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Commissioner Of Income Tax vs Jai Parabolic Springs Ltd. on 7 April, 2008

"6.6. I have analyzed the facts of the present case in the light of the parameters laid down by the Hon'ble Delhi High Court in the case of CIT vs. Jai Parabolic Springs Ltd. and the observations made by the Hon'ble Apex Court in the case of Jute Corporation of India Ltd. vs. CIT and the instructions given by the Central Board of Direct Tax on matters pertaining to assessments. On consideration, I find that the deduction on account of penalty was undisputedly allowable to the appellant company as neither the payment of income tax penalty/other liability is an admissible claim nor the refund thereof is assessable. Therefore, while the payment of penalty, if debited to the profit and loss account is to be disallowed and added back to the computation of total income, the refund thereof if credited to the P&L A/c, has to be allowed as a deduction in the computation. Therefore, in my view, it will be unjustified if such apparent mistake in the assessment order is not rectified in the appeal proceedings.
Delhi High Court Cites 10 - Cited by 199 - V B Gupta - Full Document

Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr on 4 September, 1990

"6.6. I have analyzed the facts of the present case in the light of the parameters laid down by the Hon'ble Delhi High Court in the case of CIT vs. Jai Parabolic Springs Ltd. and the observations made by the Hon'ble Apex Court in the case of Jute Corporation of India Ltd. vs. CIT and the instructions given by the Central Board of Direct Tax on matters pertaining to assessments. On consideration, I find that the deduction on account of penalty was undisputedly allowable to the appellant company as neither the payment of income tax penalty/other liability is an admissible claim nor the refund thereof is assessable. Therefore, while the payment of penalty, if debited to the profit and loss account is to be disallowed and added back to the computation of total income, the refund thereof if credited to the P&L A/c, has to be allowed as a deduction in the computation. Therefore, in my view, it will be unjustified if such apparent mistake in the assessment order is not rectified in the appeal proceedings.
Supreme Court of India Cites 19 - Cited by 674 - K N Singh - Full Document
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