Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


DCIT v. Reckit Benkiser Healthcare India (P) LTD. (2025) 237 TTJ 129 / 176 taxmann.com 573 (Ahd)(Trib)

S. 80IC: Special category States-Profits and gains derived from industrial undertaking-Income from sale of scrap-Scrap was a by-product arising directly from the manufacturing process undertaken at the eligible unit-Eligible for deduction-Disallowance under S. 40(a)(ia) would form part of the eligible profits for the purpose of deduction under s. 80-IC, allowable deduction. [S.40(a)(ia)]

Jaydeep Petro Chem Company (P) Ltd. v. ITO (2025) 237 TTJ 316 / 176 taxmann.com 871 (Chennai) (Trib.)

S. 80IB: Industrial undertakings-Manufacture or production-Production of paints, varnish and thinners-Casual workers-The undertaking engaging ten or more workers-Entitled to exemption.

BSC C & C Joint Venture v. ACIT (2025) 237 TTJ 377(Delhi)(Trib)

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Claim was not made in the return-Additional ground before CIT(A)-The disputed claim of deduction under S. 80-IA(4) was neither made in the original return nor in any revised return till the conclusion of the assessment proceedings-Claim was made first time before CIT(A)-Additional ground was rejected-Not eligible for deduction.[S. 80A(5),80IA(4), 139(1), 139 (4), 250]

Laxmi Organic Industries Ltd. v. DCIT (2025) 237 TTJ 268 / 177 taxmann.com 118 (Mum.)(Trib.)

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Sale of steam by one eligible unit to other eligible unit for captive consumption-Rejecting the comparable of the assessee and the enhancement made by the DRP by giving direction to treat the claim of deduction under s. 80-IA for steam transfer as ‘Nil’ is set aside-Claim of deduction is allowed.

Matha Medical Centre Trust v. CIT(E) (2025) 237 TTJ 613 (Chennai)(Trib)

S. 80G: Donation-Medical relief to the poor in rural areas-Rejection of application by CIT(E) is set aside and directed to approve. [S.2(15),80G(5)]

Academy of Liberal Education v. CIT(E) (2025) 237 TTJ 366 / 176 taxmann.com 675 (Bang) (Trib.)

S. 80G: Donation-Recognition of institution, etc-CIT(E) has not brought any material on record to show that the activities of the assessee trust are not genuine or the conditions as specified above are not fulfilled by the assessee-trust-CIT(E) is directed to grant approval under s. 80G to the assessee-trust. [S.11, 12A, 80G(5)]

Leela Greenship Recycling (P) Ltd. v. DCIT (2025) 237 TTJ 471/ 180 taxmann.com 407 (Ahd)(Trib)

S. 69C: Unexplained expenditure-Alleged bogus purchases-Produced documentary evidence such as purchase invoices, stock records, RTGS payments, GST returns, supplier confirmations, and segment-wise accounts-Matter was remanded back to the AO to obtain the bank account details of MT Co., and verify whether there exists any cash trail; if no such cashback trail is established upon verification, and payments are found to have remained within the banking system, then the addition is to be restricted only to the embedded profit element @ 5 per cent. [S. 145]

Paul Dhinakaran v. DCIT(2025) 237 TTJ 850 (Chennai)(Trib)

S. 69A: Unexplained money-Credit card expenses incurred in representative capacity-Reimbursed expenses-Addition was deleted-Seizure of gold jewellery-Source explained-Addition was deleted. [S. 132]

Akshat Loyalka v. ITO (E) (2025) 237 TTJ 200/ 126 ITR 373/ 175 taxmann.com 42 (Jaipur)(Trib.)

S. 69A: Unexplained money-Cash deposit in bank account-Matter remanded to the file of CIT(A)-Reassessment was affirmed.[S. 147, 148]

Nilesh Purshottam Ghodasara v. DCIT (2025) 237 TTJ 618 (Delhi) (Trib.)

S. 69: Unexplained investments-Non-Resident-Investment in property-Co-owner-Source of investment was explained-Addition was deleted.