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“Section 2(24)”

Section References (mined)Section 2Section 2(24)1,946 judgments

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

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

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

share premium received by the Respondent-Assessee is without any basis and contrary to provisions of Section 56(2)(viib) read with Section 2(24)(xvi) of the Act. Further, the AO held that the Respondent-Assessee has failed to submit any basis of projection. He also held the view

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

incentives 'Interest subsidy' and 'Power subsidy' is a 'capital receipt' and does not fall within the definition of 'Income' under Section 2(24) of Income Tax Act, 1961 and when a receipt is not on in the character of income it cannot form part of the book profit under Section

UDAYA SOUHARDA CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(1), BANGALORE

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

ITA 2472/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian, JCIT (DR)
Section 57Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

specified activities in section 80P(2) of the Act, would be eligible for deduction. The word "income" has been defined under section 2(24)( i) of the Act to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically "business profits" into the definition

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 2081/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

specified activities in section 80P(2) of the Act, would be eligible for deduction. The word "income" has been defined under section 2(24)( i) of the Act to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically "business profits" into the definition

SREE CAUVERY SOUHARDA CREDIT SAHAKARI SANGHA NIYAMITHA,BENGALURU vs. INCOME TAX OFFICER WARD 1(1)(1), BENGALURU

ITA 1854/BANG/2025[2018-19]Status: DisposedITAT Bangalore12 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Smt. Sumana, CAFor Respondent: Shri Subramanian, JCIT (DR
Section 10Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

specified activities in section 80P(2) of the Act, would be eligible for deduction. The word "income" has been defined under section 2(24)( i) of the Act to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically "business profits" into the definition

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

goods manufactured by it claimed 100% exemption and filed returned income at NIL. 2.1 In view of insertion of clause (xviii) to section 2(24) of the Act introduced by Finance Act, 2015, the AO held that contention of assessee that this was just a notional entry as explained vide ... Rs.5,15,25,900/- claimed as capital receipt exempt u/s 10 of the Act is taxed as revenue receipt in view of section 2(24)(xviii) of the Act and accordingly added to the income of assessee.” 14.3. Coordinate Bench considered the amendment brought to section 2(24)(xviii) which

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

goods manufactured by it claimed 100% exemption and filed returned income at NIL. 2.1 In view of insertion of clause (xviii) to section 2(24) of the Act introduced by Finance Act, 2015, the AO held that contention of assessee that this was just a notional entry as explained vide ... Rs.5,15,25,900/- claimed as capital receipt exempt u/s 10 of the Act is taxed as revenue receipt in view of section 2(24)(xviii) of the Act and accordingly added to the income of assessee.” 14.3. Coordinate Bench considered the amendment brought to section 2(24)(xviii) which

M/S. KAMAKSHI JUTE INDUSTRIES LIMITED,KOLKATA vs. ACIT, CIRCLE 1(1),, KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 3151/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Mar 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(2)Section 143(3)Section 2(24)(x)Section 250Section 36(1)(va)

vehemently wrong and unjustified in confirming the addition of Rs. 31,91,258/- made by the Ld. A.O. invoking the provision of section 2(24)(x) r.w.s. 36(1)(va) for the Employees the alleged delay in depositing Contribution to PF & ESI under the relevant Act. Relief Claimed: the addition ... besides interest of ₹7,945/- thereon. Accordingly, the Ld. AO disallowed the above sum u/s 36(1)(va) r.w. section 2(24)(x) of the Act on the ground that the payments were made after the due date of depositing it to the Government account and the same

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

DEPUTY COMMISSIONER OF INCOME TAX-2(2)(1), MUMBAI, AAYAKAR BHAVAN, CHURCHGATE vs. MUMBAI INTERNATIONAL AIRPORT LIMITED, MUMBAI

ITA 7035/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15
Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

collections. The Co-ordinate Bench\naccordingly held that PSF-SC collected by the assessee cannot be\ncharacterised as income within the meaning of section 2(24) read\nwith section 5 of the Act.\n60. Since the facts of the present year are identical and the\nRevenue has not brought

