APTIVE COMPONENTS INDIA P.LTD (FORMERLY KNOWN AS M/S DELPHI AUTOMOTIVE SYSTEMS PVT. LTD.),NEW DELHI vs. DCIT CIRCLE-3(1), NEW DELHI

ITA 1129/DEL/2020Status: DisposedITAT Delhi19 December 2025AY 2005-06Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI BRAJESH KUMAR SINGH (Accountant Member)8 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee is entitled to the consequential benefit of deduction under Section 10A of the Act, in respect of disallowance/addition made by the AO. This decision was based on the principles established by the Hon'ble Bombay High Court and affirmed by the Hon'ble Apex Court in similar cases, which held that statutory disallowances enhance the profits eligible for Section 10A deduction.

What were the facts?

The assessee, M/s Aptiv Components India Private Limited, filed its return of income, and during assessment under Section 143(3), an advance written off of Rs. 94,14,147/- was disallowed. This disallowance was confirmed up to the Tribunal level. The assessee claimed a consequential benefit of deduction of Rs. 2,94,25,184/- under Section 10A of the Income Tax Act, arguing that any additions/disallowances should increase the profits eligible for Section 10A deduction.

What were the issues?

Whether the assessee is eligible for a consequential benefit of deduction under Section 10A of the Income Tax Act on enhanced profits resulting from statutory disallowances/additions made by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 10A,Section 143(3),Section 14A,Section 43B,Section 36(v),Section 2(24)(x),Section 40(a),Section 40(a)(ia),Section 260A

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Income Tax Appellate Tribunal, DELHI BENCH, F: NEW DELHI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI BRAJESH KUMAR SINGH

For Appellant: Shri Gagan Kumar, Adv, Shri Gagan Deep, Adv
For Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Hearing: 30.09.2025Pronounced: 19.12.2025

PER BRAJESH KUMAR SINGH, AM:

This appeal was decided by the Co-ordinate Bench of the Tribunal vide order dated 24.10.2023, wherein ground no. 4 of the appeal was decided by observing as under:

“ No arguments were advanced by the ld. AR before us at the time of hearing with regard to Ground no.

4.

Hence, the same is here by dismissed as not pressed.”

ITA No- 1129/Del/2020 M/s Ap"v Components India Pvt. Ltd.

2.

Thereafter, the said order of the Tribunal was recalled in M.A. no. 483/Del/2023 vide order dated 31.07.2025, only for limited purpose of adjud

The order continues below.

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