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

80J. In our view, since the\n18\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back in 1948 by the\nPrivy Council in CIT v. Raja Bahadur

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

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

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

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

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

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

RAM SHARAN KHAJANI DEVI MEMORIAL CHARITABLE SOCIETY,DELHI vs. ITO, WARD-35(1), DELHI

Accordingly, appeal filed by the assessee is allowed

Bench: Shri Rama Kanta Panda[Assessment Year: 2017-18

Charitable Society Delhi High Court in the case of CIT Vs. Web Commerce (India) (P) Ltd. (supra), has held that provisions of Section 10B(5) are directory and not mandatory and once the audit report is filed before the framing of the assessment, requirement of the provision stands complied. Relevant observation of the Hon’ble High Court reads as under