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Documents citing Siemens Pub.Communication Network ... vs Cit Bangalore on 7 December, 2016

Dcit - 4(2)(2), Mumbai vs Gbtl Ltd. (Formerly Known As M/S. Grasim ... on 28 May, 2021

The Id Assessing Officer asked the appellant to justify why such loss was claimed. The appellant contended that the loss was AS-11 and Section 209(3) of the Companies Act. The appellant also relied on the Hon'ble Supreme Court judgment in the case of Woodward Governor India P Ltd (312 ITR 254} in support of its claim. The Id Assessing Officer was of the view that the decision of Woodward Governor India P Ltd [supra] was in the context of sundry creditors/debtors and was not relevant. The Id Assessing Officer distinguished forward contracts from future contracts and held that forwards are OTC in nature, customized, less liquid, without margin and settlement happens at the end.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

M/S Chatta Sugar Co. Ltd,Mathura vs A.C.I..T Circle-3, Mathura on 1 July, 2025

The principle of law as laid down in the case of Siemens Public Communication Network P. Ltd. (supra) is that voluntary payments made by the parent company to its loss making Indian subsidiary can also be understood to be payments made in order to protect the capital investment of the assessee-company. Though the grant-in-aid in this case was received from public funds, the State Government being a 100 per cent. share-holder, in our opinion, its position would be similar to that of, or at par with a parent company making voluntary payments to its loss making undertaking. No other specific business consideration on the part of the State has been demonstrated before us in this appeal. The assistance 38 ITA No.129/Agr/2015 extended appears to us to be measures to keep the assessee- company floating the assessee being, for all practical purposes an extended arm of the State. Though large part of the funds were applied for salary and provident fund dues, the object of extension of assistance, it was argued before us, to ensure survival of the company.
Income Tax Appellate Tribunal - Agra Cites 27 - Cited by 0 - Full Document

M/S. Sundaram Finance Limited vs The Assistant Commissioner Of Income ... on 6 March, 2019

3. As far as the Question No.1 quoted above is concerned, the learned counsel for the Assessee relying upon the decision of the Hon'ble Supreme Court in the case of Siemens Pub. Communication Network Pvt. Ltd., Vs. Commissioner of Income Tax and Anr., reported in (2017) 390 ITR 0001 (SC) allowing the Assessee's Appeal against the decision of the http://www.judis.nic.in 4 Karnataka High Court Division Bench held in the case of CIT Vs Siemens Public Communication Networks Limited., reported in (2014) 265 creditor (KAR) 0532, wherein the Hon'ble Supreme Court has held following the Judgement in the earlier case of Sahney Steel & Press Works Limited., Vs. CIT reported in (1997) 7 SCC 764 and CIT Vs. Ponni Sugaars and Chemicals Limited reported in (2008) 9 SCC 337, that unless the grant-in- aid received by the Assessee is utilised for acquisition of an asset, the same must be understood to be in the nature of a revenue receipt. The Court held that voluntary payments made by the parent company to its loss making Indian Company can also be understood to be payments made in order to protect the capital investment of the Assessee Company. If that is so, the payments made to the Assessee Company by the parent Company for the Assessment Years in question cannot be held to be revenue receipts.
Madras High Court Cites 8 - Cited by 0 - V Kothari - Full Document
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