ACG Associated Capsules (P) Ltd. v. CIT

343 ITR 89Supreme Court of India2012#708 most cited

What is ACG Associated Capsules (P) Ltd. v. CIT authority for?

For calculation of deduction under Section 80HHC, if total interest is netted off after adjusting interest paid and received, the 90% reduction specified in Explanation (baa) is not applicable.

144

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

ACG Associated Capsules · Section 80HHC · Explanation (baa) · 90% reduction · interest income · netting off interest · profits of business · deduction calculation · gross interest · net interest · 343 ITR 89

Also reported as

247 CTR 372

Sections most often in play

Section 115JASection 80HHCSection 80IBSection 143(3)Section 250Section 30Section 37(1)Section 44D

Issues it is cited on

section 80hsection 80hhcsection 80hhdeduction under section 80iasection 80iaeligible businesssection 80isection 30profits and gains of business or professionbook profitssection 115jrevenue expenditure

Judgments citing ACG Associated Capsules (P) Ltd. v. CIT

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

ITA 3723/DEL/2013[2009-10]Status: DisposedITAT Dehradun23 May 2025AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

…d in toto. 6. That the Ld. CIT (Appeals) has erred in not following decisions of the Hon'ble Apex Court and High Court in the appellant's favour regarding netting off of interest including ACG Associated Capsules (P) Ltd. v. CIT and CIT v. Bharat Rasayan Ltd. 343 ITR 89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012;…

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

ITA 3064/DEL/2013[2007-08]Status: DisposedITAT Dehradun23 May 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

…d in toto. 6. That the Ld. CIT (Appeals) has erred in not following decisions of the Hon'ble Apex Court and High Court in the appellant's favour regarding netting off of interest including ACG Associated Capsules (P) Ltd. v. CIT and CIT v. Bharat Rasayan Ltd. 343 ITR 89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012;…

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

ITA 3929/DEL/2012[2008-09]Status: DisposedITAT Dehradun23 May 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

…d in toto. 6. That the Ld. CIT (Appeals) has erred in not following decisions of the Hon'ble Apex Court and High Court in the appellant's favour regarding netting off of interest including ACG Associated Capsules (P) Ltd. v. CIT and CIT v. Bharat Rasayan Ltd. 343 ITR 89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012;…

M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

ITA 3925/DEL/2012[2008-09]Status: DisposedITAT Dehradun23 May 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

…d in toto. 6. That the Ld. CIT (Appeals) has erred in not following decisions of the Hon'ble Apex Court and High Court in the appellant's favour regarding netting off of interest including ACG Associated Capsules (P) Ltd. v. CIT and CIT v. Bharat Rasayan Ltd. 343 ITR 89 (SC). CIT v. Pawan Kumar Jain 298 ITR 443 (Del.), CIT v. Shahi Export House 195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012;…

M/S. MARICO INDUSTRIES LTD.,MUMBAI vs. ACIT CENT. CIR. - 35, MUMBAI

In the result, the Revenue’s appeal bearing ITA No

ITA 4823/MUM/2006[2002-2003]Status: DisposedITAT Mumbai07 Mar 2025AY 2002-2003

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee- A.Y. 2000-01 - A.Y. 2001-02 - A.Y. 2002-03

For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 801BSection 80H

…ter adjusting interest paid & received. So, the 90% reduction is not applicable for calculation of 80HHC. He stated that the issue is squarely covered by the order of Hon’ble Supreme Court in ACG Associated Capsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as follows: “8. Before we deal with the contentions of learned counsel for the parties, we may extract Explanation (baa) to Section 80HHC of the Act. "Explanation:- For the purposes of this section,- (baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession"…

ACIT C.C.- 35, MUMBAI vs. M/S. MARICO INDSUTRIES LTD., MUMBAI

In the result, the Revenue’s appeal bearing ITA No

ITA 4680/MUM/2006[2002-2003]Status: DisposedITAT Mumbai07 Mar 2025AY 2002-2003

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee- A.Y. 2000-01 - A.Y. 2001-02 - A.Y. 2002-03

For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 801BSection 80H

…ter adjusting interest paid & received. So, the 90% reduction is not applicable for calculation of 80HHC. He stated that the issue is squarely covered by the order of Hon’ble Supreme Court in ACG Associated Capsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as follows: “8. Before we deal with the contentions of learned counsel for the parties, we may extract Explanation (baa) to Section 80HHC of the Act. "Explanation:- For the purposes of this section,- (baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession"…

