GMP TECHNICAL SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

ITA 6155/MUM/2025Status: DisposedITAT Mumbai21 September 2026AY 2014-1511 pages
AI SummaryPartly Allowed

What were the facts?

The assessee claimed deduction under Section 80-IC for its manufacturing unit. The Assessing Officer disallowed certain receipts like insurance claims and penalties on vendors, and provisions for doubtful debts and advances to sundry creditors, reducing the eligible profit and consequently the deduction. The CIT(A) upheld this disallowance.

What did the Tribunal hold?

The Tribunal held that insurance claims are operational receipts directly related to manufacturing and eligible for Section 80-IC deduction. Provisions for doubtful debts and sundry creditors written back are also eligible as they represent a reduction in operational expenses. However, penalties on vendors were considered unrelated to direct manufacturing.

What were the issues?

Whether insurance claims, penalties on vendors, provisions for doubtful debts, and advances to sundry creditors are to be included in the profits derived from an eligible undertaking for Section 80-IC deduction. Also, whether TDS was required on consultancy fees paid to non-residents.

Which sections of the Income-tax Act were involved?

Section 80-IC,Section 40(a)(ia),Section 195,Section 9(1)

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL“G” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER (Physical Hearing) GMP Technical Solutions Pvt. Ltd. DCIT, 3096-316, 3rd Floor, Swastik Disha Vs Aayakar Bhawan, Business Park, Behind Wadhwani M.K. Road, Mumbai-400020 Industrial Estate, L.B.S. Marg Ghatkopar, Mumbai – 400086. [PAN: AAACQ1042P] Appellant / Assessee Respondent / Revenue Assessee by Ms. Afrin Shaikh, CA & Shri Rahul Charkha, CA Revenue by Shri Rajgopal Parthasarathi, Sr. DR Date of Institution 30.09.2025 Date of hearing 24.07.2026 Date of pronouncement 21.09.2026 Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER:

1.

This appeal by assessee is directed against the order of ld. CIT(A)/NFAC dated 25.07.2025 for Assessment Year (AY) 2014-15. The assessee has raised following grounds of appeal: Ground 1 - On the facts and in the circumstances of the case and in law, the Learned Commissioner of Income-tax (Appeals) [“Ld. CIT(A)"] erred in upholding the assessment order passed under Section 143(3) in toto without appreciating the detailed submissions, documentary evidences and legal positions placed on reco

The order continues below.

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