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M/S. Chowringhee Sales Bureau (P) Ltd vs C.I.T., West Bengal on 10 October, 1972

20. The aforesaid decision of Bombay High Court had made no reference or discussion of the three Supreme Court decisions namely Chowringhee Sales Bureau (P) Ltd.'s case (supra), George Oakes (P) Ltd.'s case (supra) and McDowell & Co. Ltd.'s case (supra) referred to above and the other decision of the Supreme Court in the case of Sinclair Murray & Co. (P) Ltd. (supra).
Supreme Court of India Cites 12 - Cited by 319 - H R Khanna - Full Document

International Research Park ... vs Assistant Commissioner Of Income-Tax on 25 July, 1994

17. The two terms, namely, "export turnover" and "total turnover" should unless a contra intention appears be given their natural and general meaning as understood in commercial laws as interpreted by the judicial decisions and not the restricted meaning as claimed by the assessee on the ground that one has a particular kind of receipt and therefore the other should also be of similar nature or specie. The contention of the assessee that like should be compared with the like may give absurd results and it could never be applied unless the same type of goods are exported and sold in local market. A similar plea for interpreting Section 80HHC(3)(b) as it then stood was rejected by the Special Bench in the case of International Research Park Laboratories Ltd. v. Assn. CIT (1994) 50 TTJ (Del)(SB) 650 : (1994) 50 ITD 37 (Del)(SB) by observing 'There are no words in Sub-section (3) as to limit this apportionment of profit on the basis of turnover in exports or to suggest that the apportionment has to be resorted to only when the same kind of goods are exported are also dealt with'. In the present case, export is stated to be of marine goods, etc. and the local sales are of IMFL, Industrial Alcohol, etc. If the export sale is of a different item than sold in the local market, then also, it can be said that two things-export and local-would not be alike or of the same specie.
Income Tax Appellate Tribunal - Delhi Cites 59 - Cited by 40 - Full Document

Commissioner Of Income-Tax vs Sudarshan Chemicals Industries Ltd., ... on 8 August, 2000

18. We, however, find two decisions of the High Court accepting the claim of the assessee on the issue. One is of Bombay High Court in the case of CIT v. Sudarshan Chemicals Industries Ltd. (2000) 245 ITR 769 (Bom) cited at the time of hearing and the other is of jurisdictional High Court of Calcutta in the case of Chloride India Ltd. (IT Ref. Nos.
Bombay High Court Cites 7 - Cited by 156 - S H Kapadia - Full Document
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