TYRES LTD. v. THE FIRST INCOME-TAX OFFICER, MYSORE’, JT 2001 (2) SC 45 PP. 459, 460

3 SCC 76Reported decision1970#9656 most cited

What is TYRES LTD. v. THE FIRST INCOME-TAX OFFICER, MYSORE’, JT 2001 (2) SC 45 PP. 459, 460 authority for?

The principles of statutory interpretation, particularly concerning legislative intent and the purpose of granting deductions for infrastructure development, remain relevant. The creation of a nodal agency does not negate the legislative intent to provide such deductions.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2012 to 2025.

Also referred to as

Vikrant Tyres Ltd. v. The First Income-Tax Officer · Mysore · deduction for infrastructure development · legislative intent · nodal agency · Section 143(3) · Section 144 · Section 154 · Section 220(2) · Section 234B · Section 260A

Sections most often in play

Section 143(3)Section 144Section 154Section 220(2)Section 234BSection 260A

Issues it is cited on

indiatotal incomebusinessinterest

Judgments citing TYRES LTD. v. THE FIRST INCOME-TAX OFFICER, MYSORE’, JT 2001 (2) SC 45 PP. 459, 460

Babudeen and Party, Jaipur vs. I.T.O. Ward 6(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 129/JPR/2025[A.Y. 2000-01]Status: DisposedITAT Jaipur13 May 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. G. M. Mehta, C.AFor Respondent: Mrs. Anita Rinesh, JCIT
Section 144Section 154Section 220(2)Section 254

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 129/JP/2025 fu/kZkj.k o"kZ@Assessment Year : 2000-01 cuke Babudeen & Party ITO Vs. 596/2, Malviya Nagar Ward 6(1), Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAAAB1827D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. G. M. Mehta, C.A jktLo dh vksj ls@ Revenue by : Mrs. Anita Rinesh, JCIT lquo…

Principal Commissioner of Income Tax 1 Kolkata vs. Bothra Shipping Services Pvt Ltd

In the result, the appeals are dismissed and the substantial

ITAT/85/2024HC Calcutta25 Sept 2024

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 80I

…thorities would be denied the 1 1940 SCC Online PC 29 2 (1957) SCC Online SC 23 3 (1964) SCC Online SC 48 4 1971 (3) SCC 543 5 (1976) 4 SCC 643 6 (1977) 3 SCC 305 7 (1999) 1 SCC 430 8 (2001) 3 SCC 76 9 (2002) 6 SCC 227 10 (2008) 4 SCC 720 11 (2018) 408 ITR 274 ITAT NOS. 85 OF 2024 AND 86 OF 2024 REPORTABLE Page 9 of 21 deduction merely on the ground that the State Government had created a nodal agency for working out of the finer details and nitty-gritty of such infrastructure developments. That the purpose of cre…

Principal Commissioner of Income Tax 1 Kolkata vs. Bothra Shipping Services Pvt Ltd

In the result, the appeals are dismissed and the substantial

ITAT/86/2024HC Calcutta25 Sept 2024

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 80I

…thorities would be denied the 1 1940 SCC Online PC 29 2 (1957) SCC Online SC 23 3 (1964) SCC Online SC 48 4 1971 (3) SCC 543 5 (1976) 4 SCC 643 6 (1977) 3 SCC 305 7 (1999) 1 SCC 430 8 (2001) 3 SCC 76 9 (2002) 6 SCC 227 10 (2008) 4 SCC 720 11 (2018) 408 ITR 274 ITAT NOS. 85 OF 2024 AND 86 OF 2024 REPORTABLE Page 9 of 21 deduction merely on the ground that the State Government had created a nodal agency for working out of the finer details and nitty-gritty of such infrastructure developments. That the purpose of cre…

Everest Organics Ltd vs. The Commissioner of I.T., Hyderabad

ITTA/9/2005HC Telangana21 Sept 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 143(1)(a)

…Court entertained no doubt that the direction given by the Board was invalid and it vitiated the proceedings before the Collector as well as the Government. Similarly in the present appeal the direction given by the Collector was invalid and 27 (1970) 3 SCC 76 57 ITA No.6 of 2005 & other connected matters the proceedings before the Deputy Superintendent or the Assistant Collector were vitiated. This position obtains in all the appeals although the type and quality of paper are different. The Central Government merely affirmed the order made by the Collector in each case and did not giv…

M/S. Karnataka Power Corporation Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 11(5), Bangalore

In the result, both the appeals of the revenue and the assessee are dismissed

ITA 26/BANG/2020[2010-11]Status: DisposedITAT Bangalore02 Mar 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2010-11

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115JSection 80I

…ROVIDENT INVESTMENT CO.,, AIR 1957 SC 664, CIT, GUJARAT VS. VADILAL LALLUBHAI, AIR 1973 SC 1016, HANSRAJ & SONS VS. STATE OF JAMMU & KASHMIR, AIR 2002 SC 2692, VIKRANT TYRES LTD. VS. THE FIRST INCOME-TAX OFFICER, MYSORE, JT 2001 (2) SC 45 PP. 459, 460: (2001) 3 SCC 76: AIR 2001 SC 800] [SEE: PRINCIPLES OF STATUTORY INTERPREATION BY JUSTICE G.P.SINGH 13TH EDITIION PAGE 830]. 7. In the light of aforesaid well settled legal principles we may advert to the substantial question of law viz., with regard to applicability of Section 115JB(2) of the Act to the Banking Companies. Before proceeding further, it is apposite t…

Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore vs. M/S. Karnataka Power Corporation Limited, Bangalore

In the result, both the appeals of the revenue and the assessee are dismissed

ITA 10/BANG/2020[2010-11]Status: DisposedITAT Bangalore02 Mar 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2010-11

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115JSection 80I

…ROVIDENT INVESTMENT CO.,, AIR 1957 SC 664, CIT, GUJARAT VS. VADILAL LALLUBHAI, AIR 1973 SC 1016, HANSRAJ & SONS VS. STATE OF JAMMU & KASHMIR, AIR 2002 SC 2692, VIKRANT TYRES LTD. VS. THE FIRST INCOME-TAX OFFICER, MYSORE, JT 2001 (2) SC 45 PP. 459, 460: (2001) 3 SCC 76: AIR 2001 SC 800] [SEE: PRINCIPLES OF STATUTORY INTERPREATION BY JUSTICE G.P.SINGH 13TH EDITIION PAGE 830]. 7. In the light of aforesaid well settled legal principles we may advert to the substantial question of law viz., with regard to applicability of Section 115JB(2) of the Act to the Banking Companies. Before proceeding further, it is apposite t…

Neelachal I.Nigam L vs. Asst.Comnr.of I.Tax

ITA/8/2005HC Orissa17 Nov 2021

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE ADITYA KUMAR MOHAPATRA

Section 143(1)(a)

…Court entertained no doubt that the direction given by the Board was invalid and it vitiated the proceedings before the Collector as well as the Government. Similarly in the present appeal the direction given by the Collector was invalid and 27 (1970) 3 SCC 76 57 ITA No.6 of 2005 & other connected matters the proceedings before the Deputy Superintendent or the Assistant Collector were vitiated. This position obtains in all the appeals although the type and quality of paper are different. The Central Government merely affirmed the order made by the Collector in each case and did not giv…

The Commissioner of Income-Tax vs. M/S. Ing. Vysya Bank Limited

The appeals are disposed of

ITA/18/2014HC Karnataka16 Jan 2020

Bench: ALOK ARADHE,RAVI V HOSMANI

Section 114JSection 260Section 37(1)

…57 SC 664, ‘CIT, GUJARAT VS. VADILAL LALLUBHAI’, AIR 1973 SC 1016, ‘HANSRAJ & SONS VS. STATE OF JAMMU & KASHMIR’, AIR 2002 SC 2692, ‘VIKRANT TYRES LTD. VS. THE FIRST INCOME-TAX OFFICER, MYSORE’, JT 2001 (2) SC 45 PP. 459, 460: (2001) 12 3 SCC 76: AIR 2001 SC 800] [SEE: ‘PRINCIPLES OF STATUTORY INTERPREATION BY JUSTICE G.P.SINGH 13TH EDITIION PAGE 830]. 7. In the light of aforesaid well settled legal principles we may advert to the substantial question of law viz., with regard to applicability of Section 115JB(2) of the Act to the Banking Companies. Before proceeding further, it…

C. Sanyasi Raju vs. The Asst. Commissioner of Income-Tax, Central Circle, Vizag

ITTA/7/2005HC Telangana21 Nov 2017

Bench: C.V.NAGARJUNA REDDY,T.AMARNATH GOUD

Section 143(1)(a)

…Court entertained no doubt that the direction given by the Board was invalid and it vitiated the proceedings before the Collector as well as the Government. Similarly in the present appeal the direction given by the Collector was invalid and 27 (1970) 3 SCC 76 57 ITA No.6 of 2005 & other connected matters the proceedings before the Deputy Superintendent or the Assistant Collector were vitiated. This position obtains in all the appeals although the type and quality of paper are different. The Central Government merely affirmed the order made by the Collector in each case and did not giv…

The Commissioner of Income Tax-III vs. M/s.Samrakshna Electricals Ltd

ITTA/28/2010HC Telangana21 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 143(1)(a)

…Court entertained no doubt that the direction given by the Board was invalid and it vitiated the proceedings before the Collector as well as the Government. Similarly in the present appeal the direction given by the Collector was invalid and 27 (1970) 3 SCC 76 57 ITA No.6 of 2005 & other connected matters the proceedings before the Deputy Superintendent or the Assistant Collector were vitiated. This position obtains in all the appeals although the type and quality of paper are different. The Central Government merely affirmed the order made by the Collector in each case and did not giv…

M/s.GVK Petro Chemicals Private Limited, (Novo Resins AND vs. The Deputy Commissioner of Income Tax

ITTA/8/2005HC Telangana05 Jul 2012
Section 143(1)(a)

…Court entertained no doubt that the direction given by the Board was invalid and it vitiated the proceedings before the Collector as well as the Government. Similarly in the present appeal the direction given by the Collector was invalid and 27 (1970) 3 SCC 76 57 ITA No.6 of 2005 & other connected matters the proceedings before the Deputy Superintendent or the Assistant Collector were vitiated. This position obtains in all the appeals although the type and quality of paper are different. The Central Government merely affirmed the order made by the Collector in each case and did not giv…