M/S. JAYSHRI EXPORTS (INDIA) LTD.,JETPUR vs. THE DCIT, CIRCLE-1, RAJKOT

ITA 56/RJT/2020Status: DisposedITAT Rajkot25 November 2025AY 2004-05Bench: DR. ARJUN LAL SAINI (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal, following the Supreme Court's decision in CIT vs. M/s. Avani Exports & Anr., held that exporters with turnover below and above Rs. 10 crores should be treated similarly and are eligible for deduction under Section 80HHC.

What were the facts?

The assessee claimed a deduction under Section 80HHC of Rs. 25,90,947 for AY 2004-05. The Assessing Officer restricted this deduction to Rs. 2,17,759 based on amended provisions of Section 80HHC and Section 28, considering a business loss after excluding certain incentives.

What were the issues?

The primary issue was the correct calculation of deduction under Section 80HHC in light of retrospective amendments and the applicability of Supreme Court judgments to the assessee's case.

Which sections of the Income-tax Act were involved?

Section 80HHC,Section 28,Section 143(3),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: DR. ARJUN LAL SAINI

For Appellant: Shri Chetan Agarwal, Ld. AR
For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Hearing: 17/09/2025Pronounced: 25/11/2025

Per, Dr. Arjun Lal Saini, A.M: Captioned appeal filed by the assessee, pertaining to Assessment Year 2004- 05, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals) (‘CIT(A)’), dated 30.07.2019, which in turn arises out of an assessment order passed by the Assessing Officer u/s. 143(3) of the Act on 27.12.2006. 2. The grounds of appeal raised by the assessee are as follows: M/s. Jayshri Exports (Indi

The order continues below.

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