What is CIT v. Glenmark Pharmaceuticals Ltd. authority for?

A taxpayer is eligible for deduction under Section 80IA for developing and operating infrastructure facilities, with the decision clarifying the distinction between a contractor and a developer for this purpose.

How many judgments cite CIT v. Glenmark Pharmaceuticals Ltd.?

69 judgments on BharatTax cite CIT v. Glenmark Pharmaceuticals Ltd. (324 ITR 199), spanning 2015 to 2025.

Which sections of the Income Tax Act does CIT v. Glenmark Pharmaceuticals Ltd. come up under?

It is most often cited in judgments turning on Section 142(1), Section 271(1)(c), Section 143(2), Section 194C, Section 80-IA, Section 143(3).

CIT v. Glenmark Pharmaceuticals Ltd. (324 ITR 199)

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTUCTURE LIMITED., MUMBAI

In the result, both the appeals of the revenue are allowed for statistical purposes

ITA 5908/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Akash Kumar (vritually appear), CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 143(3)Section 801ASection 80I

…ire issue of difference between Contractor and Developer and after taking into account the decision of ITAT, Hyderabad in the case of Koya Construction Ltd Vs ACIT (2012) as well as decision of Bombay High Court in the case of CIT VS Glenmark Pharmaceuticals (324 ITR 199), the appellant was held as eligible for deduction U/s 801A. The AO has also mentioned this fact in the assessment order and has stated that the disallowance is being done in this year also as all these orders have been subjected to further appeal and hence to maintain judicial consistency. 8.4.2 Further the appellant has listed out the ineligibl…

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD., MUMBAI

In the result, both the appeals of the revenue are allowed for statistical purposes

ITA 5907/MUM/2024[2018-19]Status: DisposedITAT Mumbai29 Dec 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Akash Kumar (vritually appear), CAFor Respondent: Shri R.A. Dhyani, CIT DR

Section 143(3)Section 801ASection 80I

…ire issue of difference between Contractor and Developer and after taking into account the decision of ITAT, Hyderabad in the case of Koya Construction Ltd Vs ACIT (2012) as well as decision of Bombay High Court in the case of CIT VS Glenmark Pharmaceuticals (324 ITR 199), the appellant was held as eligible for deduction U/s 801A. The AO has also mentioned this fact in the assessment order and has stated that the disallowance is being done in this year also as all these orders have been subjected to further appeal and hence to maintain judicial consistency. 8.4.2 Further the appellant has listed out the ineligibl…

MATRIX CLOTHING PRIVATE LIMITED,GURGAON vs. ACIT-CC-18, DELHI

In the result, the appeal of the assessee is partly allowed

ITA 3805/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR

Section 133(6)Section 143(3)Section 144C(5)Section 92C

…ich the corporate guarantee commission was prescribed at the rate of 1%. In the instant case, the assessee had not opted for Safe Harbour Rules. Further, we find the Hon’ble Bombay High Court in the case of CIT Vs. Glenmark Pharmaceuticals Limited reported in 398 ITR 439 (Bom) had held that for computing ALP of guarantee commission, comparison cannot be ITA No. 3805/Del/2024 Matrix Clothing Pvt. Ltd made between the guarantees issued by Commercial Banks for the purpose of benchmarking the transaction of corporate guarantee issued by a holding company for benefit of its AE. It also held that the considerations wh…

MATRIX CLOTHING PRIVATE LIMITED,GURGAON vs. ACIT, CENTRAL CIRCLE-18, DELHI

In the result, the appeal of the assessee is partly allowed

ITA 760/DEL/2022[2017-18]Status: DisposedITAT Delhi01 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR

Section 133(6)Section 143(3)Section 144C(5)Section 92C

…ich the corporate guarantee commission was prescribed at the rate of 1%. In the instant case, the assessee had not opted for Safe Harbour Rules. Further, we find the Hon’ble Bombay High Court in the case of CIT Vs. Glenmark Pharmaceuticals Limited reported in 398 ITR 439 (Bom) had held that for computing ALP of guarantee commission, comparison cannot be ITA No. 3805/Del/2024 Matrix Clothing Pvt. Ltd made between the guarantees issued by Commercial Banks for the purpose of benchmarking the transaction of corporate guarantee issued by a holding company for benefit of its AE. It also held that the considerations wh…

DISTT WOMAN & CHILD DEV OFFICER VIDISH,VIDISHA vs. INCOME TAX OFFICER (TDS- 2), BHOPAL

The appeal of the assessee is allowed for statistical purpose

ITA 253/IND/2025[2015-16]Status: DisposedITAT Indore28 Nov 2025AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 194CSection 201(1)Section 246ASection 250Section 253Section 4

