-06

Bench: S/Shri B.R.Baskaran (Am) & Ramlal Negi, (Jm) आमकय अऩीर सं./I.T.A. No.1426/Ahd/2009 (ननधधायण वषा / Assessment Year :2005-06) बनाम/ Indian Petrochemicals Corp.Ltd., The Addl. Commissioner Of Income (Now Merged With Reliance Tax, Range 1, Vs. Industries Ltd) Baroda, P O Petrochemicals, Gujarat Dist-Vadodara -391346 (अऩीरधथी /Appellant) (प्रत्मथी / Respondent) ..

…आयकर अपीऱीय अधिकरण, म ुंबई न्यायपीठ “आई” म ुंबई IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE S/SHRI B.R.BASKARAN (AM) AND RAMLAL NEGI, (JM) आमकय अऩीर सं./I.T.A. No.1426/Ahd/2009 (ननधधायण वषा / Assessment Year :2005-06) बनाम/ Indian Petrochemicals Corp.Ltd., The Addl. Commissioner of Income (Now merged with Reliance Tax, Range 1, Vs. Industries Ltd) Baroda, P O Petrochemicals, Gujarat Dist-Vadodara -391346 (अऩीरधथी /Appellant) (प्रत्मथी / Respondent) .. आमकय अऩीर सं./I.T.A. No.3921/Mum/2009 (ननधधायण वषा / Assessment Year :2005-06 बनाम/ Asstt. Commissioner –LTU, M/s Indian Petrochemicals Corp.Ltd…