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“statutory dues”

DisallowancesSection 43BSection 43B297 judgments

The decision most relied on for statutory dues is CIT v. Alom Extrusion Ltd. (390 ITR 306), cited in 274 judgments on BharatTax.

Leading authorities on statutory dues

CIT v. Alom Extrusion Ltd.
390 ITR 306 · 2009 · Supreme Court
274
citing judgments

The amendment to the second proviso of Section 43B, introduced by the Finance Act, 2003, is curative in nature and applies retrospectively. This means employee contributions to welfare funds like ESI and PF are deductible if paid before the due date for filing the income tax return, even if paid beyond the statutory due date.

CIT v. Hindustan Organic Chemicals Limited
366 ITR 1 · 2014 · High Court
206
citing judgments

Employees' contribution towards Provident Fund (PF) and Employees' State Insurance Corporation (ESIC) is allowable as a deduction under Section 36(1)(va) read with Section 43B if deposited before the due date of filing the income tax return, even if deposited after the expiry of the statutory time period specified in the applicable fund's statute.

Kalpesh Synthetics (P.) Ltd. v. DCIT
137 Taxmann.com 475 · 2022 · ITAT
198
citing judgments

A deduction claimed under Section 36(1)(va) for employee contributions remitted after the statutory due date but before the return filing due date cannot be disallowed during intimation processing under Section 143(1) if the issue is debatable. Such a disallowance cannot be made automatically based solely on auditor's mention of actual vs. due dates in the tax audit report.

Ghanashyam Mishra And Sons. v. Edelweiss Asset Reconstruction
126 Taxmann.com 132 · 2021 · Supreme Court
192
citing judgments

Once a resolution plan is approved under Section 31(1) of the IBC, claims not included in the plan are extinguished and cannot be pursued. This applies to statutory dues owed to the government and other authorities.

Guj.) (iii) CIT vs. South India Corporation Ltd. (2000) 242 ITR 114 (Ker) (iv) CIT v. GTN Textiles Ltd.
269 ITR 285 · 2004 · High Court
176
citing judgments

Employee contributions towards ESI and PF are allowable as a deduction if paid by the due date for filing the income tax return, even if paid after the statutory due dates prescribed under the respective ESI/PF Acts.

Bharat Commerce Industries Ltd. v. CIT
230 ITR 733 · 1998 · Supreme Court
130
citing judgments

The Supreme Court holds that interest paid under Section 201(1A) of the Income-tax Act, for failure to deduct tax at source, is not an allowable business expenditure under Section 37(1) of the Act.

Lachmandas Mathura v. CIT
254 ITR 799 · 2002 · Supreme Court
119
citing judgments

Interest paid on delayed payment of statutory dues, such as sales tax, service tax, TDS, and GST, is compensatory in nature rather than penal. Consequently, such interest is an allowable deduction in computing business profits.

CIT v. Noble and Hewitt (I) P. Ltd.
305 ITR 324 · 2008 · High Court
109
citing judgments

Section 43B of the Income-tax Act does not apply to disallow an amount (such as statutory dues like service tax or GST) if it has not been debited to the Profit & Loss account and no deduction for it has been claimed by the assessee.

Judgments citing statutory dues

DCIT, Circle-5(1), Kolkata vs. Hindusthan National Glass and Industrieslimited, Kolkata

In the result, the appeal of the Revenue is dismissed as being infructuous

ITA 338/KOL/2024[2011-12]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 148ASection 14ASection 250

NCLT approves the resolution plan, it would be binding on, among others, the Central Government and its agencies in respect of payment of any statutory dues arising under any law for the time being in force. It is now trite law that the effect of resolution ... well settled that on the approval of the resolution plan in terms of section 31 of the IBC, the dues including the statutory dues of the Government or local authority, if not part of the ITA No.: 338/KOL/2024 Assessment Year: 2011-12 Hindusthan National Glass And Industrieslimited. resolution plan, gets

