Delhi High Court High Court

The Commissioner Of Income Tax … vs Nestle India Ltd. on 1 October, 2010

Delhi High Court
The Commissioner Of Income Tax … vs Nestle India Ltd. on 1 October, 2010
Author: Manmohan
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*       IN THE HIGH COURT OF DELHI AT NEW DELHI

+       ITA 1508/2010

        THE COMMISSIONER OF
        INCOME TAX (LTU)                      ..... Appellant
                     Through: Mr. Sanjeev Sabharwal, , Advocate

                         versus

        NESTLE INDIA LTD.                       ..... Respondent

Through: Mr. Ajay Vohra, Advocate with
Ms. Kavita Jha, Advocate.

% Date of Decision: 01st October, 2010

CORAM:

HON’BLE THE CHIEF JUSTICE
HON’BLE MR. JUSTICE MANMOHAN

1. Whether the Reporters of local papers may be allowed to see the judgment?

2. To be referred to the Reporter or not?

3. Whether the judgment should be reported in the Digest?

MANMOHAN, J

CM No. 17302/2010 (exemption)

Allowed, subject to all just exceptions.

Accordingly, the application stands disposed of.

ITA 1508/2010

1. The present appeal has been filed under Section 260A of Income

Tax Act, 1961 (for brevity, “Act”) challenging the order dated 06th

November, 2009 passed by the Income Tax Appellate Tribunal (in short

“Tribunal”) in ITA No. 12/Del/2008, for the Assessment Year 1995-

1996.

ITA 1508/2010 Page 1 of 2

2. The issue involved in this appeal is with regard to deletion of

penalty imposed by the Assessing Officer (in short, “AO”) under

Section 271(1)(c) of the Act in respect of guest house expenses and the

claim of the respondent-assessee for interest income from Fixed

Deposit Receipts under Section 80HHC of the Act.

3. Mr. Sanjeev Sabharwal, learned counsel for the revenue fairly

stated at the bar that the respondent-assessee had filed its return of

income for the relevant assessment year much prior to the issuance

being finally settled by this Court and the Supreme Court against the

respondent-assessee.

4. Consequently, as the said expenses were debatable on the date

the respondent-assessee filed its return, we are of the opinion that no

penalty can be levied [see Malabar Industrial Co. Ltd. Vs. CIT (2000)

243 ITR 83 (SC)]. Accordingly, the present appeal is dismissed in

limine.

MANMOHAN, J

CHIEF JUSTICE

OCTOBER 01, 2010
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ITA 1508/2010 Page 2 of 2