decision of Hon'ble
Supreme Court in the case of Kwality Biscuits Ltd. 284 ITR 434 (SC),
has held that interest is not chargeable ... decision
of Hon'ble Supreme Court in the case of Kwality Biscuits (supra) and
also in view of the decision of ITAT in assessee
Kwality Biscuits Ltd.,, Bangalore vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
BANGALORE BENCH 'A'
BEFORE SHRI GEORGE GEORGE K, JUDICIAL MEMBER ... 1223(Bang)/2009)
(Assessment year: 2001-02)
M/s.Kwality Biscuits Ltd.,
C/o Britannia Industries Ltd.,
Britannia Gardens, Vimanpura,
Old Airport Road,
Bangalore
Supreme Court in case of CIT Vs Kwality Biscuits Ltd. 284 ITR 434 wherein
it has been held that no interest u/s 234B ... Supreme Court in case of CIT Vs
Kwality Biscuits Ltd. (supra) was the law of the land on this point and
therefore the assessee could
judgment of Hon'ble Supreme Court
in case of Kwality Biscuits Ltd (284 ITR 434). CIT(A) agreed that in view
of the judgments ... Earlier Hon'ble High Court of Karnataka in case
of Kwality Biscuits Ltd Vs. CIT (243 ITR 519) had held that while dealing
with
basis of decision given in the case of CIT Vs. Kwality Biscuits
Ltd. (284 ITR 434) (SC). The Assessing Officer has not agree with ... assessee
on the ground that in the case of Kwality Biscuits Ltd. (supra), the Hon'ble
Supreme Court decided the issue relating to profits
case of CIT vs. Kwality Biscuits Ltd. (2006) 284 ITR
434 (SC).
7
ITA No.1467/A/06 and others ... Karnataka High Court in the case of Kwality Biscuits Ltd. it has
concluded that "amount written back to the Profit and Loss
account
decisions of the Karnataka High Court and the Supreme Court
in Kwality Biscuits Ltd., rendered in the context of s. 115J
which did not have ... judgments of the Karnataka
High Court and the Supreme Court in Kwality Biscuits Ltd. is
that there is an inherent impossibility in the companies
estimating
Karnataka High Court in the case of Kwality Biscuits Ltd vs CIT reported in 243 ITR
519(Kar) and the decision
Supreme
Court in the case of CIT Vs. Kwality Biscuits Ltd. (284 ITR 434) ((SC). 7.
4 ITA Nos.1490 & 1509/H/2008 ... Supreme Court in the case of Kwality
Biscuits cited (supra) delivered in the context of provisions of Sec.115J.
However, there is a direct judgement
Supreme Court in the case of CIT Vs. Kwaliaty
Biscuits Ltd. , which is binding on various High Courts
as well as Tribunal.
2) That ... decision of Hon'ble
Supreme Court in the case of Kwality Biscuits Ltd.,
which was followed by various appellate Tribunals &
High Courts