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Sms Tolls And Developers,Nagpur vs Ito, Ward 1(5), Nagpur on 18 November, 2024 cites

The Commissioner Of Income Tax vs M.B. Stockholding Pvt. ... on 23 April, 2015

In the light of the judicial precedent laid by Hon'ble Gujarat High Court in CIT Vs. M. B. Stockholding (P) Ltd.(supra), and since no decision of jurisdictional High Court was cited in support of impugned action of Ld CIT(A), we are of the considered opinion that in the present case, while determining the deemed dividend, the AO/Ld. CIT(A) ought to have taken into consideration the accumulated profit as on 31.03.2011 i.e., loss/(-) of Rs.74,80,633/- and not accumulated profit adopted as on 31.03.2012 (Rs.3.46 crores). Therefore, no addition was possible u/s 2(22)(e) of the Act in the facts of the case and thus the assessee succeeds. And consequently, we direct the deletion of of Rs Rs.3,41,96,270/-."
Gujarat High Court Cites 2 - Cited by 5 - M R Shah - Full Document

Commissioner Of Income-Tax, Gujarat vs Ashokbhai Chimanbhai on 20 October, 1964

"Keeping in view the above interpretation of law, it cannot be said that Expln.2 to sec. 2(22)(e) is redundant. It is bound to be for a specific purpose. The question for determination is as to what is the purpose for which this Explanation has been incorporated when the Hon'ble Supreme Court in the case of CIT Vs. Ashokbhai Chimanbhai (supra) have held that the profits of business do not accrue from day to day or even from month to month. In our considered view, the legislature has taken into account the fact that whereas the profits from business for the current year may not be determinable in the middle of the year, there are certain sources of income, the income from which is capable of determination which, according to the legislative intent, should also be taken into account while determining the accumulated 11 SMS Tolls and Developers Ltd.
Supreme Court of India Cites 12 - Cited by 162 - J C Shah - Full Document

Commissioner Of Income-Tax vs Mrs. Maya B. Ramchand on 29 October, 1985

10. We find that Hon'ble Jurisdictional High Court in CIT v/s Mrs. Maya B. Ramchand: [1986] 162 ITR 460 (Bombay) while considering the issue of accumulated profit "under Section 2(6A)(e) of the Indian Income-tax Act, 1922 [corresponding to section 2(22) of the Act], observed as under: -The position, as found by the Supreme Court in Navnit Lal C. Javeri's case (supra)and this Court's judgment in P.K. Badiani's case (supra) is that, for the purposes of section 2(6A)(e) the company's accumulated profits must be determined upon the day on which the loan or advance to the shareholder is made."
Bombay High Court Cites 5 - Cited by 18 - Full Document

Satyabir Singh Yadav, Gurgaon vs Ito, Gurgaon on 13 July, 2023

10. We find that Hon'ble Jurisdictional High Court in CIT v/s Mrs. Maya B. Ramchand: [1986] 162 ITR 460 (Bombay) while considering the issue of accumulated profit "under Section 2(6A)(e) of the Indian Income-tax Act, 1922 [corresponding to section 2(22) of the Act], observed as under: -The position, as found by the Supreme Court in Navnit Lal C. Javeri's case (supra)and this Court's judgment in P.K. Badiani's case (supra) is that, for the purposes of section 2(6A)(e) the company's accumulated profits must be determined upon the day on which the loan or advance to the shareholder is made."
Income Tax Appellate Tribunal - Delhi Cites 28 - Cited by 0 - Full Document
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