ACIT CENTRAL CIRCLE 1(4), MUMBAI, MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

ITA 6530/MUM/2026Status: DisposedITAT Mumbai18 September 2026AY 2003-048 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order regarding the treatment of sales tax subsidy. The core issues were whether the subsidy should be treated as a capital receipt and whether it should be excluded when computing book profit under Section 115JB.

What did the Tribunal hold?

The Tribunal held that the sales tax subsidy is a capital receipt and should be excluded from the computation of book profit under Section 115JB. This decision was based on previous judgments of the Tribunal and High Courts on similar facts.

What were the issues?

The primary issues were the classification of sales tax subsidy as capital vs. revenue receipt and its impact on book profit calculation under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 115JB,Section 43(1)

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL“G” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Physical hearing) ACIT, Central Circle – 1(4), Mumbai – 400020. Mumbai – 400030. [PAN: AAACG4464B] Appellant / Revenue Respondent / Assessee Assessee by Shri Ronak Doshi, CA Revenue by Shri Basavaraj Hiremath, CIT DR. Date of Institution 27.05.2026 Date of hearing 17.09.2026 Date of pronouncement 18.09.2026 Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER;

1.

This appeal by Revenue is directed against the order of ld. CIT(A) – 47, Mumbai dated 12.03.2026 for Assessment Year (AY) 2003-04 in rejecting the application for registration of trust under section 12AB. The Revenue has raised following grounds of appeal:

“1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) is justified in accepting the claim of the assessee of allowing the receipt of subsidy as the capital receipt and not revenue receipt. 2.Whether on the facts and in the

The order continues below.

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