CIT v. Heartland KG Information Limited

359 ITR 1High Court2013#2933 most cited

What is CIT v. Heartland KG Information Limited authority for?

A change in shareholding or ownership of an undertaking does not affect its eligibility for deduction under Section 80IA if the business itself is not reconstructed. The benefit is tied to the undertaking, not the owner.

41

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Heartland KG Information Limited · section 80IA · deduction · change in ownership · shareholding · reconstruction of business · eligible undertaking

Also reported as

39 Taxmann.com 132

Sections most often in play

Section 10ASection 10A(2)Section 10A(2)(iii)Section 10BSection 10B(2)Section 10B(2)(iii)Section 115BBESection 133A

Issues it is cited on

section 80ia(4)going concernsection 10btax benefitdeduction under section 80iaeligible businessdeduction u/s 80iasection 10asection 80iasection 80isection 10scrutiny assessment

Judgments citing CIT v. Heartland KG Information Limited

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

ITA 3321/CHNY/2024[2018-19]Status: DisposedITAT Chennai05 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

For Appellant: Shri A. Sasikumar, CITFor Respondent: Shri.M.V.Prasad, C.A.&
Section 3Section 801ASection 801A(3)(ii)Section 80I

…आयकर अपीलीय अिधकरण,‘बी’ "ायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH, CHENNAI "ी धु"ु" आर. एल रे"ी, उपा"" एवं "ी एस.आर.रघुनाथा, लेखा सद" के सम" BEFORE SHRI DUVVURU RL REDDY, VICE PRESIDENT AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपीलसं/.ITA Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19 Assistant Commissioner of Shri Kumarasamy Ramakrishnan, Income Tax, vs. Ramakrishna Poultry Farm, Central Circle -1, Trichy. No.79, Main Road, Thalavapalayam, Karur, Tamil Nadu – 639 113. [PAN:AAGPR-3421-A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरस…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

ITA 3316/CHNY/2024[2020-21]Status: DisposedITAT Chennai05 Jun 2025AY 2020-21

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 निर्धारण वर्ष / Assessment Years: 2019-20, 2020-21 & 2018-19 Assistant Commissioner Of Income Taxх, Central Circle -1, Trichy. (अपीलार्थी/Appellant) Vs. Shri Kumarasamy Ramakrishnan, Ramakrishna Poultry Farm, No.79, Main Road, Thalavapalayam, Karur, Tamil Nadu – 639 113. [Pan:Aagpr-3421-A] (प्रत्यर्थी/Respondent) अपीलार्थीकी ओरसे/Appellant By : Shri A. Sasikumar, Cit प्रत्यर्थीकी ओरसे/Respondent By : Shri.M.V.Prasad, C.A.& Shri.K.S.Rajendra Kumar, C.A. सुनवाईकीतारीख/Date Of Hearing : 27.03.2025 घोषणाकीतारीख/Date Of Pronouncement : 05.06.2025 आदेश / Order Per S. R. Raghunatha: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai-19, Dated 07.10.2024, 04.10.2024 &04.10.2024And Pertain To Assessment Years 2019-20, 2020-21&2018-19 Respectively. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Filed By The Revenue Are Being Heard Together & Disposed Off, By This Consolidated Order. :-2-:

For Appellant: Shri A. Sasikumar, CITFor Respondent: Shri.M.V.Prasad, C.A.&
Section 3Section 801ASection 801A(3)Section 801A(3)(ii)Section 80I

…आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL, 'B' BENCH, CHENNAI श्री धुव्वुरु आर. एल रेड्डी, उपाध्यक्ष एवं श्री एस.आर. रघुनाथा, लेखा सदस्य के समक्ष BEFORE SHRI DUVVURU RL REDDY, VICE PRESIDENT AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपीलसं/.ITA Nos.:3315, 3316 & 3321/Chny/2024 निर्धारण वर्ष / Assessment Years: 2019-20, 2020-21 & 2018-19 Assistant Commissioner of Income Taxх, Central Circle -1, Trichy. (अपीलार्थी/Appellant) vs. Shri Kumarasamy Ramakrishnan, Ramakrishna Poultry Farm, No.79, Main Road, Thalavapalayam, Karur, Tamil Nadu – 639 113. [PAN:AAGPR-3421-A] (प्रत्…

