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“mercantile system of accounting”

ICDS & AccountingSection 145Section 1451,487 judgments

The decision most relied on for mercantile system of accounting is CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254), cited in 968 judgments on BharatTax.

Leading authorities on mercantile system of accounting

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

CIT v. Excel Industries Ltd.
358 ITR 295 · 2013 · Supreme Court
935
citing judgments

When an income or expenditure is revenue neutral across different assessment years, where any benefit derived is offset by a corresponding liability or reversal, no additional tax liability arises, particularly concerning income recognition under the mercantile system of accounting.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

Kedarnath Jute Mfg. Co. Ltd. v. CIT
82 ITR 363 · 1971 · Supreme Court
654
citing judgments

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

Calcutta Co. Ltd. v. CIT
37 ITR 1 · 1959 · Supreme Court
341
citing judgments

When following the mercantile system of accounting, provisions for liabilities made on a scientific and rational basis are allowable as deductions, even if their actual quantification and discharge are deferred to a future date.

United Commercial Bank v. CIT
240 ITR 355 · 1999 · Supreme Court
314
citing judgments

Liabilities accrued on a notional basis are allowable as deductions under the mercantile system of accounting even if their exact quantification or discharge is deferred to a future date or if the demand itself is disputed.

M.M.Aqua Technologies Limited v. CIT
436 ITR 582 · 2021 · Supreme Court
308
citing judgments

Amendments to tax law that impose new obligations or change existing legal positions apply prospectively, even if stated to be "for the removal of doubts." The judgment also clarifies that deductions under Section 43B are allowed only on actual payment, overriding the mercantile system of accounting.

Judgments citing mercantile system of accounting

Asst.Commissioner of Income Tax, TDS 2 1, Mumbai vs. Patel Engineering Limited, Mumbai

ITA 3065/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19
Section 194ASection 201

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

DCIT CC - 3(4), Mumbai vs. Patel Engineering Limited, Mumbai

ITA 3063/MUM/2024[2017]Status: DisposedITAT Mumbai31 Dec 2024
Section 194ASection 201

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

DCIT CC- 3(4), Mumbai vs. Patel Engineering Limited, Mumbai

ITA 3061/MUM/2024[2018]Status: DisposedITAT Mumbai31 Dec 2024
Section 194ASection 201

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

Patel Engineering Limited, Mumbai vs. DCIT-CC-3(4), Mumbai

ITA 2802/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19
Section 194ASection 201

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

Patel Engineering Limited, Mumbai vs. DCIT CC-3(4), Mumbai

In the result, appeals of the Revenue are dismissed, except for one ground no

ITA 2801/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Dec 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 194ASection 201

next assessment year i.e. A.Y.2018-19, the said expenses have bene incurred for the period pertaining to impugned assessment year. Since, assessee follows mercantile system of accounting; the said expenses are to be allowed in the year in which they pertained. Accordingly, the said claim of prior period expenses which

Bank of Maharashra, Pune vs. The Pr. Commissioner of Income Tax, Pune

In the result, the appeal filed by the assessee is allowed

ITA 682/PUN/2024[2018-19]Status: DisposedITAT Pune30 Dec 2024AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

For Appellant: Shri Ananthan and Mrs. Lalitha RameswaranFor Respondent: Shri Amol Khairnar, CIT-DR
Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 154Section 36(1)(viia)Section 40A(7)

banking company in which the public is substantially interested. It is governed by the Banking Regulation Act, 1949 and it regularly follows the mercantile system of accounting. The assessee filed its return of income on 29.09.2018 declaring total loss of Rs.1612,29,57,294/- under the normal provisions. The return

The DCIT, Circle-1(1), Now Circle-1(1)(1), Baroda vs. Gujarat State Electricity Corporation Ltd., Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 3164/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2011-12

Bench: DR. BRR Kumar (Vice President), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 28Section 37Section 43(1)

therefore same expenditure cannot be added back. The Assessing Officer has not accepted the submission of the assessee stating that assessee was following mercantile system of accounting in which the expenses related to the prior period were not an allowable expenses. Therefore, the prior period expenses amounting

Gujarat State Electricity Corporation Ltd., Baroda vs. The Dy.CIT, Circle-1(1), Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 3124/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2011-12