ITO, Ward-8(2), Kolkata vs. M/S. Sarga Hotel Pvt. Ltd., Kolkata

In the result, both the appeals filed by the Revenue are dismissed as infructuous

ITA 665/KOL/2023[2014-15]Status: DisposedITAT Kolkata31 Dec 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250

enclosed herewith and marked as Annexure A and Annexure B respectively. Under the terms of the aforementioned Resolution Plan, the admitted claims of the statutory dues of the Corporate Debtor were settled and resolved by payment of an amount of Rs 2,29,329/- (Refer Page 7.8.2 of the Resolution ... Further, subsequent to the approval of the resolution plan, all proceedings initiated prior to the admission of application of CIRP are discontinued and the statutory dues forming part of the resolution plan only can be enforced. Hence, the appeal of the Revenue becomes infructuous and are liable to be dismissed

I.T.O, Ward-8(2), Kolkata vs. M/S. Sarga Hotel Pvt. Ltd., Salt Lake

In the result, both the appeals filed by the Revenue are dismissed

ITA 664/KOL/2023[2013-14]Status: DisposedITAT Kolkata31 Dec 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250

enclosed herewith and marked as Annexure A and Annexure B respectively. Under the terms of the aforementioned Resolution Plan, the admitted claims of the statutory dues of the Corporate Debtor were settled and resolved by payment of an amount of Rs 2,29,329/- (Refer Page 7.8.2 of the Resolution ... Further, subsequent to the approval of the resolution plan, all proceedings initiated prior to the admission of application of CIRP are discontinued and the statutory dues forming part of the resolution plan only can be enforced. Hence, the appeal of the Revenue becomes infructuous and are liable to be dismissed

Ritesh Singh ACIT Circle 3 3 1, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all the three appeals are allowed for

ITA 5461/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Shri Parth Parikh, AdvFor Respondent: Shri Leyaqat Ali, Sr. DR
Section 143(3)Section 270ASection 7

basis of this statement of the facts, the Ld. CIT (A) was of the view that assessee was under liquidation process, therefore statutory dues to the central government already stands extinguished and therefore allowed the appeal of the assessee. The CIT(A) allowed the appeal primarily on the premise that ... consequent upon liquidation of the assessee as a going concern and its acquisition on a “clean slate” basis, all statutory dues, including income-tax dues, stood extinguished in terms of the IBC and the law laid down by the Hon'ble Supreme Court in Ghanshyam Mishra & Sons

Ritesh Singh ACIT Circle 3 3 1, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all the three appeals are allowed for statistical purpose

ITA 5460/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 143(3)Section 270ASection 7

basis of this statement of the facts, the Ld. CIT (A) was of the view that assessee was under liquidation process, therefore statutory dues to the central government already stands extinguished and therefore allowed the appeal of the assessee. The CIT(A) allowed the appeal primarily on the premise that ... consequent upon liquidation of the assessee as a going concern and its acquisition on a “clean slate” basis, all statutory dues, including income-tax dues, stood extinguished in terms of the IBC and the law laid down by the Hon'ble Supreme Court in Ghanshyam Mishra & Sons

Ritesh Singh ACIT Circle 3 3 1 Mumbai, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all result, all the three appeals are allowed for three appeals are allowed for statistical purpose statistical purpose

ITA 5459/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Shri Leyaqat Ali, Sr. DRFor Respondent: Shri Parth Parikh, Adv
Section 143(3)Section 270ASection 7

view (A) was of the view that assessee was under liquidation process that assessee was under liquidation process, therefore statutory therefore statutory dues to the central government dues to the central government already stands extinguished stands extinguished and therefore allowed the appeal of the assessee. and therefore allowed the appeal ... going concern and its upon liquidation of the assessee as a going concern and its acquisition on a “clean slate” basis, all statutory dues, including acquisition on a “clean slate” basis, all statutory dues, including acquisition on a “clean slate” basis, all statutory dues, including income-tax dues, stood extinguished

