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“Section 2(24)”

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

The decision most relied on for Section 2(24) is CIT v. AIMIL Ltd. (321 ITR 508), cited in 1,629 judgments on BharatTax.

Leading authorities on Section 2(24)

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).

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. 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.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

CIT v. Ponni Sugars & Chemicals Ltd.
306 ITR 392 · 2008 · Supreme Court
577
citing judgments

The "Purpose Test" determines whether an incentive or subsidy is a capital or revenue receipt for income tax purposes. If the incentive's purpose is to enable an assessee to set up a new industry or make investments in capital assets, it is a capital receipt and not taxable.

CIT v. Gujarat State Road Transport Corpn
41 Taxmann.com 100 · 2014 · High Court
540
citing judgments

Employees' contributions to provident fund or other welfare funds are deductible under section 36(1)(va) only if paid by the due date specified in the respective welfare fund enactments, and section 43B does not extend this period to the income tax return filing due date under section 139(1).

Judgments citing Section 2(24)

Tirupur South Rotary Educational Trust, Tirupur vs. The ACIT, Exemtions, Coimbatore

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

ITA 1107/CHNY/2024[2022-23]Status: DisposedITAT Chennai18 Sept 2024AY 2022-23

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1107/Chny/2024 िनधा"रण वष"/Assessment Year: 2022-23 V. Tirupur South Rotary – The Acit (Exemptions), Educational Trust, Coimbatore. South Rotary Hall, Nataraj Theatre Road, Tirupur-641 604. [Pan: Aabtt 7879 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. S. Sridhar, Adv. (Erode)For Respondent: Ms. R. Anita, Addl.CIT
Section 11Section 11(5)Section 119(2)(b)Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 2(24)(iia)Section 44A

section 11 which includes section 11(5). Therefore, the receipt through corpus donation is chargeable to tax as per the provision of section 2(24)(iia) and benefit of section 11 is not allowable. The case laws relied upon by appellant are in respect of revenue receipt and expenditure

ACIT Corp Circle 1 (1), Chennai vs. M/S Amtex Info Solutions Pvt Ltd, Chennai

In the result, the appeal filed by the Revenue is partly allowed

ITA 546/CHNY/2018[2013-14]Status: DisposedITAT Chennai12 Sept 2024AY 2013-14

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.546/Chny/2018 िनधा;रण वष; /Assessment Year: 2013-14 The Asst. Commissioner Of Income M/S. Amtex Info Solutions Pvt. Tax, Vs. Ltd., Plot No.54, 27Th Street, Corporate Circle-1(1), Chennai. Sri Krishna Nagar, Maduravoyal, Chennai – 600 095. [Pan: Aaica 6676K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथH की ओर से/ Assessee By : None JkथH की ओर से /Revenue By : Shri G. Suresh. Jcit सुनवाई की तारीख/Date Of Hearing : 02.07.2024 घोषणा की तारीख /Date Of Pronouncement : 13.09.2024 आदेश / O R D E R Per Jagadish, A.M : Aforesaid Appeal Filed By The Revenue For Assessment Year (Ay) 2013-14 Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-, Chennai [Hereinafter “Cit(A)”] Dated 12.12.2017 In The Matter Of Assessment Framed By The Assessing Officer [A.O] U/S. 143(3) Of The Act On 30.03.2016. :- 2 -:

For Appellant: NoneFor Respondent: Shri G. Suresh. JCIT
Section 143(3)Section 2(22)Section 2(22)(e)Section 2(24)Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 43B

National Travel Services cited supra. 3.1 The learned CIT(A) erred in deleting the disallowance made u/s.36(1) (va) read with section 2(24)(x) of the I.T. Act to the tune of Rs.1,05,750/-, towards non-payment of employees part of contribution ... dates, as specified in the respective Acts, and such unpaid employees contributions are liable for disallowance U/s. 36(1)(va) read with section 2(24) (x) of the Act?. 3.3 The learned CIT(A) erred in not appreciating the fact that the decision of the Hon'ble Supreme Court

