CIT v. Impel Forge and Allied

326 ITR 27High Court2010#5762 most cited

What is CIT v. Impel Forge and Allied authority for?

An assessee is entitled to claim deductions under Section 80IC (and other similar sections like 80IB) for profits derived from job work charges, as carrying out such work is considered part of the manufacturing process of an industrial undertaking.

20

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2025.

Also referred to as

CIT v. Impel Forge & Allied Industries Ltd · 326 ITR 27 · Section 80IC · Section 80IB · job work charges · manufacturing process · industrial undertaking · deduction for profits · P&H High Court

Sections most often in play

Section 115JBSection 234DSection 271(1)(c)Section 37(1)Section 80HHCSection 92C(4)Section 143(3)Section 43B

Issues it is cited on

section 80hhc(3)section 28(iv)section 115jasection 234dsection 80hhsection 80hhccorporate guaranteeright to receivesection 80ibsection 92ca(3)section 80iasection 254(1)

Judgments citing CIT v. Impel Forge and Allied

Uniphos Enterprises Ltd, Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 3878/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04
For Appellant: "I. TAXABILITY OF ADVANCE LICENCE BENEFIT RECEIVABLE: Rs.9,79
Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…ob work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the Id CIT-DR for the revenue, on various items supported the order of Id CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was argued…

Asst CIT CC 38, Mumbai vs. Uniphos Enterprises Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 3534/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the ld CIT-DR for the revenue, on various items supported the order of ld CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was ar…

Addl CIT Cen RG IX, Mumbai vs. Uniphos Enterprises Ltd ( Formlery Known As United Phosphorus Ltd), Mumbai

In the result, the appeal of assessee is allowed

ITA 6236/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the ld CIT-DR for the revenue, on various items supported the order of ld CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was ar…

Uniphos Enterprises Ltd ( Formerly Known As United Phosphorus Ltd), Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 6224/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the ld CIT-DR for the revenue, on various items supported the order of ld CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was ar…

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the ld CIT-DR for the revenue, on various items supported the order of ld CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was ar…

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…work charges submits that in AY 2000-03 she has not pressed such item for inclusion in eligible for 80IB, however, this item is also covered in favour of assessee by the decision of Punjab & Haryana High Court in CIT Vs Impel Forge & allied Industries Ltd (326 ITR 27 P&H), Madras High Court in CIT Vs Light Alloy Product Ltd (373 ITR 322 Mad) and Mumbai Tribunal in ACIT Vs Nagendra Polyplast ( 69 SOT 718 Mumbai). 68. On the other hand, the ld CIT-DR for the revenue, on various items supported the order of ld CIT(A) and in revenues appeal supported the stand of AO. In without prejudice submissions, it was ar…

Murcury Rubber Mills, Delhi vs. ACIT Circle 36(1), New Delhi

In the result, the Appeal of the Assessee is partly allowed for statistical purpose

ITA 1549/DEL/2019[2013-14]Status: DisposedITAT Delhi06 Dec 2022AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.I.T.A. No. 1549/Del/2019 (A.Y 2013-14)

Section 80I

…of the decisions in the cases of (i) Commissioner of Income Tax v. Metalman Auto (P) Ltd., (2011) 52 DTR (P&H) 385; (ii) Commissioner of Income Tax v. Vallabh Yarns (P.) Ltd., (2011) 51 DTR (P&H) 236; (iii) CIT v. Impel Forge & Allied Industries Ltd., (2010) 326 ITR 27 (P&H), (iv) CIT v. Rane (Mad) Ltd., 238 ITR 377 9 Murcery Rubber Mills Vs. ACIT (Mad), and (v) Dy. CIT v. Harjivandas Juthabhai Zaveri & Another, 258 ITR 785 (Gujarat). 13. Keeping in view the activities of the assessee in giving heat treatment for which it had earned labour charges and job-work charges, it can thus be said that the appellant h…

Asstt.Commissioner of Income Tax, Ludhiana vs. M/S Mrs.Bectors Food Specilties Ltd, Ludhiana

ITA 559/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh21 May 2018AY 2013-14

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

Asstt.Commissioner of Income Tax, Ludhiana vs. M/S Mrs.Bectors Food Specilties Ltd, Ludhiana

ITA 558/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh21 May 2018AY 2012-13

