Which sections of the Income Tax Act does Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 250, Section 143(3), Section 41(1), Section 14A, Section 40(a)(ia), Section 37(1).

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT

Q: How many judgments cite Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT?

621 judgments on BharatTax cite Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT (227 ITR 172), spanning 2007 to 2026.

227 ITR 172Supreme Court of India1997#92 most cited

What is Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT authority for?

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

621

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT · 227 ITR 172 · Section 28 · Section 56 · Section 57 · income from other sources · business income · interest income · commencement of business · capitalization of interest · year of expenditure claim

Also reported as

141 CTR 387

Sections most often in play

Section 250 Section 143(3)Section 41(1)Section 14A Section 40(a)(ia)Section 37(1)Section 147 Section 28(iv)

Issues it is cited on

section 57 profits and gains of business or profession section 56 section 32 revenue expenditure income from other sources section 28 section 37(1)capital expenditure section 43 section 37 previous year

Judgments citing Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT

VNG AUTOMOTIVE P. LTD. vs. ASSTT. COMMISSIONER OF INCOME

The appeals are disposed of as allowed

ITA-795/2004HC Delhi10 Apr 2026

For Appellant: Mr. Satyen Sethi & Mr. Arta Trana PandaFor Respondent: Mr Abhishek Maratha, SSC, Mr Apoorv

Section 148

…23,151/- and Rs.2,37,770/- for the AYs 1993-94 & 1994-95. 4. The Assessing Officer (AO) re-opened the assessment under Section 148 A of the Income Tax Act, 1961, („the Act‟) by referring to the Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT, (1997) 227 ITR 172 (SC), and treated the amount deposited in the bank as surplus amount, and that the surplus fund/interest to be taxed as „income from other sources‟. Aggrieved by the order of the AO, the appellant filed an appeal before the Commissioner of Income-tax (Appeals)-XIV, New Delhi, [“CIT (A)”], which was allowed. Aggrieved by the order of the CIT…

SHREENATH REALTORS,MUMBAI vs. INCOME TAX OFFICER WARD 19(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 7295/MUM/2025[2017-2018]Status: DisposedITAT Mumbai01 Apr 2026AY 2017-2018

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarshreenath Realtors, Ito Ward - 19(3)(1), 10 Patel Mansion, Mumbai Proctor Road, Grant Vs. Piramal Chambers, Road, Mumbai-400 007 4Th Floor, Room No. 405, Dr. Ss Rao Marg, Parel, Mumbai – 400 012 Pan/Gir No. Abifs7530G (Applicant) (Respondent) Assessee By Ms. Priyanka Jain, Ld. Ar Revenue By Smt. Usha Gaikwad, Ld. Dr Date Of Hearing 16.03.2026 Date Of Pronouncement 01.04.2026

Section 143(3)Section 250Section 270ASection 56

…was observed that the interest income was earned on idle funds and did not have any direct nexus with active business operations during the year. Relying upon the decision of the Hon’ble Supreme Court in Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (227 ITR 172), the learned CIT(A) held that interest earned on surplus funds in the absence of business activity is taxable under the head “Income from Other Sources”. The judicial precedents relied upon by the assessee were 5 Shreenath Realtors distinguished on facts. The learned CIT(A) also rejected the contention of the assessee based on the principle of…

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…

DCIT-4(1), INDORE, INDORE vs. MARAL OVERSEAS LTD, KHARGONE

In the result, the “Impugned

ITA 569/IND/2025[1992-93]Status: DisposedITAT Indore27 Feb 2026AY 1992-93

Bench: Shri B.M. Biyani & Shri Paresh M Joshideputy Commissioner Of Maral Overseas Ltd. बनाम/ Income Tax- 4(1) Maral Srovar, V & Po, Vs. Indore Khalbujurg, Kasrawad, Khargone, Bhopal (Pan: Aaccm0230B) (Appellant) (Respondent) Assessee By Shri Satyajeet Goyal, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 27.02.2026

Section 143(3)Section 250Section 253

…that the assessee did not incur any cost. The Page 7 of 56 Maral Overseas Ltd. ITA No. 569/Ind/2025 - A.Y.1992-93 learned Commissioner of income tax. (Appeals) referring to the decision of the Hon'ble Supreme Court in the case of Tuticorin Alkali Chemicals; 227 ITR 172 held that the said receipt has been rightly assessed and dismissed this ground of appeal of the assessee. f. The assessee carried the matter before the Hon'ble ITAT, which has decided on this issue in ITA no. 289/IND/02 on 16.05.2008 and restored the matter for reconsideration. The Hon'ble ITAT has accepted the proposition of the assessee that t…

