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“Section 36(1)(viii)”

Section References (mined)Section 36Section 36(1)(viii)285 judgments

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty percent ... business. Therefore, all these categories of incomes which the assessee is receiving as a direct nexus with the long term finance and therefore Section 36(1)(viii) of the Act is attracted. Therefore, we do not see any merit in these appeals. Accordingly, the first substantial question

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 "In respect of any special reserve created and maintained ... business. Therefore, all these categories of incomes which the assessee is receiving as a direct nexus with the long term finance and therefore Section 36(1)(viii) of the Act is attracted. Therefore, we do not see any merit in these appeals. Accordingly, the first substantial question

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty percent ... business. Therefore, all these categories of incomes which the assessee is receiving as a direct nexus with the long term finance and therefore Section 36(1)(viii) of the Act is attracted. Therefore, we do not see any merit in these appeals. Accordingly, the first substantial question

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 "In respect of any special reserve created and maintained ... business. Therefore, all these categories of incomes which the assessee is receiving as a direct nexus with the long term finance and therefore Section 36(1)(viii) of the Act is attracted. Therefore, we do not see any merit in these appeals. Accordingly, the first substantial question

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty ... business. Therefore, all these categories of incomes which the assessee is receiving as a direct nexus with the long term finance and therefore Section 36(1)(viii) of the Act is attracted. Therefore, we do not see any merit in these appeals. Accordingly, the first substantial question

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘B': NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI ANUBHAV SHARMA

INDIA INFRASTRUCTURE FINANCE COMPANY LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, I.P. ESTATE, NEW DELHI

ITA 5552/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Feb 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

ITA No.4170/Del/2025 & 5552/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL

JCIT(OSD), CIRCLE -10(1), DELHI vs. M/S INDIAN INFRASTRUCTURE FINANCE COMPANY LIMITED, DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1251/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Shery Gupta, CAFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 143(3)Section 154Section 36Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 861

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘E’ BENCH, NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER, AND SHRI

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2917/DEL/2024[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2916/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2915/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2914/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2913/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2912/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2911/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2910/DEL/2024[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

ITA 2573/DEL/2024[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

ITA 2572/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

ITA 2571/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

ITA 2570/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

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Section 36(1)(viii) — 285 judgments | BharatTax | BharatTax