Ms Kalamandir Jewellers Ltd., Surat vs. The Asst. Commissioner of Income Tax- Circle 1(1)(1), Surat

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

ITA 1069/SRT/2024[2020-21]Status: DisposedITAT Surat23 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Sapnesh Sheth, AdvFor Respondent: Mr. Ajay Uke, Sr-DR
Section 143(1)Section 143(3)Section 36Section 36(1)(iii)Section 37

basis of Clause 26 of the Tax Audit Report furnished in Form No. 3CB. It was contended that the said amount represented statutory dues and taxes relating to employees’ salaries, which had been paid on or before the due date of filing of return under section

Dy. Commissioner of Income Tax, Noida vs. M/S Bright Buildtech Pvt. Ltd, Delhi

ITA 1244/DEL/2025[2016]Status: DisposedITAT Delhi22 Dec 2025

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Rohit Kapoor, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr. DR

this regard, he submitted that following computation and reasoning as per para 5 of internal pages 7–8 of the assessment order:- Statutory dues paid as on (A) Rs.84,29,609 17.04.2015 and 30.04.2015 Statutory dues as per Balance Sheet (B) Rs.64,86,866 Difference C=(A-B) Rs.19 ... Page No.47-48 of the impugned order has duly noticed the facts as under: 25. That the amount of statutory dues paid, totalling Rs.84,29,609, includes an amount of Rs.7,56,410 paid towards Works Contract Tax (WC) in Haryana, and the remaining Rs.76,73,219 pertains

Dy. Commissioner of Income Tax, Noida vs. M/S Bright Buildtech Pvt. Ltd., Delhi

ITA 1240/DEL/2025[2015]Status: DisposedITAT Delhi22 Dec 2025

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Rohit Kapoor, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr. DR

this regard, he submitted that following computation and reasoning as per para 5 of internal pages 7–8 of the assessment order:- Statutory dues paid as on (A) Rs.84,29,609 17.04.2015 and 30.04.2015 Statutory dues as per Balance Sheet (B) Rs.64,86,866 Difference C=(A-B) Rs.19 ... Page No.47-48 of the impugned order has duly noticed the facts as under: 25. That the amount of statutory dues paid, totalling Rs.84,29,609, includes an amount of Rs.7,56,410 paid towards Works Contract Tax (WC) in Haryana, and the remaining Rs.76,73,219 pertains

Instakart Services Private Limited, Bangalore vs. ACIT, Special Range-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 544/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Vohra, Sr. Advocate and Ms. AnkitaFor Respondent: Shri Shivanad Kalakeri, CIT

payroll register is prepared. Salaries are released through the vendor after deduction of taxes, with the balance paid on submission of proof of disbursement. Statutory dues like PF and ESI are also deposited by the vendors. Thus, the assessee follows a structured process to source, utilize and monitor manpower

Instakart Services Private Limited, Bangalore vs. JCIT, Special Rang-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 543/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

payroll register is prepared. Salaries are released through the vendor after deduction of taxes, with the balance paid on submission of proof of disbursement. Statutory dues like PF and ESI are also deposited by the vendors. Thus, the assessee follows a structured process to source, utilize and monitor manpower

DCIT CC -1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 531/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

payroll register is prepared. Salaries are released through the vendor after deduction of taxes, with the balance paid on submission of proof of disbursement. Statutory dues like PF and ESI are also deposited by the vendors. Thus, the assessee follows a structured process to source, utilize and monitor manpower

DCIT, CC-1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 530/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

payroll register is prepared. Salaries are released through the vendor after deduction of taxes, with the balance paid on submission of proof of disbursement. Statutory dues like PF and ESI are also deposited by the vendors. Thus, the assessee follows a structured process to source, utilize and monitor manpower

Instakart Services Private Limited, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 496/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

payroll register is prepared. Salaries are released through the vendor after deduction of taxes, with the balance paid on submission of proof of disbursement. Statutory dues like PF and ESI are also deposited by the vendors. Thus, the assessee follows a structured process to source, utilize and monitor manpower