MAX SQUARE LTD,NOIDA vs. ITO WARD-5(1)(5), NOIDA

In the result, the appeal of the assessee is dismissed

ITA 4100/DEL/2025[2021-22]Status: DisposedITAT Delhi13 Feb 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2021-22] Max Square Ltd. Vs Ito L-12, Max Tower, Sector-16-B Ward-5(1)(5) Gautam Budha Nagar Noida Noida, Uttar Pradesh-201301 Pan-Aagcn5808G Appellant Respondent Appellant By Shri Anil Bhalla, Ca & Shri Nitin Kumar Sharma, Ca Respondent By Shri Gouranga Chandra Das, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 30.05.2025 Of Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2020-21/10308419 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 07.12.2023 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2021-22. 2. Brief Acts Of The Case Are That The Assessee Is A Company, Engaged In The Business Of Real Estates Development & Started Construction Of Commercial Complex Project “Max Square” At Sector 129, Noida. The Assessee Borrowed Funds From Indusind Bank Amounting To Inr 29.45 Crores For The Construction & Further Raised Funds Through Issue Of Equity/Ccd’S. The Funds Which Remained Un-Utilized, Were Invested Temporary In Fdrs From Which Interest Was Received Of Inr 63,77,502/- & Was Credited To The Cost Of Construction. However, The Ao Has Held The Same As Taxable Under The Head “Income From Other Sources”.

Section 143(3)Section 250

…interest so received was credited to the construction cost account which ultimately reduced the cost of the project. However, the AO by placing reliance on the judgement of Hon’ble Apex Court in the case of Tuticorin Alkali Chemicals & Fertilizers Ltd. [1997] 227 ITR 172 (SC), has treated the same as “Income from Other Sources”. 7. On perusal of the facts, it is observed that the assessee has borrowed funds from Indusind banks as well as through CCDs, on which interest is payable. Therefore, when the funds remained ideal for short period, they were temporarily invested only for that period in FDRs and thus had d…

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 104/ASR/2024[2017-18]Status: DisposedITAT Amritsar15 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

Section 143(3)Section 148Section 250Section 35A

…the following judgment that interest income on fixed deposits pledged as margin with banks for obtaining bank guarantees etc., are taxable as business income and not as income from other sources. a. Tuticorin Alkali Chemicals & Fertilisers Ltd. v. CIT [1997] 227 ITR 172 (SC) b. CIT v. Karnal Co-operative Sugar Mills Ltd. [2001] 118Taxman489 (SC) c. CIT v. Bokaro Steel Ltd. [1999] 236 ITR 315 (SC) d. CIT v. Shahi Export House [2010] 195 taxman 163 (Delhi HC) e. DCIT vs. G. G. Continental Traders (P.) Ltd. [2023] 151 taxmann.com 384 (Amritsar - Trib.) I.T.A. No. 103 & 104/Asr/202 1 Assessment Years: 2014-15…

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 103/ASR/2024[2014-15]Status: DisposedITAT Amritsar15 Jan 2026AY 2014-15

Section 143(3)Section 148Section 250Section 35A

CHANGLANG COMMUNITY RESOURCE MANAGEMENT SOCIETY,CHANGLALNG vs. ITO(EXEMPTION), 2(4), SHILLONG

In the result, appeal of the assessee is allowed for statistical purposes

ITA 181/GTY/2025[2016-17]Status: DisposedITAT Guwahati08 Jan 2026AY 2016-17

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI LAXMI PRASAD SAHU (Accountant Member)

Section 11Section 11(1)(a)Section 11(2)Section 12ASection 143(1)Section 143(1)(a)Section 250

…annot be granted as held in CIT Vs. Nagpur Hotels Industries Association (2001) 247 ITR 201 (SC) and he also relied on the judgment of Hon'ble Apex Court in the case of CIT Vs. State Urban Development Society (2011), Tuticorn and Cloth Chemical Vs. CIT (1997) 227 ITR 172 (SC) and he further noted that the assessee could not substantiate its case. Accordingly, he dismissed the appeal of the assessee. 3. Aggrieved on the above order, the assessee filed appeal before the ITAT. 4. The Ld. Counsel reiterated the submissions made before the Ld. CIT(A) and submitted that the assessee is registered under Section 12A of…

