ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

ITA 371/IND/2023Status: DisposedITAT Indore17 October 2024AY 2013-14Bench: SHRI VIJAY PAL RAO (Judicial Member), SHRI B.M. BIYANI (Accountant Member)57 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee's activities constituted manufacturing eligible for deduction under Section 80IB(11A), following various judicial precedents. The Tribunal also found that the reopening of assessment by the AO was not justified.

What were the facts?

The assessee, Prataap Snacks Limited, claimed deduction under Section 80IB(11A) for manufacturing potato-based snacks. The Assessing Officer (AO) disallowed this claim, leading to appeals by both the assessee and the revenue.

What were the issues?

Whether the assessee's activities qualify for deduction under Section 80IB(11A) and whether the reopening of assessment under Section 147 was valid.

Which sections of the Income-tax Act were involved?

Section 80IB(11A),Section 147,Section 148,Section 143(3)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(20)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI VIJAY PAL RAO & SHRI B.M. BIYANI

For Appellant: Shri Satnam
For Respondent: Shri Ram Kumar, CIT-DR
Hearing: 24.09.2024

Per Bench:

Prataap Snacks Limited ITA Nos.370 to 374 & C.O No.6 & 7

These 5 appeals by the Revenue for Assessment Years

2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 and two Cross

Objections by assessee for the Assessment Years 2012-13 &

2013-14 are directed against the consolidated order dated

31.07.

2023 of the Commissioner o

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80IB(11A)

All 71 judgments and leading authorities on Section 80IB(11A) →

Recent GST High Court judgments

Search GST case law →