Aban Offshore Limited, Chennai vs. DCIT, Chennai

In the result, the appeal of the assessee in ITA

ITA 1381/CHNY/2025[2017-18]Status: DisposedITAT Chennai16 Dec 2025AY 2017-18

Bench: Hon’Ble Shri Inturi Rama Rao & Before Hon’Ble Shri Manu Kumar Giriआयकर अपील सं./Ita No.1380 & 1381/Chny/2025 Assessment Years: 2013-14 & 2017-18 Aban Offshore Limited, Deputy Commissioner Of Income No.113, Janpriya Crest, Tax, Pantheon Road, Egmore, Corporate Circle-1(1), Chennai- 600 008. Chennai. [Pan: Aaaca3012H] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Ms.Vinitha, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Arv Sreenivasan, Cit सुनवाई की तारीख/Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 16.12.2025 आदेश / O R D E R Per Bench : These Appeals Filed By The Assessee-Company Directed Against The Orders Of The Assistant Commissioner Of Income Tax, Corporate Circle-1(1), Chennai Passed U/S 143(3) R.W.S. 254 Of The Income Tax Act-1961 Dated 30.03.2025 & 31.03.2025 For The Assessment Years 2013-14 & 2017-18 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Two Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order.

For Appellant: Ms.Vinitha, AdvocateFor Respondent: Mr.ARV Sreenivasan, CIT
Section 13Section 143(3)Section 31Section 7

therefore will be effective from the date on which I&B Code has come into effect; and (iii) Consequently all the dues including the statutory dues owed to the Central Government, any State Government or any local authority, if not part of the resolution plan, shall stand extinguished ... therefore will be effective from the date on which I&B Code has come into effect; 102.3. Consequently, all the dues including the statutory dues owed to the Central Government, any State Government or any Page - 5 - of 8 ITA No.1380 & 1381 /Chny/2025 local authority, if not part

Aban Offshore Limited, Chennai vs. DCIT, Chennai

In the result, the appeal of the assessee in ITA

ITA 1380/CHNY/2025[2013-14]Status: DisposedITAT Chennai16 Dec 2025AY 2013-14

Bench: Hon’Ble Shri Inturi Rama Rao & Before Hon’Ble Shri Manu Kumar Giriआयकर अपील सं./Ita No.1380 & 1381/Chny/2025 Assessment Years: 2013-14 & 2017-18 Aban Offshore Limited, Deputy Commissioner Of Income No.113, Janpriya Crest, Tax, Pantheon Road, Egmore, Corporate Circle-1(1), Chennai- 600 008. Chennai. [Pan: Aaaca3012H] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Ms.Vinitha, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Arv Sreenivasan, Cit सुनवाई की तारीख/Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 16.12.2025 आदेश / O R D E R Per Bench : These Appeals Filed By The Assessee-Company Directed Against The Orders Of The Assistant Commissioner Of Income Tax, Corporate Circle-1(1), Chennai Passed U/S 143(3) R.W.S. 254 Of The Income Tax Act-1961 Dated 30.03.2025 & 31.03.2025 For The Assessment Years 2013-14 & 2017-18 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Two Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order.

For Appellant: Ms.Vinitha, AdvocateFor Respondent: Mr.ARV Sreenivasan, CIT
Section 13Section 143(3)Section 31Section 7

therefore will be effective from the date on which I&B Code has come into effect; and (iii) Consequently all the dues including the statutory dues owed to the Central Government, any State Government or any local authority, if not part of the resolution plan, shall stand extinguished ... therefore will be effective from the date on which I&B Code has come into effect; 102.3. Consequently, all the dues including the statutory dues owed to the Central Government, any State Government or any Page - 5 - of 8 ITA No.1380 & 1381 /Chny/2025 local authority, if not part