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

ITA 744/CHNY/2005[2000-01]Status: DisposedITAT Chennai26 Dec 2025AY 2000-01

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T

Section 132Section 148Section 15Section 158BSection 17(1)(iv)

…961) 41 ITR 367 (SC) CIT, W.B. v. Imperial Chemical Industries Pvt. Ltd. (1969) 74 ITR 17 (SC) M.K. Brother Pvt. Ltd. v. CIT, Kanpur (1972) 86 ITR 38 (SC) Addl. CIT v. Rani Preetam Kunwar (1980) 125 ITR 102 (All) Tuticorin Alikali Chemicals & Fertilizers Ltd. 227 ITR 172 (SC) As already observed, M/s PPL was liable to pay interest on the loans taken from various financial institutions. The Appellant in the capacity of Managing Director was under no legal obligation to discharge the liabilities of interest belonging to M/s PPL even though he was its promoter. It is in this context the principles enunciated by the…

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

ITA 2197/CHNY/2005[1999-2000]Status: DisposedITAT Chennai26 Dec 2025AY 1999-2000

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T

Section 132Section 148Section 15Section 158BSection 17(1)(iv)

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…urns are determinative cannot be a conclusive basis to compute the income of an assessee. Reliance is placed on following judgments: i) ITA No. 589/2011 (Del) dated 30.09.2011 CIT vs. Arvind Kumar Jain ii) 82 ITR 363 (SC) Kedarnath Jute Mfg. Co. Ltd. ii) iii) 227 ITR 172 (SC) Tuticorn Alkali Chemicals and Fertilizers Ltd. vs. CIT 18 iv) 285 ITR 221 (Mad) CIT vs. Idhayam Publications Ltd 17 It is submitted that it is a case of lack of inquiry. In this regard appellant company seeks to place reliance on following judgments: ⅰ) 361 ITR 10 (Del) CIT v. Gangeshwari Metal (P) Ltd. ii) 357 ITR 146 (Del) CIT vs. Fair Fi…

MAHARASHTRA STATE ROAD DEVELOPMENT CORPORATION LTD,MUMBAI vs. DCIT 5(2), MUMBAI

ITA 696/MUM/2012[2008-09]Status: DisposedITAT Mumbai06 Oct 2025AY 2008-09

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Maharashtra State Road Dcit-5(2) Development Corporation Ltd. Aayakar Bhavan M.S.R.D.C. Ltd. Vs. M. K. Road Priyadarshini Park Nepenasea Mumbai-400 020. Road, Mumbai-400 036. Pan : Appellant Respondent

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Dalpat Shah

Section 14ASection 37Section 43B

…ame cannot be claimed in this year. As each assessment year is different, the concerned income and expenditure of each year should be claimed in the concerned year only. The Ld. AO further relied on the decision of Hon'ble Supreme Court of Tuticorin Alkalis ( 227 ITR 172) for the proposition that expenses pertaining to one year cannot be allowed in another year and made the addition. 4. The Ld. CIT(A) called for the details of expenditure and found that the appellant in fact claimed an expenditure of Rs. 46.33 crore relating to earlier years, in this assessment year and enhanced the same to Rs. 46.33 crore on tw…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. CHENANI NASHRI TUNNELWAY LIMITED, MUMBAI

ITA 4686/MUM/2025[2012-13]Status: HeardITAT Mumbai29 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Mr. Bhupal RapelliFor Respondent: Mr. Virabhadra S. Mahajan, Sr.DR

…harged as income from other sources and should not be capitalized nor set off against the interest paid on borrowed funds and reliance was placed on the decision of the Hon'ble Supreme Court in the case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT 227 ITR 172 and various other decisions on the subject and it was accordingly held that the interest income of Rs.3,44,38,898/- be treated as income from other sources as against the business income treated by the assessee and accordingly determined the income at Rs.3,44,38,898/- as against NIL income reported by the assessee while filing its return of incom…

