J.P TOBACO PRODUCTA PVT. LTD. vs. ADD. COMMISSIONER OF INCOME TAX CIRCLE - SAGAR,

ITA 185/JAB/2016Status: DisposedITAT Jabalpur13 May 2026AY 1992-19938 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee failed to provide adequate evidence to satisfy the conditions for deductions under Sections 80HHA and 80IA. However, due to deficiencies in how the AO presented the negative findings and the assessee's lack of effective confrontation, the matter was remanded.

What were the facts?

The assessee company claimed deductions under Sections 80HHA and 80IA for AY 1992-93. These claims were initially disallowed and subsequently disallowed again after a remand from the ITAT for verification. The assessee failed to provide sufficient documentation to substantiate the claims.

What were the issues?

Whether the assessee fulfilled the conditions for claiming deductions under Sections 80HHA and 80IA, and whether the assessment proceedings adequately allowed the assessee to present its case.

Which sections of the Income-tax Act were involved?

Section 80HHA,Section 80IA,Section 143(3),Section 253(1),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH, MP

Before: HON’BLE SHRI KUL BHARAT & SHRI G.D. PADMAHSHALI

For Appellant: Mr G N Purohit [‘Ld. AR’]
For Respondent: Mr N M Prasad [‘Ld. DR’]
Pronounced: 13/05/2026

PER G. D. PADMAHSHALI; By the present appeal filed u/s 253(1) of the Income-tax Act,

1961 [‘the Act’] the assessee impugns order dt. 16/03/2018

passed u/s 250 of the Act by Commissioner of Income

Tax(Appeals-1), Jabalpur [‘Ld. CIT(A)’] which sprung out

from order of assessment dt. 10/08/2006 passed 143(3) r.w.s.

254 of the Act by Asstt. Commissioner of Income Tax Circle,

Sagar [‘Ld. AO’] anent to assessment year 1992-93 [‘AY’].

ITAT-Jabalpur M/s J P Tobacco Products Pvt. Ltd. Vs ACIT ITA No. 185/JAB/2016 AY: 1992-93

2.

Briefly stated the relevant facts of the case are that;

3.

1 The assessee is a private limi

The order continues below.

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