Bench: DR. BRR Kumar (Vice President), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 28Section 37Section 43(1)

therefore same expenditure cannot be added back. The Assessing Officer has not accepted the submission of the assessee stating that assessee was following mercantile system of accounting in which the expenses related to the prior period were not an allowable expenses. Therefore, the prior period expenses amounting

M/S. La Opala RG Ltd., Kolkata vs. D.C.I.T., Circle - 11(1) [Formerly JCIT, Range-12, Kolkata ]

In the result, the appeal of the assessee is partly allowed

ITA 1865/KOL/2024[2012-2013]Status: DisposedITAT Kolkata16 Dec 2024AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit, Circle 11(1) M/S La Opala Rg Ltd. Aaykar Bhavan, P-7, 8Th Floor, Premises No.803 & 804 Eco Centre, Em-4, Sector-V, Chowringhee Square, Vs. Kolkata-700091, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aaacl5569J Assessee By : Shri Ashok Kumar Tulsyan & Deepak Mundhra, Tanmoy Kar, Ars Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 21.11.2024 Date Of Pronouncement : 16.12.2024

For Appellant: Shri Ashok Kumar Tulsyan, &For Respondent: Shri Ruchika Sharma, DR
Section 133(6)Section 37

plus applicable taxes. The A.O on the basis of above facts has alleged that the appellant is following Mercantile system of Accounting and should have claimed the deduction of Rs. 20,00,000/-. Hence, on the basis of said allegation the A.O has concluded that the appellant has only paid

Dhoot Compack Private Limited, Ahmednagar vs. The Deputy Commissioner of Income Tax, Ahmednagar Circle, Ahmednagar

In the result, the appeal filed by the assessee is allowed

ITA 1549/PUN/2024[2014-15]Status: DisposedITAT Pune13 Dec 2024AY 2014-15

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Prasad S. Bhandari
Section 133(6)Section 143(3)Section 148

issued asking the appellant to show cause why profit of Rs.16,68,485/- should not be taxed when the appellant was following mercantile system of accounting. In response, appellant replied that profit of Rs. 7,26,485/ was notional profit and it was neither received nor accrued

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Cholan Auto Finance, Karur

In the result, both the appeal of the Revenue in ITA

ITA 1192/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 13. -9- ITA No.1155 ... alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 2.2 The Ld.CIT(A) failed

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Cholan Auto Finance, Karur

In the result, both the appeal of the Revenue in ITA

ITA 1191/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 13. -9- ITA No.1155 ... alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 2.2 The Ld.CIT(A) failed

Cholan Auto Finance, Karur vs. Deputy Commissioner of Income Tax, Central Circle 2, Trichy, Tiruchirappalli

In the result, both the appeal of the Revenue in ITA

ITA 1156/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 13. -9- ITA No.1155 ... alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 2.2 The Ld.CIT(A) failed

Cholan Auto Finance, Karur vs. Deputy Commissioner of Income Tax (Central Circle 2), Trichy, Tiruchirappalli

In the result, both the appeal of the Revenue in ITA

ITA 1155/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.1155 & 1156/Chny/2024 िनधा"रणवष"/Assessment Year:2018-2019 M/S. Cholan Auto Finance, Vs. The Deputy Commissioner Of Income Tax, 43, Padma Tower, 3Rd Floor, Central Circle 2, Covai Road, Trichy. Karur 639 002. आयकरअपीलसं./Ita Nos.1191 & 1192/Chny/2024 िनधा"रणवष"/Assessment Year:2018-2019 The Assistant Commissioner Of M/S. Cholan Auto Finance, Income Tax, 43, Padma Tower, 3Rd Floor, Vs Central Circle 2, . Covai Road, Trichy. Karur 639 002. [Pan : Aagfc 1043B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri N.V.Balaji, Advocate Department By : Shri. R. Clement Ramesh Kumar, Irs, Cit. सुनवाईक"तारीख/Date Of Hearing : 23.10.2024 घोषणाक"तारीख/Date Of Pronouncement : 13.12.2024 आदेश /O R D E R Per Bench: These Cross Appeals Are Arising Out Of The Orders Of The Commissioner Of Income Tax (Appeals) – 19, Chennai [Hereinafter