MUMBAI INTERNATIONAL AIRPORT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

income by overriding title, had held that the PSF-SC collected by the assessee cannot be characterised as income within the meaning of section 2(24) read with section 5 of the Act. Following the decision of the Co-ordinate Bench in the assessee’s own case for earlier assessment ... collections. The Co-ordinate Bench accordingly held that PSF-SC collected by the assessee cannot be characterised as income within the meaning of section 2(24) read with section 5 of the Act. 60. Since the facts of the present year are identical and the Revenue has not brought

DCIT-CIRCLE 1(3)(1), MUMBAI vs. DIEBOLD INDIA PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue and the\nCOs filed by the assessee stand dismissed

ITA 5508/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Mar 2026AY 2013-14
Section 195Section 250Section 40Section 9(1)(vi)

source outside India.\nSection 9(1)(viii) -Sum of Money: Income arising outside India, being any\nsum of money referred to in Section 2(24) (xvila), paid on or after 5 July,\n2019 by a resident to a non-resident/foreign company shall be deemed to\naccrue or arise

DCIT-CIRCLE 1(3)(1), MUMBAI vs. DIEBOLD INDIA PRIVATE LIMITED, MUMBAI

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

ITA 5507/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Mar 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 195Section 250Section 40Section 9(1)(vi)

source outside India. Section 9(1)(viii) -Sum of Money: Income arising outside India, being any sum of money referred to in Section 2(24) (xvila), paid on or after 5 July, 2019 by a resident to a non-resident/foreign company shall be deemed to accrue or arise ... India. Section 2(24) (xviia) includes in Income-any sum of money covered u/s. 56(2)(x) of the Act. However. Gift of any sum of money from relative shall not be liable for withholding tax obligation u/s. 195. Section 9(1)(i) - Income other than Interest / Royalty FTS/Salaries/Dividend

DCIT-CIRCLE 1(3)(1), MUMBAI vs. DIEBOLD INDIA PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue and the\nCOs filed by the assessee stand dismissed

ITA 5506/MUM/2025[2011-12]Status: DisposedITAT Mumbai09 Mar 2026AY 2011-12
Section 195Section 250Section 40Section 9(1)(vi)

source outside India.\nSection 9(1)(viii) -Sum of Money: Income arising outside India, being any\nsum of money referred to in Section 2(24) (xvila), paid on or after 5 July,\n2019 by a resident to a non-resident/foreign company shall be deemed to\naccrue or arise

DCIT-CIRCLE 1(3)(1), MUMBAI vs. DIEBOLD INDIA PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue and the\nCOS filed by the assessee stand dismissed

ITA 5505/MUM/2025[2010-11]Status: DisposedITAT Mumbai09 Mar 2026AY 2010-11
Section 195Section 250Section 40Section 9(1)(vi)

source outside India.\nSection 9(1)(viii) -Sum of Money: Income arising outside India, being any\nsum of money referred to in Section 2(24) (xvila), paid on or after 5 July,\n2019 by a resident to a non-resident/foreign company shall be deemed to\naccrue or arise

VALUELABS LLP,HYDERABAD vs. DCIT., CENTRAL CIRCLE 8(1), HYDERABAD

In the result, we uphold the order passed by the CIT(A) and\ndismiss the assessee's appeal

ITA 1609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Mar 2026AY 2020-21
For Appellant: \nShri P. Murali Mohan, CAFor Respondent: \nMs. U. Mini Chandran
Section 115BSection 143(3)Section 2(24)(xviii)Section 250Section 80

that the\nincome derived from the sale of RECs does not form part of 'business\nincome within the meaning of the proviso to Section 2(24)(xviii) of the\nAct, and therefore, the same cannot be taxed as business income at\nthe normal rate.\n6.\nThe Ld. CIT(A) erred

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