M/S. MARICO INDUSTRIES LTD. vs. THE ACIT CC-35,

In the result, the Revenue’s appeal bearing ITA No

ITA 2564/MUM/2005[2001-2002]Status: DisposedITAT Mumbai07 Mar 2025AY 2001-2002

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee- A.Y. 2000-01 - A.Y. 2001-02 - A.Y. 2002-03

For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 801BSection 80H

…ter adjusting interest paid & received. So, the 90% reduction is not applicable for calculation of 80HHC. He stated that the issue is squarely covered by the order of Hon’ble Supreme Court in ACG Associated Capsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as follows: “8. Before we deal with the contentions of learned counsel for the parties, we may extract Explanation (baa) to Section 80HHC of the Act. "Explanation:- For the purposes of this section,- (baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession"…

THE ACIT CC-35 vs. M/S. MARICO INDUSTRIES LTD.,

In the result, the Revenue’s appeal bearing ITA No

ITA 1678/MUM/2005[2001-2002]Status: DisposedITAT Mumbai07 Mar 2025AY 2001-2002

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee- A.Y. 2000-01 - A.Y. 2001-02 - A.Y. 2002-03

For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 801BSection 80H

…ter adjusting interest paid & received. So, the 90% reduction is not applicable for calculation of 80HHC. He stated that the issue is squarely covered by the order of Hon’ble Supreme Court in ACG Associated Capsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as follows: “8. Before we deal with the contentions of learned counsel for the parties, we may extract Explanation (baa) to Section 80HHC of the Act. "Explanation:- For the purposes of this section,- (baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession"…

ACIT C.C. 35, MUMBAI vs. M/S. MARICO FOODS LTD., MUMBAI

In the result, the Revenue’s appeal bearing ITA No

ITA 7397/MUM/2004[2000-2001]Status: DisposedITAT Mumbai07 Mar 2025AY 2000-2001

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee- A.Y. 2000-01 - A.Y. 2001-02 - A.Y. 2002-03

For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 801BSection 80H

…ter adjusting interest paid & received. So, the 90% reduction is not applicable for calculation of 80HHC. He stated that the issue is squarely covered by the order of Hon’ble Supreme Court in ACG Associated Capsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as follows: “8. Before we deal with the contentions of learned counsel for the parties, we may extract Explanation (baa) to Section 80HHC of the Act. "Explanation:- For the purposes of this section,- (baa) "profits of the business" means the profits of the business as computed under the head "Profits and gains of business or profession"…

M/S. MARICO INDUSTRIES LTD.,MUMBAI vs. DCIT CEN. CIR. - 35, MUMBAI

In the result, the Revenue's appeal bearing ITA No

ITA 7124/MUM/2004[2000-2001]Status: DisposedITAT Mumbai07 Mar 2025AY 2000-2001
For Appellant: Shri Nitesh Joshi & Shri MilinFor Respondent: Ms. Monica H Pande,SR AR
Section 115JSection 143(3)Section 250Section 80HSection 80I

…adjusting interest paid & received. So, the 90%\nreduction is not applicable for calculation of 80HHC. He stated that the issue is\nsquarely covered by the order of Hon'ble Supreme Court in ACG Associated\nCapsules (P.) Ltd. v. CIT, Central-IV, Mumbai (2012) 343 ITR 89 (SC), held as\nfollows:\n\n“8. Before we deal with the contentions of learned counsel for the parties, we may extract\nExplanation (baa) to Section 80HHC of the Act.\n\"Explanation:- For the purposes of this section,-\n(baa) \"profits of the business\" means the profits of the business as computed under the head\n\"Profits and gains of business or…

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 1172/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad26 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Vartik Choksi, With Shri DhrunalBhatt, ARsFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 14ASection 35Section 43BSection 80

…ting of the interest for disallowance under Section 80IA of the Act. In this respect, we notice that in the decision of the Supreme Court in case of ACG Associated Capsules (P.) Ltd. v. Commissioner of Income Tax[2012] 18 taxmann.com 137/205 Taxman 136 (Mag.)/343 ITR 89 such issue in the context of deduction under Section 80HHC of the Act has been settled. It is held that it would only be the net of the interest excluding the expenditure incurred in earning such interest income which should be excluded for the purpose of under Section 80 HHC of the Act. To our mind, same would apply even when the revenue desirous…

M/S. UNITED PHOSPHORUS LTD.,MUMBAI vs. DCIT CENT. CIR. - 38, MUMBAI

In the result, appeal of the revenue is partly allowed

ITA 4695/MUM/2005[1999-2000]Status: DisposedITAT Mumbai20 Sept 2023AY 1999-2000

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W), Mumbai – 400 052 Pan: Aaacu3440P ...... Appellant Vs. Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ..... Respondent Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ...... Appellant Vs. M/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W) Mumbai – 400 052 Pan: Aaacu3440P ...... Respondent (Now Known As Uniphos Enterprises Ltd.)

