AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1,, BARODA

ITA 903/AHD/2016Status: DisposedITAT Ahmedabad18 February 2026AY 2011-12Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)11 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT's order was not sustainable as the DPCO liability was already held to be an ascertained liability by the ITAT for the same assessment year. Therefore, the assessment order allowing the deduction was not erroneous.

What were the facts?

The PCIT invoked Section 263, considering the assessee's allowance of an unascertained DPCO liability for book profit calculation under Section 115JB to be erroneous and prejudicial to revenue. The assessee contended that the liability was ascertained and had been allowed as a deduction in prior proceedings.

What were the issues?

Whether the DPCO liability was an ascertained liability for the purpose of computing book profits under Section 115JB, and if the PCIT's revisionary order under Section 263 was justified.

Which sections of the Income-tax Act were involved?

Section 263,Section 115JB,Section 143(3),Section 37(1)

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Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SMT. ANNAPURNA GUPTA

For Appellant: Shri Bandish Soparkar, AR, Shri Alpesh Parmar, CIT.DR
For Respondent: Shri Alpesh Parmar, CIT.DR
Pronounced: 18/02/2026

PER ANNAPURNA GUPTA, AM:

The present appeal has been filed by the assessee against the order of the Principal Commissioner of Income Tax, PCIT, Vadodara-1 (hereinafter referred to as “PCIT”), dated 29.02.2016 invoking his revisional juri iction under Section 263 of the ITA No.903/Ahd/2016 [Ambalal Sarabhai Enterprises Ltd. vs. PCIT] A.Y. 2011-12 - 2 –

Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2011-12. 2. The order in the present appeal was originally passed vide order dated 25.06.2025 dismis

The order continues below.

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