…sale of goods and not a "work contract." Page 3 of 8 Distt Woman & Child Dev Officer ITA No.251 to 253/Ind/2025 8. Further reliance is placed on the following case laws which support the appellant's contentions CIT vs. Glenmark Pharmaceuticals Ltd. (2010) 324 ITR 199 (SC): The Hon'ble Supreme Court held that where a transaction is purely in the nature of the sale of goods, TDS provisions under Section 1940 are not applicable. ITO. vs. V.S. Dempo& Co. Ltd. (2006) 104 TTJ 913 (Mum): The ITAT ruled that when the primary purpose Re of the contract is the sale of goods and no raw material or resource is supplied b…

DISTT WOMAN & CHILD DEV OFFICER VIDISHA,VIDISHA vs. INCOME TAX OFFICER (TDS-2), BHOPAL

The appeal of the assessee is allowed for statistical purpose

ITA 252/IND/2025[2012-13]Status: DisposedITAT Indore28 Nov 2025AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 194CSection 201(1)Section 246ASection 250Section 253Section 4

…sale of goods and not a "work contract." Page 3 of 8 Distt Woman & Child Dev Officer ITA No.251 to 253/Ind/2025 8. Further reliance is placed on the following case laws which support the appellant's contentions CIT vs. Glenmark Pharmaceuticals Ltd. (2010) 324 ITR 199 (SC): The Hon'ble Supreme Court held that where a transaction is purely in the nature of the sale of goods, TDS provisions under Section 1940 are not applicable. ITO. vs. V.S. Dempo& Co. Ltd. (2006) 104 TTJ 913 (Mum): The ITAT ruled that when the primary purpose Re of the contract is the sale of goods and no raw material or resource is supplied b…

DISTT WOMAN & CHILD DEV OFFICER VIDISHA,VIDISHA vs. INCOME TAX OFFICER (TDS-2), BHOPAL

The appeal of the assessee is allowed for statistical purpose

ITA 251/IND/2025[2014-15]Status: DisposedITAT Indore28 Nov 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 194CSection 201(1)Section 246ASection 250Section 253Section 4

…sale of goods and not a "work contract." Page 3 of 8 Distt Woman & Child Dev Officer ITA No.251 to 253/Ind/2025 8. Further reliance is placed on the following case laws which support the appellant's contentions CIT vs. Glenmark Pharmaceuticals Ltd. (2010) 324 ITR 199 (SC): The Hon'ble Supreme Court held that where a transaction is purely in the nature of the sale of goods, TDS provisions under Section 1940 are not applicable. ITO. vs. V.S. Dempo& Co. Ltd. (2006) 104 TTJ 913 (Mum): The ITAT ruled that when the primary purpose Re of the contract is the sale of goods and no raw material or resource is supplied b…

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 231/PUN/2025[2015-16]Status: DisposedITAT Pune23 Oct 2025AY 2015-16

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT

Section 143(2)Section 80

…ire issue of difference between Contractor and Developer and after taking into account the decision of ITAT, Hyderabad in the case of Koya Construction Ltd Vs ACIT (2012) as well as decision of Bombay High Court in the case of CIT VS Glenmark Pharmaceuticals (324 ITR 199), the appellant was held as eligible for deduction U/s 80IA. The AO has also mentioned this fact in the assessment order and has stated that the disallowance is being done in this year also as all these orders have been subjected to further appeal and hence to maintain judicial consistency. 8.4.2 Further the appellant has listed out the ineligibl…

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 230/PUN/2025[2014-15]Status: DisposedITAT Pune23 Oct 2025AY 2014-15

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT

Section 143(2)Section 80

…ire issue of difference between Contractor and Developer and after taking into account the decision of ITAT, Hyderabad in the case of Koya Construction Ltd Vs ACIT (2012) as well as decision of Bombay High Court in the case of CIT VS Glenmark Pharmaceuticals (324 ITR 199), the appellant was held as eligible for deduction U/s 80IA. The AO has also mentioned this fact in the assessment order and has stated that the disallowance is being done in this year also as all these orders have been subjected to further appeal and hence to maintain judicial consistency. 8.4.2 Further the appellant has listed out the ineligibl…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 229/PUN/2025[2013-14]Status: DisposedITAT Pune23 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT

Section 143(2)Section 80

…ire issue of difference between Contractor and Developer and after taking into account the decision of ITAT, Hyderabad in the case of Koya Construction Ltd Vs ACIT (2012) as well as decision of Bombay High Court in the case of CIT VS Glenmark Pharmaceuticals (324 ITR 199), the appellant was held as eligible for deduction U/s 80IA. The AO has also mentioned this fact in the assessment order and has stated that the disallowance is being done in this year also as all these orders have been subjected to further appeal and hence to maintain judicial consistency. 8.4.2 Further the appellant has listed out the ineligibl…