ACIT, RAJKOT vs. CRYSTAL GLOBAL INDUSTRIES, RAJKOT

ITA 538/RJT/2025Status: DisposedITAT Rajkot31 August 2026AY 2014-1529 pages
AI SummaryPartly Allowed

What were the facts?

The assessee claimed 100% deduction under Section 80-IC for AY 2014-15, arguing a substantial expansion in FY 2011-12 made them eligible. The Assessing Officer disallowed this, stating the assessee had already exhausted the 5-year period for 100% deduction and the expansion did not qualify for fresh eligibility.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer's rejection of the assessee's books of accounts was not tenable, especially when purchases were accepted and the books were audited. Consistency with previous years' treatment of accounts was also a significant factor.

What were the issues?

Whether a substantial expansion in business activity qualifies for a fresh period of 100% deduction under Section 80-IC, and whether the rejection of the assessee's books of accounts by the Assessing Officer was justified.

Which sections of the Income-tax Act were involved?

Section 80-IC,Section 143(3),Section 145(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Mehul Ranpura, Ld. AR
For Respondent: Shri Rajneesh Yadav, Ld. CIT. DR
Hearing: 09/07/2026Pronounced: 31/08/2026

Per, Dr. Arjun Lal Saini, AM: Captioned two appeals filed by the Revenue and one appeal filed by the assessee, pertaining to assessment years (AY) 2011-12, 2013-14 & 2014-15, are directed against the separ

The order continues below.

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