Norben Tea & Exports Ltd., Kolkata vs. DCIT, Cir. 4(2), Kolkata

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

ITA 833/KOL/2024[2014-15]Status: DisposedITAT Kolkata11 Sept 2024AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra]

Section 147Section 148Section 14ASection 36(1)(va)Section 37(1)

Provident Fund Act. The contribution works out to Rs. 13,30,802/- which was deposited later and in view of the provision of section 2(24)(x) read with Section 36(1)(va) a sum of Rs. 13,30,802/- was treated as the assessee’s income and added back ... unless the amount is deposited in time, it will not be allowed as a deduction u/s 36(1)(va) of the Act. Section 2(24)(x) defines the income wherein any sum received by the assessee from his employees as contributions to any provident fund or superannuation fund

Shell International Petroleum Company Limited, Mumbai vs. DDIT(It)-2(1), Mumbai

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

ITA 1253/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Sept 2024AY 2009-10

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am M/S. Shell International Petroleum Dy. Director Of Income Tax Company Limited (International Taxation)-2(1) C/O. Bsr & Co. Llp, 1St Floor, Room No. 120, Scindia House, Vs. Lodha Excelus, Apollo Mills Ballard Estate, N.M. Road, Compound, N.M. Joshi Marg, Mumbai-400 038 Mahalaxmi, Mumbai-400 011 Pan/Gir No. Aaics 0357 B (Assessee) : (Respondent) Assessee By : Shri J. D. Mistry/ Madhur Agarwal/Ms. Reema Grewal Respondent By : Smt. Shaileja Rai Date Of Hearing : 13.06.2024 Date Of Pronouncement : 10.09.2024

For Appellant: Shri J. D. Mistry/For Respondent: Smt. Shaileja Rai
Section 143(2)Section 143(3)Section 144C(5)Section 2(24)Section 271(1)(c)

services, etc. which are not liable to be taxed in India and would not be categorized as ‘income of the assesse’ as per section 2(24) of the Act. Further, the ld. AR contended that the services are not been made available to the Indian entity and would

Aket Foundation, Pune vs. Commissioner of Income Tax, Exemption, Pune

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

ITA 1223/PUN/2023[-]Status: DisposedITAT Pune09 Sept 2024

Bench: Shri R. K. Panda & Ms Astha Chandraaket Foundation Cit Exemption, Pune Shop No.3, Sidhi Apartment, Building No.20, Shindenagar, Vs. Bavdhan Khurd, Bavdhan B O Puen – 411021 Pan: Aavca1058Q (Appellant) (Respondent) Assessee By : Smt. Deepa Khare Department By : Shri Keyur Patel, Cit-Dr Date Of Hearing : 20-08-2024 Date Of Pronouncement : 09-09-2024 O R D E R Per R.K. Panda, Vp :

For Appellant: Smt. Deepa KhareFor Respondent: Shri Keyur Patel, CIT-DR
Section 12ASection 12A(1)(ac)

trust. Even in the financial statements also, the payment to these persons has been shown as ‘commission’. He analyzed the relevant provisions of section 2(24) of the Act, the term ‘voluntary’, etc. Rejecting the various explanations given by the assessee, the CIT(Exemption) held that the genuineness

Economic Explosives Limited, Nagpur vs. National E Assessment Centre, New Delhi

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 242/NAG/2023[2018-19]Status: DisposedITAT Nagpur09 Sept 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

under section 115JB of the Act specifically when such receipts are capital receipts and did not fall within the definition of “income” under section 2(24) of the Act. The specific finding of the High Court reads as under: “Held, dismissing the appeal, (i) that according to the West Bengal ... capital receipts" and not "income" liable to be taxed in the assessment year 2010-11. The amendment to the definition of income under section 2(24) wherein sub-clause (xviii) has been inserted including "subsidy" for the first time by the Finance Act, 2015 with effect from April

