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Documents citing Krishna Associates vs Income-Tax Officer on 16 April, 1987

M/S. Krishna Associates, Ahmedabad vs The Ito, Ward-3(2)(2), Ahmedabad on 7 October, 2022

M/s. Krishna Associates vs. ITO 6.1. In the above circumstances, we deem it fit that it is a fit case to be remand it back to the Assessing Officer to verify whether any other project done by the assessee during the assessment year and verify the expenses claimed by the above five parties. Needless to say, the assessee should cooperate with the Assessing Officer in the set aside proceedings to pass appropriate assessment order. For this limited purpose, the Grounds of Appeal raised by the assessee are allowed for statistical purposes.
Income Tax Appellate Tribunal - Ahmedabad Cites 6 - Cited by 1 - Full Document

Data Base Industries vs Income-Tax Officer on 11 October, 1990

This requires that the machinery, i.e., Computer must be used in an industrial undertaking for the purpose of business of (deleting the words not necessary for our present purpose) production of any article or thing not being an article or thing specified in the list in the Eleventh Schedule. The argument of the Departmental Representative is that M/s Tata Consultancy Services is not an industrial undertaking. We cannot accept this contention for two reasons. One is, this is not the reason given by the Commissioner of Income-tax in his order or in the notice given by him to the assessee calling for his explanation. Secondly, there is no evidence to show that M/s Tata Consultancy Services was not an industrial undertaking. On the other hand, the proceedings have gone on, on the basis that the requirement was satisfied. We, therefore, do not accept this argument of the Departmental Representative. Secondly, it is now decided unanimously by several Benches of the Income-tax Appellate Tribunal that whatever was given out by a Computer amounts to production of an article or thing. We do not have to refer to the decided cases on the subject except to refer to a case decided by the Bangalore Bench of the Income Tax Appellate Tribunal in the case of Krishna Associates v. ITO [1987] 22 ITD 530 which was followed by Delhi Bench of the Tribunal in the case of Softek (P.)
Income Tax Appellate Tribunal - Delhi Cites 9 - Cited by 8 - Full Document

Softek (P.) Ltd. vs Income-Tax Officer on 19 December, 1989

16. As has already been pointed out above, the CIT(A) upheld the order of the ITO for different reasons. He was of the view that the computers do not either produce or manufacture any article. On this point there is a decision of the Bangalore Bench of the Tribunal in Krishna Associates' case (supra) wherein on similar facts, it was held by the Tribunal that data processed and printed out would certainly be a thing produced by the assessee even if not a thing manufactured by it. The assessee was, therefore, entitled to deduction under Section 32A. Respectfully following the said decision of the Tribunal, we hold that the assessee is engaged in the business of production of an article or thing and that the computers are being used for that purpose. The assessee will also be entitled to investment allowance on the airconditioner provided it is found that it is not installed in the office premises.
Income Tax Appellate Tribunal - Delhi Cites 19 - Cited by 1 - Full Document

Commissioner Of Income Tax vs Daljeet Tyres on 22 September, 2005

4. The CIT(A), considering the reply of the assessee, in which he had narrated about the manufacturing process involved, came to the conclusion that the material so processed was capable of being sold in an acceptable form and, therefore, investment allowance on such plant and machinery used for such process was allowable. For reaching this finding he also relied upon the decision of the Tribunal, Bangalore Bench in the case of Krishna Associates v. ITO in ITA No. 928/Bang/1985 for the asst. yr. 1984-85 reported at (1987) 28 TTJ (Bang) 494--Ed..
Allahabad High Court Cites 19 - Cited by 0 - Full Document

Ubs Publishers Distributors Ltd. vs Inspecting Assistant Commissioner on 11 December, 1990

16. It would be seen from the above observation that paucity of materials was the reason why the Tribunal set aside the matter to the assessing authority. There is no such reason for this year. All materials necessary have been considered by us. We may also mention that the fact that in a sister company's case, the ITO himself has allowed the deduction, cannot carry the assessee's case for, because each case will depend upon its facts. Finally, we may also refer to the decision of the Bangalore Bench of the ITAT in the case of Krishna Associates (supra). That case was more or less similar to the Karnataka High Court decision in Datacons Ltd., considered above. So the facts of that case are entirely different. Under these circumstances, we are of opinion that the assessee is not entitled to Investment Allowance.
Income Tax Appellate Tribunal - Delhi Cites 8 - Cited by 0 - Full Document
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