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...in Commissioner of Income Tax v. R.M Chidambaram Pillai [(1977) 106 ITR ...Pillai [(1977) 106 ITR 292 (SC)] wherein the Hon'ble Supreme Court held that “there cannot be a contract of service in strict la...Commissioner of Income Tax v. R.M Chdambaram Pillai [(1977) 106 ITR 292 (SC); Assistant Director of Inspect...
...income and is taxable as held in the case reported in CIT v. R. M. Chidambaram Pillai [1977] ...CIT v. R. M. Chidambaram Pillai [1977] 106 ITR 292, to which decision ...CIT v. R. M. Chidambaram Pillai [1977...
...CIT v. K.M. Chidambaram Pillai [1977] 106 ITR 292 (SC). During the subsistence of the partnership, however, no partner can d...] 55 ITR 159 (AP), Chittoor Motor Transport Co. (P.) Ltd. v. ITO [1966] 59 ITR 238 (SC) and CIT v. B.M. Kharwar...[1969] 72 ITR 603 (SC), in support of his argument that we must hold that there was a sale as held by the ITO. In all the cases relied upon by...
...the membership of the HUFs in the partnership. Relying upon the decision in CIT v. Chidambaram Pillai [1977] 106 ITR 292 (...counsel was that the decision in CIT v. Chidambaram Pillai [1977] 106 ITR 292 (SC), related to the consideration of the que....9. It only remains to consider the decision of the Supreme Court in CIT v. Chidambaram Pillai [1977] 106 ITR 292 (...
...following decisions:CIT v. R.M. Chidambaram Pillai [1977] 106 ITR 292 (SC), ...Siddharthbhai v. Commissioner Of Income Tax, Ahmedabad, Gujarat. [1985] 156 ITR 509/23 Taxman 14W (SC...), Malabar Fisheries Co., Calicut v. Commissioner Of Income Tax, Kerala [1979] 120 ITR 49/ 2 Taxman 409 (SC), Third ITO v. Arunagiri Chettiar...
...great emphasis is laid by learned counsel for the Revenue on CIT v. R.M Chidambaram Pillai, [1977] 106 ITR 292 (SC). The de...and even necessary to assume all those facts on which alone the fiction can operate (see CIT v. Teja Singh, [1959] 35 ITR 408 (SC)).8. In an oft-quoted passage, Lord...ITR 643. As indicated above, the Revenue moved for a reference which has been accepted.4. In support of the reference application, learned counsel for the Revenue submitted that what...
...partner is hit by S. 40(b) of the Act, is squarely covered by the decision of the Supreme Court in CIT vs. Chidambaram Pillai (1977) 106 ITR ...) SC 223, in which the Court ruled down that when the assessee is following mercantile system of accounting, in case of sales-tax payable by the assessee, the liability to pay sales-tax would accrue...JT 1997 (3) SC 441. The interest of Rs. 5,708 having been paid to the HUF of Shri Dhan Kumar and not to th...
...judgments of Hon'ble Supreme Court in the case of CIT v. R.M Chidambaram Pillai (1977) 106 ITR 292 (SC) and that of ...CIT v. Lokhpat Film Exchange (Cinema) (2008) 304 ITR 172 (Raj) which infer that non-compliance with provisions of section 269T...Court in the case of CIT v. Lokhpat Film Exchange (Cinema) (2008) 304 ITR 172 (Raj) wherein the contention of the assessee that in view of...
.... CIT v. R.M Chidambaram Pillai (1977), 106 ITR 292 (SC)6. On the issue of Short Term Capi.... Teja Constructions v. ACIT (2010) 129 TTJ (Hyd.) (U.O 57)2. Badridas Daga v. CIT (1958) 34 ITR 10 (SC...)3. Keshavji Ravji & Co. etc. v. CIT (1990), 183 ITR 1 (SC)4...
...CIT v. R.M Chidambaram Pillai, [1977] 106 ITR 292 (SC), at page 295, the question posed was—”What is the real nature of the...CIT v. Pramod Kumar Jain, [1995] 216 ITR 598 (Raj) and CIT v. N.S.M Sankarapandian, [1996] 222 ITR 289...ITR 396, the Tribunal held that “a partner of a firm is entitled to salary for rendering the services to the firm and in case a person draws salary he is entitled to the statutory deduction under...