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. ITA No.1155, 1156, 1191 & 1192/Chny/2024 ... alternative submission and sustaining only a sum of Rs.7,04,22,819/- as interest income, without appreciating that the assessee is following mercantile system of accounting and the interest receivable mentioned in the seized documents is also considered to be income of the assessee. 2.2 The Ld.CIT(A) failed

Ashwin S. Mehta (Legal Heir of Late Rasila S. Mehta), Mumbai vs. ACIT, CC- 4(1), Mumbai

Appeal is allowed for

ITA 295/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Dec 2024AY 2020-21

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Dharmesh ShahFor Respondent: Dr. P. Daniel (Spl. Counsel for the Department)
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 250Section 3(2)Section 68

noted that the assessee has disclosed the loan taken for the purchase of investment. The assessee is consistently following mercantile system of accounting which is apparent even from the assessment order of A.Y. 1990-91 as well as from the impugned assessment year. The order ... apparent that the assessee is liable to pay interest on the amount outstanding. Therefore the liability towards interest got accrued. Under the mercantile system of accounting interest is deductible when it has accrued. This also proves that there was an agreement, may be oral, to pay the interest

Orchid Pharma Limited, Chennai vs. DCIT, Chennai

In the result, the appeal of the assessee is partly allowed

ITA 73/CHNY/2017[2012-13]Status: DisposedITAT Chennai11 Dec 2024AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.73/Chny/2017 निर्ाारण वर्ा /Assessment Years: 2012-13

For Appellant: Shri B.Ramakrishnan, FCA & ShriFor Respondent: Shri A.Sasikumar, CIT
Section 143(3)Section 92A(2)(i)

person to whom payment for expenditure has to be made and that the accounting practice followed by the assessee was contrary to the mercantile system of accounting. The assessee had also reportedly not made any TDS on the amounts of provision. The Ld. Counsel for the assessee argued that appellant

Flsmidth Private Limited, Chennai vs. PCIT- 1, Chennai

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

ITA 1636/CHNY/2024[2014-15]Status: DisposedITAT Chennai10 Dec 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1636/Chny/2024 िनधा:रण वष: /Assessment Year: 2014-15 M/S. Flsmidth Pvt. Ltd., The Principal Commissioner Of No.34, Egatoor, Kelambakkam Vs. Income Tax-1, Rajiv Gandhi Salai, Chennai. Chennai – 603 103. [Pan: Aaacf 4997N]

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri Nilay Baran Som, CIT
Section 143(3)Section 147Section 14ASection 263

this being the amount reduced from the billed amount which the assessee had already charged its clients. Since the assessee follows mercantile system of accounting, income :- 4 -: accrues the moment bill is raised by the assessee. When the bill raised by the assessee is served on the client, liability

Indus Towers Limited (Formerly Known As Bharti Infratel Ltd and As Successor in Interest of Erstwhile Indus Tower Ltd), Gurugram, Haryana vs. DCIT, Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2762/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

assessee excludes such SRO cost from the cost of fixed assets and therefore does not claim any tax depreciation thereon. Following the mercantile system of accounting and the law enunciated by the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation ... arise, and it was entitled for deduction of expenses which it was supposed to incur for filling those pits, as it was following mercantile system of accounting. 5.6 Similarly the Hon‟ble Madras High Court in the case of Vedanta vs JCIT in Tax Case (Appeal) Nos. 2117 to 2119/2008

ACIT, Circle 10, New Delhi vs. Indus Tower Limited, Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 2212/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

assessee excludes such SRO cost from the cost of fixed assets and therefore does not claim any tax depreciation thereon. Following the mercantile system of accounting and the law enunciated by the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation ... arise, and it was entitled for deduction of expenses which it was supposed to incur for filling those pits, as it was following mercantile system of accounting. 5.6 Similarly the Hon‟ble Madras High Court in the case of Vedanta vs JCIT in Tax Case (Appeal) Nos. 2117 to 2119/2008

Indus Towers Ltd., Gurgaon vs. DCIT Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1962/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

assessee excludes such SRO cost from the cost of fixed assets and therefore does not claim any tax depreciation thereon. Following the mercantile system of accounting and the law enunciated by the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation ... arise, and it was entitled for deduction of expenses which it was supposed to incur for filling those pits, as it was following mercantile system of accounting. 5.6 Similarly the Hon‟ble Madras High Court in the case of Vedanta vs JCIT in Tax Case (Appeal) Nos. 2117 to 2119/2008