DCIT-3(1)(1), MUMBAI, AAYAKAR BHAWAN vs. EXPORT IMPORT BANK OF INDIA, MUMBAI
In the result, all the appeals by the Revenue are dismissed
ITA 9456/MUM/2025[1999-2000]Status: DisposedITAT Mumbai30 Mar 2026AY 1999-2000
Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailita No. 9460/Mum/2025 (Assessment Year: 1999-00) (Assessment Year: 2004-05) Ita No. 9457/Mum/2025 Ita No. 9461/Mum/2025 (Assessment Year: 2000-01) (Assessment Year: 2005-06) Ita No. 9462/Mum/2025 (Assessment Year: 2001-02) (Assessment Year: 2006-07) Deputy Commissioner Of Income Tax – 3(1)(1), Room No.607, 6Th Floor, Aayakar Bhawan, ............... Appellant Mumbai – 400020 V/S Export Import Bank Of India, Centre One Building, Floor 21, World Trade Centre Complex, ……………… Respondent Cuffe Parade, Mumbai – 400005 Pan : Aaace2769D
For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Ritesh Misra, CIT-DR
Section 115Section 2(22)Section 23(2)Section 237Section 250
…its shareholders amounted to distribution of dividend. That means that dividend can be distributed in cash or kind. To the same effect is the decision of Hon'ble Madhya Pradesh High Court in the ca se of Ujjain General Trading Society (P.) Ltd. v. CIT (1968) 67 ITR 315. In the case of Smt. Mrudulaben B. Patel v. Asstt. CIT (2003) 85 ITD 463 (Ahd.) (SMC), the question was whether any part undisclosed income of a company received by director could be said to be income chargeable to tax. In the case of Kishanchand Chellaram v. CIT (1962) 46 ITR 640 (SC), the question was whether payment made as dividend by a compan…