For Appellant: Ms. Vasanti B Patel / Shri KiritFor Respondent: Shri Rajneesh Yadav
Section 143(3)Section 37(1)

…only to the net receipts and accordingly, gross receipts cannot be reduced from the profits of the business. In support of the above contention, reliance is placed on the decision of the Hon'ble Apex court in case of ACG Associated Capsules Pvt. Ltd vs. CIT (343 ITR 89). Attention is further invited to the following decisions passed by the ITAT in the assessee's own case: a) AY 1994-95-ITA No. 184/Ahd/1998 (Para 38-39 at page A142 of the Paper- book Volume II) b) AY 1995-96-ITA No. 1516/Ahd/2002 (Para 17.7 at page A122 of the Paper- book Volume II) c) AY 1998-99-ITA No. 1519/A/02 (Para 11.3.5 at page A185-A186 o…

MMTC LTD. vs. DCIT, CIRCLE-5(1),,

The appeal is allowed, with aforesaid consequences, as directed in ground wise findings

ITA 1722/DEL/2006[2003-2004]Status: DisposedITAT Delhi30 Jun 2023AY 2003-2004

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmam/S. Mmtc Ltd., Scope Vs. Dcit, Complex, Circle-5(1) Core 1,7, Institutional Area, New Delhi Lodhi Road, New Delhi- 110003 Pan : (Appellant) (Respondent)

Section 143(3)Section 44ASection 80Section 80H

…de the above items as not forming part of business profits in computing relief under Section 80HHC of the Act.” 22. In this context Hon’ble Supreme Court of India in ACG Associated Capsules Private Ltd. (Formerly Associated Capsules Private Ltd. v. CIT [2012] 343 ITR 89 (SC) is also relevant where with regard to items covered under the Expln. (baa) and their treatment, it was held; “9. Explanation (baa) extracted above states that "profits of the business" means the profits of the business as computed under the head "Profits and Gains of Business or Profession" as reduced by the receipts of the nature mentioned…

DCIT CIR. 6 (3), MUMBAI vs. M/S. GRASIM INDUSTRIES LTD., MUMBAI

In the result, the appeal by the Revenue is dismissed

ITA 4337/MUM/2005[2004-2005]Status: DisposedITAT Mumbai23 Jun 2023AY 2004-2005

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43BSection 80Section 80HSection 80I

…The next grievance of the assessee relates to allowing deduction u/s 80HHC of the Act with respect to interest income. The issue under consideration is squarely covered by the decision of Hon'ble Supreme Court in the case of ACG Associated Capsules Pvt. Ltd., 343 ITR 89(SC) wherein it was held that net interest income is to be excluded from the eligible profit for computing deduction u/s 80HHC rather than gross interest. 15. An identical issue raised as additional grounds for the assessment year 1996-97 and 97-98 was considered and decided by this Tribunal in assessee's own case in paras 30 & 30.1 as under: "30 A…

M/S. GRASIM INDUSTRIES LTD.,MUMBAI vs. DCIT CIT CIR. 6(3), MUMBAI

In the result, the appeal by the Revenue is dismissed

ITA 3439/MUM/2005[2004-2005]Status: DisposedITAT Mumbai23 Jun 2023AY 2004-2005

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43BSection 80Section 80HSection 80I

…The next grievance of the assessee relates to allowing deduction u/s 80HHC of the Act with respect to interest income. The issue under consideration is squarely covered by the decision of Hon'ble Supreme Court in the case of ACG Associated Capsules Pvt. Ltd., 343 ITR 89(SC) wherein it was held that net interest income is to be excluded from the eligible profit for computing deduction u/s 80HHC rather than gross interest. 15. An identical issue raised as additional grounds for the assessment year 1996-97 and 97-98 was considered and decided by this Tribunal in assessee's own case in paras 30 & 30.1 as under: "30 A…

DCIT CIR 6(3), MUMBAI vs. M/S. GRASIM INDUSTRIES LTD., MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 5978/MUM/2004[2003-2004]Status: DisposedITAT Mumbai13 Jun 2023AY 2003-2004

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistry a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(3)Section 250Section 43BSection 80Section 80H

