Addl. CIT v. Delhi Press Patra Prakashan

10 SOT 74Income Tax Appellate Tribunal2006#5919 most cited

What is Addl. CIT v. Delhi Press Patra Prakashan authority for?

An Assessing Officer cannot arbitrarily adjust the profit margin of a specific unit by comparing it to the overall profit margin of the assessee, especially when the units have different business natures and separate books of accounts are maintained.

19

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Addl. CIT v. Delhi Press Patra Prakashan · section 10AA · section 80-IA · profit margin adjustment · different business units · arbitrary comparison · separate books of account

Sections most often in play

Section 14ASection 35(1)(iv)Section 80JJAASection 10AASection 115BBDSection 35(2AB)Section 80IA(10)Section 80IA(8)

Issues it is cited on

scientific research expendituresection 35(1)(iv)section 115bbdnew employeessection 80ia(8)section 35(1)(i)section 80iabsection 80ia(5)section 35(1)section 92basection 36(l)(iii)r&d expenditure

Judgments citing Addl. CIT v. Delhi Press Patra Prakashan

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 8 1 (INCHARGE), HYDERABAD vs. VIRTUSA CONSULTING SERVICES PRIVATE LIMITED, TAMIL NADU

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2632/CHNY/2024[2013-14]Status: DisposedITAT Chennai14 Nov 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

…adjustment made by the assessing officer by comparing the profit margin of different units is not legally tenable. In this connection, we duly follow the judgement of the Hon’ble Delhi Tribunal in the case of Addl.CIT vs. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi). “We have heard the arguments of both the sides and also perused the relevant material on record. As has been pointed out on behalf of the assessee-company before the authorities below as well as before us, unit 1 was its publishing house whereas units 3 and 4 were its printing houses. The nature of business of unit 1 and unit 4 of the ass…

ASSISTANT COMMISSIONER OF INCOME TAX, HYDERABAD vs. VIRTUSA CONSULTING SERVICES PRIVATE LIMITED, CHENNAI TAMIL NADU

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2631/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

…adjustment made by the assessing officer by comparing the profit margin of different units is not legally tenable. In this connection, we duly follow the judgement of the Hon’ble Delhi Tribunal in the case of Addl.CIT vs. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi). “We have heard the arguments of both the sides and also perused the relevant material on record. As has been pointed out on behalf of the assessee-company before the authorities below as well as before us, unit 1 was its publishing house whereas units 3 and 4 were its printing houses. The nature of business of unit 1 and unit 4 of the ass…

VIRTUSA CONSULTING SERVICES PVT. LTD.,CHENNAI vs. DCIT, CC-5(2), CHENNAI

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2262/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

…adjustment made by the assessing officer by comparing the profit margin of different units is not legally tenable. In this connection, we duly follow the judgement of the Hon’ble Delhi Tribunal in the case of Addl.CIT vs. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi). “We have heard the arguments of both the sides and also perused the relevant material on record. As has been pointed out on behalf of the assessee-company before the authorities below as well as before us, unit 1 was its publishing house whereas units 3 and 4 were its printing houses. The nature of business of unit 1 and unit 4 of the ass…

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

…663/Chny/2024 (AY 2019-20) M/s. Ashok Leyland Ltd. :: 39 :: AO is empowered to disturb the computation of profit, is always a subject matter of controversy. From the side of the assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s.80-IA in respect of a Unit No.4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section (10)…

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

ITA 1402/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1402/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (अपीलार्थी/Appellant) V. The Dcit, Ncc-8(1), Ltu-Ii, Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1663/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 The Dcit, Ncc-8, Chennai. (अपीलार्थी/Appellant) V. M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (प्रत्यर्थी/Respondent) Assessee By : Mr.R. Vijayaraghavan, Advocate Department By : Ms.Ann Marry Baby, Cit सुनवाईकीतारीख/Date Of Hearing : 04.06.2025 घोषणाकीतारीख /Date Of Pronouncement : 07.07.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Cross-Appeals Preferred By The Assessee As Well As The Revenue Against The Order Of The Learned Commissioner Of Income Tax

For Appellant: Mr.R. Vijayaraghavan, AdvocateFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

…1663/Chny/2024 (AY 2019-20) M/s. Ashok Leyland Ltd. :: 39 :: AO is empowered to disturb the computation of profit, is always a subject matter of controversy. From the side of the assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s.80-IA in respect of a Unit No. 4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section (1…

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

ITA 561/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 35Section 35(1)(iv)

…d to disturb the computation of profit, is always a subject matter of ITA Nos.554 & 561/Chny/2023 (AY 2018-19) M/s. Ashok Leyland Ltd. :: 39 :: controversy. From the side of the assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s.80IA in respect of a Unit No.4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section (10)…