M/S RPJ MINERALS PVT. LTD ,MAIHAR vs. INCOME TAX OFFICER, WARD -1,SATNA, SATNA

ITA 86/JAB/2022[2017-18]Status: DisposedITAT Jabalpur19 Sept 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR

Section 143(3)Section 234ASection 43B

…TD (Delhi) when particularly the facts of the cases are different to this case and are more similar t the case of the Hon'ble Supreme Court in case of M/s TUTUCRIN ALKALI CHEMICALS & FERTILIZERS LTD vs COMMISSIONER OF INCOME TAX(1997) 141 CTR (SC) 387: (1997) 227 ITR 172. 4. That the appellant reserves the right to amend/alter any of the grounds of appeal/add other grounds of appeal at the time of hearing." ITA No.- 86/JAB/2022 "1. On 1. The learned CIT(A) erred in not deleting the sum of Rs.23,01,000/- being amount of Rural Infrastructure Tax paid before the due date of submission of return as details of payment…

INCOME TAX OFFICER WARD-1 vs. M/S RPJ MINERALS PRIVATE LTD., SATNA

ITA 154/JAB/2016[2012-13]Status: DisposedITAT Jabalpur19 Sept 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR

Section 143(3)Section 234ASection 43B

…TD (Delhi) when particularly the facts of the cases are different to this case and are more similar t the case of the Hon'ble Supreme Court in case of M/s TUTUCRIN ALKALI CHEMICALS & FERTILIZERS LTD vs COMMISSIONER OF INCOME TAX(1997) 141 CTR (SC) 387: (1997) 227 ITR 172. 4. That the appellant reserves the right to amend/alter any of the grounds of appeal/add other grounds of appeal at the time of hearing.” ITA No.- 86/JAB/2022 “1. On 1. The learned CIT(A) erred in not deleting the sum of Rs.23,01,000/- being amount of Rural Infrastructure Tax paid before the due date of submission of return as details of payment…

ACIT-8(1)(1), MUMBAI, MUMBAI vs. RELIANCE RETAIL LTD, MUMBAI

In the result, appeal by the revenue is dismissed and cross objection by the assessee is allowed for statistical purposes

ITA 4251/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Madhur Agarwal, Advocate, Shri NimeshFor Respondent: Smt. Sanyogita Nagpal, CIT DR

Section 115JSection 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2018-19 Assistant Commissioner of Reliance Retail Ltd., Income Tax – 8(1)(1), 3rd Floor, Court House, Mumbai Lokmanya Tilak Marg, Vs. Dhobi Talao, Mumbai – 400 002 (PAN : AABCR1718E) (Appellant) (Respondent) CO No.194/Mum/2024 (Arising out of ITA 4251/Mum/2024) Assessment Year: 2018-19 Reliance Retail Ltd., Assistant Commissioner of 3rd Floor, Court House, Income Tax – 8(1)(1), Lokmanya Tilak Marg, Mumbai Dhobi Talao, Vs. Mumbai – 400 002 (PAN :…

M/S BROOKS LABORATORIES LTD. ,BADDI vs. ACIT, CIRCLE , PANCHKULA

The appeal stands dismissed

ITA 596/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh20 May 2025AY 2016-17

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) & Ms. DeepaliFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld.Sr. DR

Section 143(3)

…to other entities which were brought into Escrow Account as per the directions of the SEBI and therefore, the funds lying in escrow account were not connected with the setting up of a new plant. In the case of Tuticorin Alkali Chemical and Fertilizers Ltd. (227 ITR 172), it was held that interest received on surplus funds would have to be treated as income from other sources, In the case of Bokaro Steel Ltd. (236 ITR 315), the assessee earned interest on advances paid to the contractors during pre-commencement period and the same was found to be inextricably linked to the setting up of the plant of the assessee…

M/S BROOKS LABORATORIES LIMITED,SOLAN vs. DCIT, PANCHKULA

The appeal stands dismissed

ITA 530/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh20 May 2025AY 2014-15

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) & Ms. DeepaliFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld.Sr. DR

Section 143(3)

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 448/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)

Section 250

…a different entity. As it is considered as trading loss, there is no question of applicability of section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision of Great Eastern Shipping related to interest which was decided by the Apex Court. 7. The Ld. DR submitted that as regards ground No.4, there was no transfer of goods and the assessee could not explain as to why…

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