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

ITA 906/HYD/2024[2018-19]Status: DisposedITAT Hyderabad27 Nov 2024AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

For Appellant: Shri Rakesh Joshi, CAFor Respondent: : Shri Gudimella V P Pavan
Section 80I

…assets and liabilities would not constitute formation of undertaking by splitting up or reconstruction of existing business. He has also relied upon the decision of the Hon'ble Madras High Court in the case of CIT vs. Heartland KV Information Ltd, reported in 359 ITR 1 (Mad.) as well as the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Tata Communications Internet Services Ltd reported in 251 CTR 290 (Del.) and submitted that the Hon'ble Delhi High Court has considered an identical issue of 80IA and held that a mere change of ownership/ pattern of shareholding does not make any difference for th…

LANCO SOLAR (GUJARAT) PRIVATE LIMITED ,HYDERABAD vs. ITO., WARD-16(1), HYDERABAD

In the result, appeals filed by the assessee are allowed

ITA 905/HYD/2024[2017-18]Status: DisposedITAT Hyderabad27 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

For Appellant: Shri Rakesh Joshi, CAFor Respondent: : Shri Gudimella V P Pavan
Section 80I

…assets and liabilities would not constitute formation of undertaking by splitting up or reconstruction of existing business. He has also relied upon the decision of the Hon'ble Madras High Court in the case of CIT vs. Heartland KV Information Ltd, reported in 359 ITR 1 (Mad.) as well as the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Tata Communications Internet Services Ltd reported in 251 CTR 290 (Del.) and submitted that the Hon'ble Delhi High Court has considered an identical issue of 80IA and held that a mere change of ownership/ pattern of shareholding does not make any difference for th…

ACC LIMITED,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by department is dismissed

ITA 800/MUM/2022[2013-14]Status: DisposedITAT Mumbai30 Jun 2023AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blem/S. Acc Limited V. Dcit (Ltu) 121, Cement House, M.K. Road 29Th Floor, Center-1 Churchgate, Mumbai-400020 World Trade Centre, Cuffe Parade Mumbai - 400005 Pan: Aaact1507C (Appellant) (Respondent) Asst. Cit – 3(4) V. M/S. Acc Limited 29Th Floor, Center-1 Cement House,121, M.K. Road World Trade Centre, Cuffe Parade Churchgate, Mumbai-400020 Mumbai-400005 Pan: Aaact1507C (Appellant) (Respondent)

Section 14A

…ner thereof and successor will be entitled to benefit for the unexpired period. In support of such contention Ld. AR has lied upon following decisions: (i). CIT vs Sonata Software Ltd 343 ITR 397 Bombay High Court (ii). CIT vs Heartland KG Information Limited 359 ITR 1, Madras High court (iii). ITO vs Hindustan Petroleum Corporation Ltd 25 TJ28. 58. Thus, Ld.AR has claimed that assessee is entitled for deduction u/s.80IA on both the units. So far as observation of Ld.CIT(A) that assessee is not entitled to deduction u/s 80IA for TG-2 as deduction u/s.80IA was first claimed in notes forming part of return of incom…

ASST. COMMISSIONER OF INCOME TAX-3(4), MUMBAI-400005 vs. M/S. ACC LIMITED, MUMBAI-400020

In the result, appeal filed by department is dismissed

ITA 1171/MUM/2022[2013-14]Status: DisposedITAT Mumbai30 Jun 2023AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blem/S. Acc Limited V. Dcit (Ltu) 121, Cement House, M.K. Road 29Th Floor, Center-1 Churchgate, Mumbai-400020 World Trade Centre, Cuffe Parade Mumbai - 400005 Pan: Aaact1507C (Appellant) (Respondent) Asst. Cit – 3(4) V. M/S. Acc Limited 29Th Floor, Center-1 Cement House,121, M.K. Road World Trade Centre, Cuffe Parade Churchgate, Mumbai-400020 Mumbai-400005 Pan: Aaact1507C (Appellant) (Respondent)

