DILIP BUILDCON LTD ,BHOPAL vs. DCIT CENTRAL-1, BHOPAL
In the result, appeal of Assessee is allowed
ITA 163/IND/2021[2018-19]Status: DisposedITAT Indore20 Oct 2022AY 2018-19
Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2018-19 M/S. Dilip Buildcon Ltd. Acit Central-1 Bhopal Bhopal बनाम/ Vs. (Appellant / Assessee) (Respondent /Revenue) Pan: Aaccd 6124 B Assessee By Shri Hitesh Chimnani & Shri Yash Kukreja, Ld. Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 18.10.2022 Date Of Pronouncement 20.10.2022
Section 143(2)Section 143(3)Section 32(1)(iia)Section 32A
…as has been categorically held by the hon'ble Supreme Court. The learned standing counsel would also rely on the decisions of the Delhi High Court in CIT v. Minocha Brothers P. Ltd. [1986] 60 ITR 134 (Delhi) and Bhagat Construction Co. Pvt. Ltd. v. CIT [1998] 232 ITR 722 (Delhi). Page 20 of 25 Dilip Buildcon Ltd. Assessment year 2018-19 8. At the outset, we are called upon to answer the question of law arising & from the majority decision; whether the making of RMC can be termed to be manufacture and it qualifies as a thing or article. Both the Tribunal Members, who found that the product of RMC does not invol…