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

ITA 554/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 35Section 35(1)(iv)

…d to disturb the computation of profit, is always a subject matter of ITA Nos.554 & 561/Chny/2023 (AY 2018-19) M/s. Ashok Leyland Ltd. :: 39 :: controversy. From the side of the assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s.80IA in respect of a Unit No.4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section (10)…

ADD. CIT SPL RANGE--3, NEW DELHI vs. DLF LTD, NEW DELHI

ITA 5919/DEL/2019[2016-17]Status: DisposedITAT Delhi19 Jul 2023AY 2016-17

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…allocation of expenses. It was further submitted that working of profit in these units is supported from certificate in Form 10CCB issued by Chartered Accountant. The Ld. Counsel also relied upon the decision of Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). 22.4 We have considered the rival submissions and gone through the orders passed by sub-ordinate authorities. The issue before us is allocation of expenses to eligible units claiming deduction u/s 80IA and consequential disallowance in the hands of the assessee company. In short, the assessing officer has observed that common expense…

ADD. CIT SPL RANGE--3, NEW DELHI vs. DLF LTD, NEW DELHI

ITA 2238/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jul 2023AY 2015-16

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…allocation of expenses. It was further submitted that working of profit in these units is supported from certificate in Form 10CCB issued by Chartered Accountant. The Ld. Counsel also relied upon the decision of Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). 22.4 We have considered the rival submissions and gone through the orders passed by sub-ordinate authorities. The issue before us is allocation of expenses to eligible units claiming deduction u/s 80IA and consequential disallowance in the hands of the assessee company. In short, the assessing officer has observed that common expense…

ADDL. CIT, SPECIAL RANGE- 03, NEW DELHI vs. DLF LTD., NEW DELHI

ITA 5978/DEL/2017[2014-15]Status: DisposedITAT Delhi19 Jul 2023AY 2014-15

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…allocation of expenses. It was further submitted that working of profit in these units is supported from certificate in Form 10CCB issued by Chartered Accountant. The Ld. Counsel also relied upon the decision of Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). 22.4 We have considered the rival submissions and gone through the orders passed by sub-ordinate authorities. The issue before us is allocation of expenses to eligible units claiming deduction u/s 80IA and consequential disallowance in the hands of the assessee company. In short, the assessing officer has observed that common expense…

THE ACIT, CENTRAL-2, INDORE vs. M/S. SHAKTI PUMPS (INDIA) LTD., INDORE

ITA 1358/IND/2016[2010-11]Status: DisposedITAT Indore26 Apr 2023AY 2010-11

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2010-11 Acit (Central)-2, Shakti Pumps (India) Ltd. Indore 226, Shastri Market, बनाम/ M.G. Road, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Aaecs 5027 L Revenue By Shri P.K. Mishra, Cit-Dr Assessee By Ms. Nisha Lahoti & Vijay Bansal, Ars Date Of Hearing 23/11/2022 / 22.02.2023 Date Of Pronouncement 26.04.2023

Section 10ASection 143(2)Section 143(3)Section 145Section 263

…ngineering & Industries (P) Ltd. [2015] 60 taxmann.com 440 (Jabalpur), order dated 27.03.2015 is relevant in this regard which dealt with similar aspect of the issue. 2.37 The appellant has placed reliance on the decision of Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s 80IA in respect of a Unit No.4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was XRE only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section P…

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

ITA 1977/DEL/2020[2014-15]Status: DisposedITAT Delhi02 Sept 2022AY 2014-15

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

For Respondent: Shri Vivek Verma
Section 132Section 142Section 144C(4)Section 153ASection 80Section 801BSection 80I

…e drawn a separate profit and loss account. In such a situation, whether AO is empowered to disturb computation of profit, is always a subject matter of controversy. From side of assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, assessee was claiming deduction u/s.80IA in respect of a Unit No.4. said Unit was showing profit @ 62%. a against that, AO has noticed that a margin of profit shown by assessee as a whole was only to extent of 10%. AO has therefore recomputed profit of said Unit by applying subsection. (10) of section 80IA and restrict…

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYAPAL LTD., NEW DELHI

ITA 1976/DEL/2020[2013-14]Status: DisposedITAT Delhi02 Sept 2022AY 2013-14

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

For Respondent: Shri Vivek Verma
Section 144C(4)Section 80Section 801BSection 80I

…e drawn a separate profit and loss account. In such a situation, whether AO is empowered to disturb computation of profit, is always a subject matter of controversy. From side of assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, assessee was claiming deduction u/s.80IA in respect of a Unit No.4. said Unit was showing profit @ 62%. a against that, AO has noticed that a margin of profit shown by assessee as a whole was only to extent of 10%. AO has therefore recomputed profit of said Unit by applying subsection (10) of section 80IA and restricted…

ADDL. CIT, SPECIAL RANGE- 03, NEW DELHI vs. DLF LTD., NEW DELHI

ITA 5941/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Sept 2021AY 2012-13

Bench: Shri Amit Shukla & Prashant Maharishi

For Appellant: Shri Surender Pal, CIT-DRFor Respondent: S/Shri R.S. Singhvi & Satyajeet Goel
Section 14A

…allocation of expenses. It was further submitted that working of profit in these units is supported from certificate in Form 10CCB issued by Chartered Accountant. The Ld. Counsel also relied upon the decision of Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). I.T.As. No.5940 & 5941/DEL/2017 and CO No.5 & 6/DEL/2021 36 22.4 We have considered the rival submissions and gone through the orders passed by sub-ordinate authorities. The issue before us is allocation of expenses to eligible units claiming deduction u/s 80IA and consequential disallowance in the hands of the assessee company. In…

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

ITA 1380/DEL/2017[2012-13]Status: DisposedITAT Delhi07 Oct 2020AY 2012-13

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

Section 115JSection 143Section 144CSection 14ASection 14A(2)Section 36Section 43(5)(d)Section 80I

…e drawn a separate profit and loss account. In such a situation, whether AO is empowered to disturb computation of profit, is always a subject matter of controversy. From side of assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, assessee was claiming deduction u/s.80IA in respect of a Unit No.4. said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by assessee as a whole was only to extent of 10%. AO has therefore recomputed profit of said Unit by applying sub- section (10) of section 80IA and restric…

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

ITA 781/DEL/2015[2010-11]Status: DisposedITAT Ahmedabad05 Sept 2019AY 2010-11

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

For Appellant: Shri S.N.Soparkar, Shri Vartik ChokshiFor Respondent: Shri Mahesh Shah, CIT-DR
Section 143(3)Section 144CSection 92D

…IN THE INCOME TAX APPELLATE TRIBUNAL “ D ” BENCH, AHMEDABAD BEFORE JUSTICE P.P. BHATT, PRESIDENT And SHRI WASEEM AHMED, ACCOUNTANT MEMBER 1. आयकर अपील सं./IT(TP)A No. 1782/Del/2014 2. आयकर अपील सं./IT(TP)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The DCIT बनाम/ 12th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.CIT Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACR0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant by : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan…

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

ITA 1782/DEL/2014[2009-10]Status: DisposedITAT Ahmedabad05 Sept 2019AY 2009-10

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

For Appellant: Shri S.N.Soparkar, Shri Vartik ChokshiFor Respondent: Shri Mahesh Shah, CIT-DR
Section 143(3)Section 144CSection 92D

…IN THE INCOME TAX APPELLATE TRIBUNAL “ D ” BENCH, AHMEDABAD BEFORE JUSTICE P.P. BHATT, PRESIDENT And SHRI WASEEM AHMED, ACCOUNTANT MEMBER 1. आयकर अपील सं./IT(TP)A No. 1782/Del/2014 2. आयकर अपील सं./IT(TP)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The DCIT बनाम/ 12th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.CIT Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACR0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant by : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan…

DCIT, NEW DELHI vs. M/S DHARAMPAL SATYAPAL LTD.,, DELHI

ITA 3883/DEL/2016[2011-12]Status: DisposedITAT Delhi18 Apr 2019AY 2011-12

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

For Appellant: Shri R. S. Singhvi, CAFor Respondent: Shri Sanjay I Bara, CIT DR
Section 142Section 147Section 153Section 153ASection 201(1)Section 36Section 40Section 40A(3)

…e drawn a separate profit and loss account. In such a situation, whether AO is empowered to disturb computation of profit, is always a subject matter of controversy. From side of assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, assessee was claiming deduction u/s.80IA in respect of a Unit No.4. said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by assessee as a whole was only to extent of 10%. AO has therefore recomputed profit of said Unit by applying sub-section (10) of section 80IA and restrict…

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

ITA 196/DEL/2013[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

For Appellant: 1. Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amrendra Kumar, CIT, DR
Section 143Section 143(3)Section 92D

…te profit and loss account. In such a situation, whether the AO is empowered to disturb the computation of profit, is always a subject matter of controversy. From the side of the assessee, reliance was placed on Addl. CIT v. Delhi Press Patra Prakashan [2006] 10 SOT 74 (Delhi) (URO). In this case, the assessee was claiming deduction u/s.80IA in respect of a Unit No.4. The said Unit was showing profit @ 62%. As against that, AO has noticed that a margin of profit shown by the assessee as a whole was only to the extent of 10%. The AO has therefore recomputed the profit of the said Unit by applying sub-section (10)…

Addl. CIT v. Delhi Press Patra Prakashan (10 SOT 74) — Cited in 19 Judgments | BharatTax