Dbg Leasing and Housing Ltd., New Delhi vs. ITO-7(1), New Delhi

In the result, the Assessee’s appeal is dismissed

ITA 8308/DEL/2019[2008-09]Status: DisposedITAT Delhi15 Dec 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri Krinwant Sahayasstt. Year : 2008-09 Dbg Leasing & Housing Ltd., Vs Ito, Ward 7(1), New Delhi C-88, Gali No. 8, Jyoti Colony, Shahdara, Delhi – 110 032 (Pan: Aaacd0473F) (Appellant) (Respondent) Appellant By : Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr

For Appellant: Shri Ved Jain, Adv. & Ms. Uma Upadhyay, CAFor Respondent: Ms. Harpreet Kaur Hansra, SR. DR
Section 147Section 29ASection 30(2)Section 31(1)

corporate debtor and its employees, shareholders of the corporate debtor, creditors including the Central Government, any State Government or any local authority to whom statutory dues are owed, Successful Resolution Applicant and other stakeholders involved. In view of the above, I.A. 6308/ND/2023 stands allowed ... Private Limited vs. Edelweiss Asset Reconstruction Company Limited reported in (2021) 9 SCC 657 wherein, it has been held that all the claims, including statutory dues, predating the resolution plan’s approval, stand extinguished. Thus, taking into consideration this particular aspect of the matter, the statutory dues, including tax liabilities

Tejasvi Singh, Deputy Commissioner of Income Tax vs. Amtek Transportation Systems Ltd, Haryana

In the result, the appeal filed by the Revenue is dismissed

ITA 1282/DEL/2024[2021-22]Status: DisposedITAT Delhi05 Dec 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmadcit, Vs. Amtek Transportation Systems Ltd., Delhi. Begampur Khatoula, Gurgaon Khandsa 104, Gurgaon – 122 004 (Haryana). (Pan : Aahca5047K) (Appellant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Revenue By : Shri Amit Jain, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 24.01.2024 For The Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 7.86 Crore Made On Account Of Discrepancy Found In The Sales Turnover Reflected In Form 26As Vis-A-Vis Gross Sales Reported In The Profit & Loss Account By Accepting The Additional Evidence Furnished By The Assessee Without Appreciating The Fact The Assessee Has Been Provided Sufficient Opportunity During The Assessment Proceedings To Furnish The Details In This Regard.

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Liabilities, as on 31st March 2021, comprised of, - (i) Personnel Expenses of Rs. 82.54 Lakh, (ii) Other Expenses Payable of Rs. 8.95 Lakh, (iii)Statutory Dues Payable of Rs. 15.02 Lakh, (iv) Capex Trade Payable of Rs. 1.70 Crore, and (v) Other liabilities of Rs. 97.08 Crore. The appellant ... head wise details and the relevant ledgers, viz. ledgers of Salary Payable, GWR Payable, Auditors Expenses Payable, Other Expenses payable etc. In respect of Statutory Dues Payable, the appellant has clarified that addition during the year under this head was to the tune of Rs. 5,89,109/- only

ACIT, New Delhi vs. M/S. Kct Papers Ltd., New Delhi

In the result, grounds raised by the revenue are dismissed

ITA 3380/DEL/2014[2008-09]Status: DisposedITAT Delhi05 Dec 2025AY 2008-09

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 391

allowed to the assessee even if the conditions of amalgamation and demerger are not satisfied. Another contention of the A.O. that since statutory dues like stamp duty have been discharged by the assessee, and has not claimed waiver thereof, seems totally absurd and arbitrary. 12 As rightly pointed

Asia Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, all the three appeals are allowed partly

ITA 6353/MUM/2017[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Kalpesh Unadkat &For Respondent: Mr. Rajesh Kumar Yadav, CIT-DR
Section 143(3)Section 14A

assessee was merely an investment company entitled to deduction only for expenses necessary for the upkeep of its corporate structure (such as audit fees, statutory dues, and ROC- related charges), the Assessing Officer concluded that the impugned expenditure had been incurred not for the assessee's business, but for managing