ACIT, CIRCLE vs. SHEENA INDUSTRIES,,

ITA 1229/DEL/2006Status: DisposedITAT Delhi03 February 2026AY 1999-2000Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. Naveen Chandra (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal noted that the Supreme Court's decision in CIT vs. M/s Carpet India allowed for re-examination of whether the assessees were direct exporters. Since the assessees had only claimed as supportive manufacturers, the Assessing Officer was directed to re-examine the issue afresh.

What were the facts?

The Revenue filed appeals challenging the CIT(A)'s orders granting deductions under Section 80HHC and 80IB to the assessees as 'supportive' manufacturers. This was the second round of proceedings following a Supreme Court decision.

What were the issues?

Whether 'supportive' manufacturers are entitled to deductions under Section 80HHC on par with direct exporters, and if the assessees can prove they are also direct exporters.

Which sections of the Income-tax Act were involved?

Section 80HHC,Section 80IB

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘F’, NEW DELHI

Before: Sh. Satbeer Singh Godara & Sh. Naveen Chandra

For Respondent: Ms. Monika Singh, CIT-DR
Hearing: 03.02.2026Pronounced: 03.02.2026

Heard together (3 matters)

ITA No. 1229/Del/2006
ITA No. 1228/Del/2006
ITA No. 970/Del/2007

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

Per Satbeer Singh Godara, Judicial Member:

The Revenue has filed it’s identical twin appeals ITA Nos. 1228 & 1229/Del/2006; for assessment years 1999-2000 and 2002-03, in the former assessee M/s Sheena Industries case(s), against the CIT(A), Karnal’s as many years dated 13 & 14.02.2006; respectively. It’s third appeal ITA No. 970/Del/2007 involving M/s Sheena Exports, in assessment year 2003-04, has arisen against the very CIT(A)’s order dated 18.12.2006 in issue. Relevant proceedings in all these cases are u/s 143(3).

2.

Cases called twice. None appears

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