...CIT vs. R.M. Chidambaram Pillai (1977) 106 ITR 292 (SC) and that of Rajasthan H.C. in ...(Cinema) (2008) 304 ITR 172 (Raj) which infer that non-compliance with provisions of section 269T, in such cases, can be ignored and explanation tendered can be accepted as bona fide...CIT vs. Lokhpat Film Exchange (Cinema) (2008) 304 ITR 172 (Raj) wherein the contention of the assessee that in view of the fact that partner and firm are not independent of each...
.... R.M Chidambaram Pillai [1977] 106 ITR 292 (SC), while confirming the decision of the Full Bench of this court in R.M ...R.M Chidambaram Pillai v. CIT [1970] 77 ITR 494 (Mad) [FB], a Full Bench of this court, while considering the nature and character of salary paid to a partner,...CIT v. Kalu Babu Lal Chand [1959] 37 ITR 123 (SC), CIT v. Nandlal Ganda Lal [1960] 40 ...
...referred to the decision in CIT v. Chidambaram Pillai, [1977] 106 ITR ...not referred to the following decisions of the Supreme Court and this court in CIT v. Chidambaram Pillai, [1977] 106 ITR 292 and..., [1967] 63 ITR 292, and also the decision of the Allahabad High Court in Ram...
...CIT v. R.M. Chidambaram Pillai [1977] 106 ITR 292 (SC) and Sant...CIT v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC), cited from the side of the assessee, and, confirme...
...CIT v. A.W Figgies and Co., [1953] 24 ITR 405 (SC).”5. In CIT v. R.M Chidambaram Pillai, [1977] 106 ITR ...Pillai, [1977] 106 ITR 292, 298 (SC):“What is called the property of the firm is their property, and what are called the debts and liabilities of the firm are .... WTO, [1984] 145 ITR 485 (SC), the question was as to whether the interest of a Hindu undivided family in a firm is exigible to...
...1. A neat point of law, which, as described by Krishna Iyer J. in CIT v. R. M. Chidambaram Pillai [...Pillai's case [1977] 106 ITR 292, 299 the Supreme Court, speaking through Krishna Iyer J., referred to the various authorities, viz...[1956] 29 ITR 535 (SC), and Addanki Narayanappa v. Bhaskara Krishnappa, AIR 1966 SC...
...have been quoted in extenso in the order. He has found the decisions in the cases of CIT v. R. M. Chidambaram Pillai [1977] 106 ITR ..., following the Supreme Court decisions in the cases of CIT v. Gurunath V. Dhakappa [1969] 72 ITR 192 and...Raj Kumar Singh Hukam Chandji v. CIT [1970] 78 ITR 33 accepted the assessee's claim and directed the ITO to exclude the said amount of Rs. 12,000 from the total...
...designate an entity, not a person. In income-tax law a firm is a unit of assessment by special provisions but is not a full person—CIT v. R.M Chidambaram Pillai, [1977] 106 ITR 292 (SC)....“association”—Deccan Wine and General Stores v. CIT, [1977] 106 ITR 111 (AP).29. Joining together by the members of the.... CIT, [1977] 106 ITR 111 (AP).31. The body of individuals with which the Income-tax Act is...
...the circumstances of the case, the Deputy Commissioner was right in applying the case law in CIT v. R.M Chidambaram Pillai, [1977] 106 ITR ..., 1975. The assessment orders for the years 1974–75, 1975–76 and 1976–77 were rendered on March 31, 1976. The assessment order for the year 1977–78 was passed on June 28, 1978, and for the assessment...assessment order for the year 1976–77; more than five years after the original assessment order for the year 1977–78 and four years after the assessment order for the year 1978–79. The assessments for...
...CIT v. R.M. Chidambaram Pillai [1977] 106 ITR 292 (SC) is not really applicable to the facts of the case because it was hel...CIT v. A.W. Figgies & Co., [1953] 24 ITR 405 (SC), it is observed that change in the constitution of the firm does not amount to the succession...hands of the firm and the assessee partners.3.4 In the case of Dulichand Laxminarayan v. CIT, [1956] 29 ITR 535(SC), it...