Economic Explosives Limited, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 1 (2), Nagpur

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 177/NAG/2022[2017-18]Status: DisposedITAT Nagpur09 Sept 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

under section 115JB of the Act specifically when such receipts are capital receipts and did not fall within the definition of “income” under section 2(24) of the Act. The specific finding of the High Court reads as under: “Held, dismissing the appeal, (i) that according to the West Bengal ... capital receipts" and not "income" liable to be taxed in the assessment year 2010-11. The amendment to the definition of income under section 2(24) wherein sub-clause (xviii) has been inserted including "subsidy" for the first time by the Finance Act, 2015 with effect from April

M/S. Bindhya Bashini Traders, Liluah, Howrah vs. D.C.I.T., Circle - 32, Kolkata

The appeal of the assessee is hereby dismissed and the order of the Ld

ITA 1144/KOL/2024[2019-2020]Status: DisposedITAT Kolkata09 Sept 2024AY 2019-2020

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2018-19 & Assessment Year: 2019-20 M/S Bindhya Bashini Traders, Circle – 32, Kolkata, 268/10, Narayani Complex, Aayakar Bhawan, 110, Vs G.T. Road, Liluah - 711204 Middletown Row, (Pan: Aagfb2388A) Kolkata - 700071 (Appellant) (Respondent)

For Appellant: Miraj D. Shah, A.RFor Respondent: Amuldeep Kaur, JCIT
Section 139(1)Section 143(1)Section 154Section 250Section 36(1)(va)

specifically inserted by the Finance Act, 1987, w.e.f. 01- 04-1988. Through the same amendment, by Section 3(b), Section 2(24) – which defines various kinds of "income" – inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received ... separately dealt with in different clauses of Section 36 (1). All these establish that Parliament, while introducing Section 36(1)(va) along with Section 2(24)(x), was aware of the distinction between the two types of contributions. There was a statutory classification, under the IT Act, between

M/S. Bindhya Bashini Traders, Liuah, Howrah vs. DCIT, Circle - 32, Kolkata

The appeal of the assessee is hereby dismissed and the order of the Ld

ITA 1143/KOL/2024[2018-2019]Status: DisposedITAT Kolkata09 Sept 2024AY 2018-2019

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2018-19 & Assessment Year: 2019-20 M/S Bindhya Bashini Traders, Circle – 32, Kolkata, 268/10, Narayani Complex, Aayakar Bhawan, 110, Vs G.T. Road, Liluah - 711204 Middletown Row, (Pan: Aagfb2388A) Kolkata - 700071 (Appellant) (Respondent)

For Appellant: Miraj D. Shah, A.RFor Respondent: Amuldeep Kaur, JCIT
Section 139(1)Section 143(1)Section 154Section 250Section 36(1)(va)

specifically inserted by the Finance Act, 1987, w.e.f. 01- 04-1988. Through the same amendment, by Section 3(b), Section 2(24) – which defines various kinds of "income" – inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received ... separately dealt with in different clauses of Section 36 (1). All these establish that Parliament, while introducing Section 36(1)(va) along with Section 2(24)(x), was aware of the distinction between the two types of contributions. There was a statutory classification, under the IT Act, between

Sanjiv Prakashan, Jaipur vs. ACIT, Circle-1, Jaipur

ITA 9/JPR/2023[2020-2021]Status: DisposedITAT Jaipur09 Sept 2024AY 2020-2021
For Appellant: Sh. Anil Goyal, CAFor Respondent: Sh. Anoop Singh (Addl.CIT)
Section 139(1)Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 43B

case. 2. The learned AO has erred in disallowing a sum of Rs. 16,46,879/- under section 36(1)(va) read with section 2(24)(x) and the learned CIT(A) has erred in confirming the said disallowance. 3. That the assessee craves his right to add, alter, amend ... specifically inserted by the Finance Act,1987, w.e.f. 01-04-1988. Through the same amendment, by Section 3(b), Section 2(24) which defines various kinds of “income” – inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received

