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

ITA 373/IND/2023Status: DisposedITAT Indore17 October 2024AY 2020-21Bench: SHRI VIJAY PAL RAO (Judicial Member), SHRI B.M. BIYANI (Accountant Member)57 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's activities qualified for deduction under Section 80IB(11A), considering the processing of potatoes into chips as manufacturing. The Tribunal also found that the reopening of assessment by the AO was not valid in this case.

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 constitute manufacturing eligible for deduction under Section 80IB(11A), and whether the reopening of assessment under Section 147 was justified.

Which sections of the Income-tax Act were involved?

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

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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.

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