Section 14A

…ner thereof and successor will be entitled to benefit for the unexpired period. In support of such contention Ld. AR has lied upon following decisions: (i). CIT vs Sonata Software Ltd 343 ITR 397 Bombay High Court (ii). CIT vs Heartland KG Information Limited 359 ITR 1, Madras High court (iii). ITO vs Hindustan Petroleum Corporation Ltd 25 TJ28. 58. Thus, Ld.AR has claimed that assessee is entitled for deduction u/s.80IA on both the units. So far as observation of Ld.CIT(A) that assessee is not entitled to deduction u/s 80IA for TG-2 as deduction u/s.80IA was first claimed in notes forming part of return of incom…

DCIT CENT. CIR -8(1) , MUMBAI vs. M/S. ALLCARGO LOGISTIC LTD, MUMBAI

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

ITA 2046/MUM/2021[2017-18]Status: DisposedITAT Mumbai27 Mar 2023AY 2017-18

Bench: Shri Baskaran Br & Shir Pavan Kumar Gadaledcit C.Cir 8(1), Vs. All Cargo Logistic Ltd Room No. 656, 6Th Floor, 6Th Floor, Avvashya Aayakar Bhavan, House, Cst Road, Mk Road, Kalina, Santacruz (E), Mumbai – 400020. Mumbai – 400098. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacca2894D Appellant .. Respondent Appellant By : Mr.Manoj Kumar Sinha.Dr Respondent By : Mr.Madhur Agrawal, Mr Fenil Bhatt & Mr. Chimanlal Dangi.Ar Date Of Hearing 10.01.2023 Date Of Pronouncement 20.02.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-50, Mumbai, Passed U/S 250 Of The Act. The Revenue Has Raised The Fallowing Grounds Of Appeal:

For Appellant: Mr.Manoj Kumar Sinha.DRFor Respondent: Mr.Madhur Agrawal, Mr Fenil
Section 143(2)Section 250Section 4Section 80Section 801ASection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI BASKARAN BR, ACCOUNTANT MEMBER & SHIR PAVAN KUMAR GADALE, JUDICIAL MEMBER DCIT C.CIR 8(1), Vs. All cargo Logistic Ltd Room No. 656, 6th Floor, 6th Floor, Avvashya Aayakar Bhavan, House, CST Road, MK Road, Kalina, Santacruz (E), Mumbai – 400020. Mumbai – 400098. "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AACCA2894D Appellant .. Respondent Appellant by : Mr.Manoj Kumar Sinha.DR Respondent by : Mr.Madhur Agrawal, Mr Fenil Bhatt & Mr. Chimanlal Dangi.AR Date of Hearing 10.01.2023 Date of Pronouncement 20.02.2023 आदेश / O R D E R PER PAVAN KUMAR GADALE…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

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

ITA 3178/MUM/2019[2011-12]Status: DisposedITAT Mumbai28 Feb 2023AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 14Section 143(3)Section 14A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3177/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Feb 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3176/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

ACC LTD.,MUMBAI vs. ADDL CIT(LTU) , MUMBAI

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

ITA 3139/MUM/2019[2011-12]Status: DisposedITAT Mumbai28 Feb 2023AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 14Section 143(3)Section 14A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

ACC LTD.,MUMBAI vs. ADDL CIT(LTU) , MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3137/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Feb 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3136/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3135/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 268/MUM/2019[2008-09]Status: DisposedITAT Mumbai28 Feb 2023AY 2008-09

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Ltu (Formerly Known As The Associated Cement 29Th Floor, Center-1 Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai-400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Dy. Cit - Ltu-1 V. M/S. Acc Limited 29Th Floor, Center-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai-400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 14A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

