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“Section 36(1)”

Section References (mined)Section 36Section 36(1)3,872 judgments

The decision most relied on for Section 36(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

TRF Ltd. v. CIT
323 ITR 397 · 2010 · Supreme Court
714
citing judgments

For claiming deduction for bad debts under section 36(1)(vii) of the Income Tax Act, it is sufficient for the assessee to write off the debt as irrecoverable in its accounts, and it is not necessary to prove that the debt has actually become irrecoverable.

Judgments citing Section 36(1)

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under Section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under Section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under Section 37. The department

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under Section 37. The department

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under section 37. The department

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

while arriving at the assessed income included the provision made towards country risk for the purpose of determining the deduction allowable under Section 36(1)(viia)(b) i.e. an amount not exceeding 5% of the total income. The DRP confirmed the decision of the AO on both counts that ... that the same to be considered with other provisions made towards bad and doubtful debts for the purpose of deduction under Section 36(1)(viia)(b). The ground raised by the assessee is with regard to AO not allowing the claim separately as a deduction under Section 37. The department

M/S Novel Sugar Ltd, Kanpur vs. DCIT, CPC, Bengaluru

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 27/LKW/2022[2019-2020]Status: DisposedITAT Lucknow19 Mar 2025AY 2019-2020

Bench: Shri Kul Bharat & Shri Nikhil Choudharym/S. Novel Sugar Ltd Dcit, Centralized V. 123/355, Fazalganj, Kanpur- Processing Centre, 208012. Bangaluru. Pan:Aaccb2480N (Appellant) (Respondent)

For Appellant: Shri Ashish Jaiswal, AdvFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 143(1)Section 36(1)(va)Section 43B

learned Assessing Officer as well as learned Commissioner of Income Tax (Appeals) has erred in making addition of Rs.5,29,103.00 under section 36(1)(va) of the Income Tax Act, 1961. 2. That the learned Commissioner of Income Tax (Appeals) has erred in confirming the addition under section 36

Dushyantsinh Yadvendrasinh Chudasama, Vadodara vs. Income Tax Officer, Ward-1(2)(4), Vadodara

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 354/AHD/2022[2015-16]Status: DisposedITAT Ahmedabad19 Mar 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Kinjal Shah, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 143(3)Section 40Section 43BSection 68Section 69

accepted by the AO, who observed that if the interest was genuinely a business expense, it ought to have been claimed under Section 36(1)(iii) of the Act rather than under Section 57 of the Act. The AO also noted that Form 15G/15H, which could have exempted the assessee

Dushyantsinh Yadvendrasinh Chudasama, Vadodara vs. Dy.Comm. of Income Tax, Circle-1(2), Vadodara

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 353/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad19 Mar 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Kinjal Shah, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 143(3)Section 40Section 43BSection 68Section 69

accepted by the AO, who observed that if the interest was genuinely a business expense, it ought to have been claimed under Section 36(1)(iii) of the Act rather than under Section 57 of the Act. The AO also noted that Form 15G/15H, which could have exempted the assessee

Deputy Commissinoer of Income Tax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

ITA 470/CHNY/2024[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca Department By Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement 19.03.2025

Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Deputy Commissioner of Incometax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

ITA 1463/CHNY/2024[2017-18]Status: DisposedITAT Chennai19 Mar 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) V. M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Department By : Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca : Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing : 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.03.2025

For Respondent: Mr. Sandeep Bagmar, Advocate
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Deputy Commissioner of Income Tax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

In the result, Revenue Appeal for AY 2012-13 stands dismissed

ITA 1462/CHNY/2024[2016-17]Status: DisposedITAT Chennai19 Mar 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay Baran Som, CIT
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Deputy Commissioner of Income Tax, Nungambakkam Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

In the result, Revenue Appeal for AY 2012-13 stands dismissed

ITA 1438/CHNY/2024[2011-12]Status: DisposedITAT Chennai19 Mar 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay Baran Som, CIT
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Deputy Commissioner of Income Tax Officer, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

In the result, Revenue Appeal for AY 2012-13 stands dismissed

ITA 1339/CHNY/2024[2018-19]Status: DisposedITAT Chennai19 Mar 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay Baran Som, CIT
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Cholamandalam Ms General Insurance Company Limited, Chennai vs. DCIT, Non Corp Ward 8, Chennai

In the result, Revenue Appeal for AY 2012-13 stands dismissed

ITA 1285/CHNY/2024[2018-19]Status: DisposedITAT Chennai19 Mar 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay Baran Som, CIT
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Cholamandalam Ms General Insurance Company Limited, Chennai vs. DCIT, Non Corp Circle 8, Chennai

In the result, Revenue Appeal for AY 2012-13 stands dismissed

ITA 1284/CHNY/2024[2017-18]Status: DisposedITAT Chennai19 Mar 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay Baran Som, CIT
Section 115JSection 14ASection 2Section 37(1)

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims

Cholamandalam Ms General Insurance Company Limited, Chennai vs. DCIT, Non Corp Circle 8, Chennai

ITA 1282/CHNY/2024[2011-12]Status: DisposedITAT Chennai19 Mar 2025AY 2011-12
Section 115JSection 14ASection 2Section 37(1)Section 40

towards claims Incurred But Not Reported (IBNR) and claims Incurred But Not Enough Reported (IBNER). The above deduction was claimed under section 36(1) of the Act. The basis of the claim was that the provision has been made for all the unsettled claims on the basis of the claims