THE THE HIND SAMACHAR LTD,NEW DELHI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

ITA 122/ASR/2017Status: DisposedITAT Amritsar31 August 2026AY 2012-134 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that since both units operate under the same PAN, they are treated as a single taxable entity. Therefore, losses and profits must be computed collectively for taxation purposes.

What were the facts?

The assessee, The Hind Samachar Ltd. (Delhi Unit), claimed that its brought forward unabsorbed business losses and depreciation should be adjusted against its business profits. The Assessing Officer (AO) and the Commissioner (Appeals) disallowed this claim.

What were the issues?

Whether brought forward losses and depreciation of one unit can be set off against the profits of another unit of the same assessee when they share the same PAN.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

For Appellant: CA for Delhi Group and Sh. Sudhir Sehgal, Advocate
Hearing: 21.07.2026Pronounced: 31.08.2026

Per: Udayan Dasgupta, JM: This appeal if filed by the assessee against the order of the CIT(A), passed u/s 250(6) of the Income Tax Act 61 dated 04.11.2016 for A.Y. 2012-13, which has emanated from the order of the AO /ACIT Circle – III, Jalandhar , dated 31/12/2014 passed u/s 143(3) of the Act.

2.

The Grounds of appeal taken in Form 36 by the “ Delhi Unit ” are as follows:

Assessment Years: 2012-13 Assessment Years: 2012-13

3.

The Ld AR of the assessee ( Delhi Unit ) has not filed any written submissions and during the course of hearing he submit

The order continues below.

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