ACC LTD ( FORMELRY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD),MUMBAI vs. ADDLL CIT ,(LTU), MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 6638/MUM/2018[2008-09]Status: DisposedITAT Mumbai28 Feb 2023AY 2008-09

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Ltu (Formerly Known As The Associated Cement 29Th Floor, Center-1 Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai-400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Dy. Cit - Ltu-1 V. M/S. Acc Limited 29Th Floor, Center-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai-400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 14A

…urt in the case of Mega Packages [2011] 203 Taxman 236 while considering the eligibility of deduction under section 80-IC on conversion of proprietorship concern into a partnership firm and Hon’ble Madras High court in the case of Heartland KG Information Ltd 359 ITR 1. 66. Thus, the crux of all the above decisions clearly suggest that deduction u/s 80IA is available to undertaking and change in ownership does not mean that unit is established by split up or reconstruction of entire business. Considering ratio laid down by various courts as referred supra, assessee is entitled to deduction u/s 80IA on two units p…

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3246/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Feb 2023AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Ltd., V. Dcit – Range – 1(1) Mumbai {Formerly Known As The Associated Cement Companies, Ltd.,} Cement House, 121 M.K. Road, Churchgate Mumbai - 400020 Pan: Aaact1507C (Appellant) (Respondent) Dcit (Ltu)-1 V. M/S. Acc Ltd., 29Th Floor, Centre No.1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON'BLE JUDICIAL MEMBER M/s. ACC Ltd., V. DCIT – Range – 1(1) Mumbai {Formerly Known as The Associated Cement Companies, Ltd.,} Cement House, 121 M.K. Road, Churchgate Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) DCIT (LTU)-1 V. M/s. ACC Ltd., 29th Floor, Centre No.1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) Assessee represented by : Shri Yogesh Thar…

ACC LIMITED (FORMERLY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD.),MUMBAI vs. ADDLL. CIT ,RG. 1(1), MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3203/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Feb 2023AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Ltd., V. Dcit – Range – 1(1) Mumbai {Formerly Known As The Associated Cement Companies, Ltd.,} Cement House, 121 M.K. Road, Churchgate Mumbai - 400020 Pan: Aaact1507C (Appellant) (Respondent) Dcit (Ltu)-1 V. M/S. Acc Ltd., 29Th Floor, Centre No.1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON'BLE JUDICIAL MEMBER M/s. ACC Ltd., V. DCIT – Range – 1(1) Mumbai {Formerly Known as The Associated Cement Companies, Ltd.,} Cement House, 121 M.K. Road, Churchgate Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) DCIT (LTU)-1 V. M/s. ACC Ltd., 29th Floor, Centre No.1 Cement House, 121 World Trade Centre, Cuffe Parade M.K. Road, Churchgate Mumbai - 400005 Mumbai - 400020 PAN: AAACT1507C (Appellant) (Respondent) Assessee represented by : Shri Yogesh Thar…

ACC LTD,MUMBAI vs. ASST CIT LTU, MUMBAI

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

ITA 6082/MUM/2014[2007-08]Status: DisposedITAT Mumbai28 Feb 2023AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 145A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON'BLE JUDICIAL MEMBER ITA NO.4669/MUM/2012 (A.Y: 2007-08) M/s. ACC Limited v. Addl. CIT – LTU (Formerly known as The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 PAN: AAACT1507C (Appellant) (Respondent) Addl. CIT – LTU v. M/s. ACC Limited 28th Floor, Centre – 1 (Formerly known as The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai-400005 Churchgate, Mumbai-40…

ACC LIMITED (FORMERLY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD.),MUMBAI vs. ACIT - LTU, MUMBAI

ITA 417/MUM/2014[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON'BLE JUDICIAL MEMBER M/s. ACC Limited v. Addl. CIT -Range 1(1) (Formerly known as The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 PAN: AAACT1507C (Appellant) (Respondent) M/s. ACC Limited v. Asst. CIT-LTU (Formerly known as The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 PAN: AAACT1507C (Appellant) (Respondent) ACIT – LTU v. M/s. ACC Limited 28th Floor, Centre-…

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