…The next grievance of the assessee relates to allowing deduction u/s 80HHC of the Act with respect to interest income. The issue under consideration is squarely covered by the decision of Hon'ble Supreme Court in the case of ACG Associated Capsules Pvt. Ltd., 343 ITR 89(SC) wherein it was held that net interest income is to be excluded from the eligible profit for computing deduction u/s 80HHC rather than gross interest. 15. An identical issue raised as additional grounds for the assessment year 1996-97 and 97-98 was considered and decided by this Tribunal in assessee's own case in paras 30 & 30.1 as under: "30 A…

GRASIM INDUSTRIES LTD.,MUMBAI vs. DCIT RANGE 6(3), MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 4754/MUM/2004[2003-04]Status: DisposedITAT Mumbai13 Jun 2023AY 2003-04

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistry a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(3)Section 250Section 43BSection 80Section 80H

…The next grievance of the assessee relates to allowing deduction u/s 80HHC of the Act with respect to interest income. The issue under consideration is squarely covered by the decision of Hon'ble Supreme Court in the case of ACG Associated Capsules Pvt. Ltd., 343 ITR 89(SC) wherein it was held that net interest income is to be excluded from the eligible profit for computing deduction u/s 80HHC rather than gross interest. 15. An identical issue raised as additional grounds for the assessment year 1996-97 and 97-98 was considered and decided by this Tribunal in assessee's own case in paras 30 & 30.1 as under: "30 A…

M/S. ZENSAR TECHNOLOGIES LTD,MUMBAI vs. THE ACIT -2(3), MUMBAI

In the result, appeal filed by the revenue is dismissed

ITA 2908/MUM/2008[2003-2004]Status: DisposedITAT Mumbai12 May 2023AY 2003-2004

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Zensor Technologies Ltd V. Acit-2(3) Magnet House, 2Nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 Pan: Aaacf0742K (Appellant) (Respondent) Acit- 2(3) V. M/S. Zensor Technologies Ltd Room No. 555, Aayakar Bhavan Magnet House, 2Nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 Pan: Aaacf0742K (Appellant) (Respondent)

Section 10ASection 80HSection 92Section 92(1)Section 92CSection 94(7)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRI ABY T VARKEY, HON’BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER M/s. Zensor Technologies Ltd v. ACIT-2(3) Magnet House, 2nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 PAN: AAACF0742K (Appellant) (Respondent) ACIT- 2(3) v. M/s. Zensor Technologies Ltd Room No. 555, Aayakar Bhavan Magnet House, 2nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 PAN: AAACF0742K (Appellant) (Respondent) Assessee Represented by : Shri Nitesh Joshi Department Represented by : Shri. Karan P.…

M/S MIRZA SONS MIRZA,SRINAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SRINAGAR

In the result, the appeal filed by the assesse is dismissed

ITA 7/ASR/2019[2003-04]Status: DisposedITAT Amritsar31 Jan 2023AY 2003-04

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 56Section 80H

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T. A. No. 07/Asr/2019 Assessment Year: 2003-04 M/s Mirza Sons Mirza Bagh V. The Asstt. Commissioner of Nageen, Srinagar Income Tax, Circle-3, Srinagar [PAN: AACFM 1237B] (Respondent) (Appellant) Appellant by Sh. P. N. Arora, Adv. Respondent by Ms. Priyanka Singla, Sr. D.R. Date of Hearing : 20.12.2022 Date of Pronouncement : 31.01.2023 ORDER Per Dr. M. L. Meena, AM: The present appeal has been filed by the assessee against the order of the Ld. Commissi…

M/S. SNEHA KINETIC POWER PROJECTS PVT. LTD,,HYDERABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal filed by the assessee is partly allowed

ITA 1054/BANG/2022[2014-15]Status: HeardITAT Bangalore19 Dec 2022AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.V.Srinivasan, AdvocateFor Respondent: Sri.Sri.Gudimella V.P.Pavan Kumar, JCIT-DR
Section 142(2)Section 234B

…ided by the Tribunal in assessee’s own case for assessment years 2012-2013 and 2013-2014 (supra). The Tribunal in the above case, by following the judgment of the Hon’ble Supreme Court in the case of ACG Associates Capsules Pvt. Ltd. v. CIT reported in (2012) 343 ITR 89 (SC) had directed the A.O. to adopt the netting method. The relevant finding of the Tribunal reads as follows:- “7. Next comes Mr.Rama Rao yet another plea that both the lower authorities ought to have adopted netting method by following the decision of Hon’ble apex court ACG Associated 5 M/s.Sneha Kinetic Power Projects Pvt.Ltd. Capsules Pvt.…

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