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Commissioner Of Income-Tax, Madras vs K. Srinivasan And K. Gopalan on 22 December, 1952

24. The learned departmental representative referred to the decision of the honourable Supreme Court in case of CIT versus K Srinivasan (1972) 83 ITR 346 and submitted that education cess is part of 'tax' and therefore same is not allowable either u/s 37 (1) of the act and further as it is not an allowable expenditure the applicability of provisions of Section 40 (a) does not arise at all.
Supreme Court of India Cites 16 - Cited by 155 - Full Document

Perfetti Van Melle India Pvt. Ltd., ... vs Acit, Circle-3(1), Gurgaon on 22 September, 2021

25. We have carefully considered the rival contentions and pursued the various judicial precedents cited before us. We have appreciated the arguments of the ld DR . However the judicial precedents cited before us of Honourable Bombay and Rajasthan High court bind us. We find that this issue is squarely covered in favour of the assessee by the decision of Honourable Bombay high court in case of Sesa Goa Limited [2020] 117 taxmann.com 96 (Bombay)/[2020] 423 ITR 426 (Bombay )and Honourable Rajasthan High court in case of Chambal fertilizers Limited[2019] 107 taxmann.com 484 (Rajasthan). Coordinate bench in Perfetti Van Melle India Pvt. ... vs Acit, Circle-3(1), Gurgaon on 22 September, 2021 I.T.A. No. 463/Del/2021 has already considering all the arguments has allowed the claim of the assessee. Therefore respectfully following the same, we direct the ld AO to allow assessee the deduction of cess u/s 37 (1) of the act. Accordingly, additional ground of appeal is allowed.
Income Tax Appellate Tribunal - Delhi Cites 94 - Cited by 6 - Full Document
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