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Mahalaxmi Sugar Mills Co. Ltd vs Commissioner Of Income-Tax, Delhi, New ... on 9 April, 1980

14. Before coming to conclude the subject matter of disallowance, we note that, the Hon'ble Apex Court in 'Mahalakshmi Sugar Mills' (supra) settled the issue of deductibility of interest on taxes/duties holding that, interest payable on unpaid or delayed liability is part and parcel of such liability and was in the nature of compensation to the government. The said decision rendered in context of deductibility cannot robotically be pressed for the purpose of provisions of section 43B(a) of the Act, when the legislature in its wisdom thought fit not to provide interest explicitly in clause (a) of section 43B of the Act.
Supreme Court of India Cites 22 - Cited by 195 - R S Pathak - Full Document

Prakash Cotton Mills Pvt. Ltd vs Commissioner Of Income Tax (Central) ... on 6 April, 1993

Insofar as the deductibility of such unpaid interest u/s 37(1) of the Act is concerned there is much less dispute in view of 'Mahalakshmi Sugar Mills Co Vs CIT' [1980, 123 ITR 429 (SC)]'Prakash Cotton Mills Ltd. Vs CIT (Central)' [1993, 201 ITR 684 (SC)] & 'Lachmandas Mathura Vs CIT' reported in 254 ITR 799 (SC). However it is the case of the Revenue that, the interest on MVAT is in the form of sales tax/VAT which remained unpaid before the expiry of due date prescribed u/s 139(1) for filing return of income hence is subject matter of disallowance u/c (a) of section 43B of the Act. Per contra the appellant dismantles Revenue's proposition on twofold contentions that; (a) such unpaid interest is not a tax, hence provisions of section 43B(a) of the Act are inapplicable and (b) without prejudice to (a) the disallowance of such unpaid interest u/s 43B through summary processing u/s 143(1)(a) of the Act is impermissible.
Supreme Court of India Cites 19 - Cited by 63 - N Venkatachala - Full Document
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