JAYDEEP PETRO CHEM CO. PVT.LTD.,CHENNAI vs. ITO, CORP. WARD-2(3), CHENNAI

ITA 179/CHNY/2025Status: DisposedITAT Chennai18 July 2025AY 2006-0717 pages
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What did the Tribunal hold?

The Tribunal held that contractual workers engaged by the assessee should be counted towards the minimum of 10 workers required for the deduction. The Tribunal also found that the volume of sales indicated that contractual workers were indeed involved in manufacturing activities.

What were the facts?

The assessee claimed deduction under Section 80IB(2)(iv) for AYs 2006-07 and 2007-08. The AO denied the deduction, stating the assessee was not a manufacturer and did not employ more than 10 workers. This was confirmed by the CIT(A).

What were the issues?

Whether contractual workers are to be included in the count of employees for Section 80IB(2)(iv) and whether the assessee was engaged in manufacturing activities.

Which sections of the Income-tax Act were involved?

Section 80IB(2)(iv)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HON’BLE SHRI MANU KUMAR GIRI & HON’BLE SHRI AMITABH SHUKLA

Hearing: 16.06.2025Pronounced: 18.07.2025

Heard together (2 matters)

ITA No.179/Chny/2025
ITA No.180/Chny/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER AMITABH SHUKLA, A.M :

The below mentioned two appeals have been filed by the appellant

assessee for AY-2006-07 to AY-2007-08 contesting the order of Ld. First

Appellate Authority indicated Column-E, herein below:-

S. Appeal AYs Appellant CIT(A) Order Details Respondent No. Nos

The order continues below.

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