Shell Information Technologies International Bv, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumba

In the result, the assessee’s appeal is partly allowed

ITA 4711/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrishell Information V/S. Dcit (International Tax)- Technology International बनाम 4(2)(1), Bv 17Th Floor, Room No. 1708, C/O. Bsr & Co. Llp, Air India Building, 2Nd Floor, Lodha Excelus, Nariman Point, Apollo Mills Compound, Mumbai-400021 N.M. Joshi Marg, Mahalakshmi, Mumbai-400011 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics9091A Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Madhur AgarwalFor Respondent: Smt. Shaileja Rai
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 234ASection 234BSection 234C

only arrangement and the receipts were reimbursements being in the nature of cost allocation without markup and hence does not constitute 'income' under section 2(24) of the Act; Receipts from Key Application Service ('KAS') providers and Shell group entities towards software access treated as 'royalty' under

Income Tax Officer, Ward-6(2), Jaipur, Ncr Building, Statue Circle Jaipur vs. Vasudev Hemrajani, Arjun Nagar, Jaipur

The appeal of the revenue stands dismissed

ITA 634/JPR/2024[2020-2021]Status: DisposedITAT Jaipur05 Sept 2024AY 2020-2021

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anil Dhaka, CIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250Section 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Padmavati Agrico (India) Pvt Ltd, Ajmer vs. ACIT Circle - 1, Ajmer

In the result, the appeal of the assessee is allowed

ITA 702/JPR/2023[2010-11]Status: DisposedITAT Jaipur05 Sept 2024AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal (CA)For Respondent: Sh. Anoop Singh (Addl. CIT)
Section 143Section 147

under— “8. Regarding Question B: (a) We find ……………………………………………………………… ……. (b) It is further pertinent to note that the definition of income as provided under section 2(24) of the Act at the relevant time did not define as income any consideration received for issue of share in excess of its fair

Assistant Commissioner of Income Tax, Chennai vs. Buhari Holdings Privae Limited, Chennai

Appeal of the assessee is allowed

ITA 325/CHNY/2024[2010-11]Status: DisposedITAT Chennai29 Aug 2024AY 2010-11

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.325/Chny/2024 (िनधा"रणवष" / Assessment Year: 2010-2011) The Assistant Commissioner Of Vs. M/S. Buhari Holdings Pvt. Ltd, Income Tax, No.4, Buhari Towers, Corporate Circle 1(2) Moores Road, Chennai. Chennai 600 006. [Pan Aaacb 2679M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. G. Baskar, Advocate ""यथ" क" ओर से /Respondent By : Shri Arv Srinivasan, Irs, Addl Cit. सुनवाई क" तार"ख/Date Of Hearing : 20.06.2024 घोषणा क" तार"ख /Date Of Pronouncement : 29.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri ARV Srinivasan, IRS, Addl CIT
Section 143(3)Section 147Section 14ASection 28

assessee during the financial year in question have to be regarded as capital receipts, and, therefore, are not income within meaning of section 2(24) of the Income Tax Act."(Emphasis by underlining supplied by us). This clearly shows, as is the settled law that a capital receipt, in principle ... specific provisions under the Income Tax Act which provide hat certain capital receipts can also be considered as income, such as under section 2 (24)(vi) of the Act which covers "any capital gains chargeable under section 45", but right now we are confined to normal connotations of the expression

Dilip Verma, Gurugram vs. Income Tax Officerward1(4)Gurgaon, Gurgaon

In the result, appeal of the assessee is dismissed

ITA 1285/DEL/2024[2019-20]Status: DisposedITAT Delhi29 Aug 2024AY 2019-20

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshita Nos. 1284 & 1285/Del/2024 (Assessment Years : 2018-19 & 2019-20) Dilip Verma Vs. Ito 902, Ramses Tower, Ward – 1(4), Omaxe The Nile, Sector-49, Gurgaon Sohna Road, Gurugram Haryana – 122 018 Pan No. Aahpv 4660 L (Appellant) (Respondent) Assessee By -Na- Revenue By Ms. Harpreet Kaur, Sr. D.R. Date Of Hearing: 07.08.2024 Date Of Pronouncement: 29.08.2024 Order Per M. Balaganesh:

Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee

Dilip Verma, Gurugram vs. Income Tax Officer, Ward -1(4), Gurgaon

In the result, appeal of the assessee is dismissed

ITA 1284/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Aug 2024AY 2018-19

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshita Nos. 1284 & 1285/Del/2024 (Assessment Years : 2018-19 & 2019-20) Dilip Verma Vs. Ito 902, Ramses Tower, Ward – 1(4), Omaxe The Nile, Sector-49, Gurgaon Sohna Road, Gurugram Haryana – 122 018 Pan No. Aahpv 4660 L (Appellant) (Respondent) Assessee By -Na- Revenue By Ms. Harpreet Kaur, Sr. D.R. Date Of Hearing: 07.08.2024 Date Of Pronouncement: 29.08.2024 Order Per M. Balaganesh:

Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee

Universal Tractor Holding Llc, Usa vs. DCIT, International Taxation Circle 3(1)(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 2216/DEL/2022[2019-20]Status: HeardITAT Delhi28 Aug 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Durgesh Shankar, AdvFor Respondent: Ms. Banita Devi Neorem, CIT-DR
Section 143(3)Section 49

wherein it was observed that being the case, the amount received towards compensation/damage cannot fit in to the definition of income as per section 2(24) r.w.s. 4 of the Act. The ld. AR further relied on the judgment of Hon'ble Jurisdictional High Court in the case of Amar

Parry Engineering & Electronics Ltd., Ahmedabad vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

In the result the appeal of the assessee is dismissed

ITA 464/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad27 Aug 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Suresh Gandhi, C.AFor Respondent: Shri H. Phani Raju, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 263Section 36(1)(va)Section 80I

आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ “ए“, अहमदाबाद

Hyundai Motor India Limited, Kancheepuram vs. DCIT Non Corp Circle 8(1), Chennai

In the result, appeal filed by the assessee is dismissed

ITA 609/CHNY/2024[2016-17]Status: DisposedITAT Chennai21 Aug 2024AY 2016-17

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 609/Chny/2024 िनधा"रणवष" / Assessment Year: 2016-17 Deputy Commissioner Of Income M/S. Hyundai Motor India V. Tax, Limited, Non Corporate Circle – 8(1), Plot No. H-1, Sipcot Chennai – 600 034. Industrial Park, Irungatukottai, Sriperumbudurtaluk, Kancheepuram District, Tamil Nadu – 602 117. [Pan: Aaach-2364-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nanda Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 घोषणा क" तार"ख/Date Of Pronouncement : 21.08.2024 आदेश /O R D E R

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Shri. V. Nanda Kumar, CIT
Section 115JSection 143(3)Section 14ASection 250Section 43BSection 92

neither the AO nor the CIT(A) has dealt with the taxability of the subsidy by taking into consideration the amendment made to section 2(24)(xviii) of the Act. However, this Hon’ble ITAT in Assessee’s own case in IT(TP)A No.53/Chny/2022 vide order dated ... held that post amendment to section 2(24)(xviii) of the Act, subsidy will have to be treated as revenue receipt chargeable to tax and accordingly dismissed the appeal of the Appellant for AY 2018-19 on this particular ground. Since the subject AY 2016-17 is the first year

Bsnl Employees Co-Operative Credit Society Limited, Hubli vs. Assistant Commissioner of Income Tax, Circle-3(1), Hubli

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

ITA 1003/BANG/2024[2012-13]Status: DisposedITAT Bangalore21 Aug 2024AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2012-13

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri V. Parithivel, Jt. CIT(DR)(ITAT), Bengaluru
Section 234Section 234BSection 250Section 57Section 80P

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY