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Documents citing Kalyani Steels Ltd. vs Deputy Commissioner Of Income Tax on 14 March, 1997

Core Health Care Ltd. vs Deputy Commissioner Of Income Tax on 6 June, 2000

"Whether in the facts and in the circumstances of the case, considering the different views taken by the different Benches of the Tribunal i.e. Bharat Forge Ltd. v. Dy. CIT (supra), Kalyani Steels Ltd. v. Dy. CIT (supra) and J.C.T. Ltd. v. Assistant CIT (supra) and the decisions of Supreme Court and High Court discussed in the orders, the interest paid on borrowed capital which has been capitalised in the books of account as part of actual cost of the new machineries of the new unit of the assessee-company can be claimed as deduction under section 36(1)(iii) of the Income Tax Act."
Income Tax Appellate Tribunal - Ahmedabad Cites 144 - Cited by 7 - Full Document

Core Health Care Ltd. vs Deputy Commissioner Of Income Tax. on 6 June, 2000

The decision of the Calcutta Bench reported in (1999) 65 ITD 169 (supra) is also clearly contrary to the judgment of the Hon'ble jurisdictional High Court in the case of Alembic Glass Industries. It is also contrary to various decisions of the Tribunal which have been referred to in the order of the learned A.M. The impact of Expln. 8 inserted in s. 43(1) will be considered in the later part of this order. The said decision is based mainly on the fact that after capitalisation of the amount of interest, it has merged into cost of assets and thus lost its original character.
Income Tax Appellate Tribunal - Ahmedabad Cites 143 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax,, vs M/S. Alfa Laval India Ltd.,, Pune on 9 January, 2019

"25. We have heard the rival contentions and perused the record. The issue which arises in the present appeal is the preliminary issue of recording of satisfaction by the Assessing Officer before applying provisions of Rule 8D of the Rules in line with section 14A of the Act. We find that similar issue of exercise of jurisdiction by the Assessing Officer in recording the satisfaction while applying the provisions of section 14A of the Act arose before the Tribunal in Kalyani Steels Ltd. Vs. Addl.CIT (supra), wherein it was held as under:-
Income Tax Appellate Tribunal - Pune Cites 23 - Cited by 0 - Full Document

Core Health Care Ltd. vs Deputy Commissioner Of Income-Tax on 6 June, 2000

12. Shri Dastur submitted that the various Benches of the Tribunal even after considering Explanation 8 to section 43(1) have held that interest paid in respect of borrowings made for running business/ existing business is deductible under section 36(1)(iii). He placed reliance on decisions reported in Bharat Forge Ltd.'s case (supra), Kalyani Steels Ltd's case (supra) Kumar Printers (P.)
Income Tax Appellate Tribunal - Ahmedabad Cites 129 - Cited by 0 - Full Document

Assistant Commissioner Of ... vs M/S. Alfa Laval India Ltd.,, Pune on 1 April, 2019

"25. We have heard the rival contentions and perused the record. The issue which arises in the present appeal is the preliminary issue of recording of satisfaction by the Assessing Officer before applying provisions of Rule 8D of the Rules in line with section 14A of the Act. We find that similar issue of exercise of jurisdiction by the Assessing Officer in recording the satisfaction while applying the provisions of section 14A of the Act arose before the Tribunal in Kalyani Steels Ltd. Vs. Addl.CIT (supra), wherein it was held as under:-
Income Tax Appellate Tribunal - Pune Cites 5 - Cited by 0 - Full Document

Deputy Commissioner Of Income-Tax, ... vs M/S. Alfa Laval (India) Limited,, Pune on 20 June, 2019

"25. We have heard the rival contentions and perused the record. The issue which arises in the present appeal is the preliminary issue of recording of satisfaction by the Assessing Officer before applying provisions of Rule 8D of the Rules in line with section 14A of the Act. We find that similar issue of exercise of jurisdiction by the Assessing Officer in recording the satisfaction while applying the provisions of section 14A of the Act arose before the Tribunal in Kalyani Steels Ltd. Vs. Addl.CIT (supra), wherein it was held as under:-
Income Tax Appellate Tribunal - Pune Cites 6 - Cited by 0 - Full Document

Deputy Commissioner Of Income-Tax,, vs M/S. Alfa Laval India Ltd.,, Pune on 26 July, 2017

25. We have heard the rival contentions and perused the record. The issue which arises in the present appeal is the preliminary issue of recording of satisfaction by the Assessing Officer before applying provisions of Rule 8D of the Rules in line with section 14A of the Act. We find that similar issue of exercise of jurisdiction by the Assessing Officer in recording the satisfaction while applying the provisions of section 14A of the Act arose before the Tribunal in Kalyani Steels Ltd. Vs. Addl.CIT (supra), wherein it was held as under:-
Income Tax Appellate Tribunal - Pune Cites 9 - Cited by 0 - Full Document

Bosch Chassis Systems Ltd.,, Pune vs Assessee on 20 February, 2014

8.3 So far as the decision of the Tribunal in the case of Kalyani Steels Ltd. (Supra) is concerned, we find in that case the assessee has suomoto disallowed an amount of Rs.5 lakhs out of the dividend income of Rs.5.46 crores towards principal administrative expenses. However, in the instant case the assessee has not disallowed any such expenditure. Further, the Tribunal in assessee's own case in the preceding 2 assessment years has held that 1% of the dividend income can reasonably be disallowed towards principal administrative expenses. In this view of the matter, the decision relied on by the Ld. Counsel for the assessee cannot be accepted. The grounds raised by the assessee are accordingly partly allowed.
Income Tax Appellate Tribunal - Pune Cites 5 - Cited by 0 - Full Document
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