DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. BARAMATI AGRO LIMITED , PUNE

ITA 395/PUN/2026Status: DisposedITAT Pune25 August 2026AY 2021-2215 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing a deduction under Section 80-IA. The Assessing Officer had disallowed a portion of the deduction claimed by the assessee, arguing it exceeded book profits. The Revenue also appealed the CIT(A)'s direction not to reduce carried forward MAT credit pending appeal.

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision, stating that the deduction under Section 80-IA should be computed based on profits as per the Act, including all allowable deductions, not just book profits. The Tribunal also affirmed the CIT(A)'s order regarding MAT credit, finding no infirmity.

What were the issues?

Whether the deduction under Section 80-IA is to be computed on book profits or profits computed as per the Income Tax Act, and whether MAT credit reduction is permissible when the underlying assessment is pending appeal.

Which sections of the Income-tax Act were involved?

Section 80-IA,Section 80AB,Section 32,Section 115JB,Section 115JAA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Nikhil S Pathak
For Respondent: Shri Vishwas S. Mundhe, CIT

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated 28th November, 2025 of the Ld. CIT(A), Pune - 13 relating to assessment year 2021-22. 2. Grounds raised by the Revenue are as under:

1.

On the facts and in the circumstances of the case and in law, the Ld. CIT(A) is not justified by allowing deduction under Section 80-IA amounting to Rs.47,38,81,024/, without appreciating that the deduction is allowable only on the profits and gains of the eligible undertaking as per its commercial/book profits and not on income recomputed after making tax adjustments.

2.

On the facts and in the circumstances of the case and in law, the Ld. CIT(A) is not justified in ignoring the fact

The order continues below.

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