Supreme Court of India

Kerala State Beverages Manufacturing & Marketing Corporation Ltd. v. The Assistant Commissioner of Income Tax Circle 1(1)

Neutral citation
Reported as [2022] 1 S.C.R. 105
Bench R. Subhash Reddy and Hrishikesh Roy JJ.
Decided 3 January 2022

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

We hold that the gallonage fee, licence fee and shop rental (kist) with respect to FL-9 and FL-1 licences granted to the appellant will, squarely fall within the purview of Section 40(a)(iib) of the Income-tax Act, 1961.

Judgment, page 24

From the headnote

Income Tax Act, 1961: s.40(a)(iib) – Purpose of amend ment of Income Tax Act by Act 17 of 2013, by which s.40(a)( iib)( ), ( ) is inserted – Held: The said amendment is made to plug the pos sible diversion or shifting of profits from state owned unde rtakings into State’s treasury – In view of s.40(a)(iib) of the ct any amount, which is levied exclusively on the State owned undertak ing (KSBC in the instant case), cannot be claimed as a deduction in the books of State owned undertaking, thus same is liable to income ta x – It is fairly well settled that the interpretation is to be in the

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