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

Asstt.Commissioner of Income Tax, Ludhiana vs. M/S Mrs.Bectors Food Specilties Ltd, Ludhiana

ITA 557/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh21 May 2018AY 2011-12

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

Asstt.Commissioner of Income Tax, Ludhiana vs. M/S Mrs.Bectors Food Specilties Ltd, Ludhiana

ITA 556/CHANDI/2017[2010-11]Status: DisposedITAT Chandigarh21 May 2018AY 2010-11

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

Asstt.Commissioner of Income Tax, Ludhiana vs. M/S Mrs.Bectors Food Specilties Ltd, Ludhiana

ITA 555/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh21 May 2018AY 2007-08

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

ACIT, Ludhiana vs. M/S Mrs. Bectors Food Specialties Pvt. Ltd., Ludhiana

ITA 405/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh21 May 2018AY 2008-09

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: Sh. Subhash AggarwalFor Respondent: Smt. Chandrakanta
Section 14ASection 36Section 80I

…ion that even vis-à-vis prof i ts derived from job work charges the assessee is entitled u/s 80IC of the Act . The Ld.CIT(Appeals) relying upon the decision of the Hon'ble jurisdictional High Court in the case of CIT Vs. Impel Forge & Allied Industries Ltd. , 326 ITR 27 and the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Northern Aromatics Ltd. (2005) 196 CTR 479 held that the assessee was entitled to claim deduct ion on profits earned on account of job work undertaken by i t holding as under: Further, the basic process is carried out by the appellant is the same whether the production is don…

M/S A.P. Processors, Delhi vs. ITO, New Delhi

In the result, ITA No.4345/Del/2015 of the assessee is partly allowed for

ITA 4346/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Oct 2016AY 2010-11

Bench: Smt Diva Singh

Section 32(1)(iia)

…e cases of (i) CIT vs. Metalman Auto(P)m Ltd. ( 011) 52 DTR (P&H) 385; (ii) CIT vs. Vallabh Yams (P) Ltd. (2011) 51 DTR (P&H) 236; (iii) CIT vs. Impel Forge & I.T.A .No.-4345 & 4346/Del/2015 (A.P.PROCESSORS VS ITO) Page 3 of 7 Allied Industries Ltd. (2010) 326 ITR 27 (P&H); (iv) CIT vs. Rane (Madras) Ltd. (1998) 148 CTR (Mad) 404 : (1999) 238 ITR 377 (Mad) and (v) Dy, CIT vs. Harjivandas Juthabhai Zaveri & Anr. (2002) 258 ITR 785 (Guj.) strengthens our aforesaid view. In view of the above detailed discussions and precedents, we hold that assessee is a manufacturer and eligible for deduction u/s 32(1)(iia) of t…

M/S A.P. Processors, Delhi vs. ITO, New Delhi

In the result, ITA No.4345/Del/2015 of the assessee is partly allowed for

ITA 4345/DEL/2015[2009-10]Status: DisposedITAT Delhi21 Oct 2016AY 2009-10

Bench: Smt Diva Singh

Section 32(1)(iia)

…e cases of (i) CIT vs. Metalman Auto(P)m Ltd. ( 011) 52 DTR (P&H) 385; (ii) CIT vs. Vallabh Yams (P) Ltd. (2011) 51 DTR (P&H) 236; (iii) CIT vs. Impel Forge & I.T.A .No.-4345 & 4346/Del/2015 (A.P.PROCESSORS VS ITO) Page 3 of 7 Allied Industries Ltd. (2010) 326 ITR 27 (P&H); (iv) CIT vs. Rane (Madras) Ltd. (1998) 148 CTR (Mad) 404 : (1999) 238 ITR 377 (Mad) and (v) Dy, CIT vs. Harjivandas Juthabhai Zaveri & Anr. (2002) 258 ITR 785 (Guj.) strengthens our aforesaid view. In view of the above detailed discussions and precedents, we hold that assessee is a manufacturer and eligible for deduction u/s 32(1)(iia) of t…

DCIT, Madurai vs. Penguin Apparels P Ltd., Madurai

In the result, the appeal of the Revenue in ITA

ITA 390/CHNY/2014[2009-10]Status: DisposedITAT Chennai27 Apr 2016AY 2009-10

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2230/Mds/2013 & 390/Mds/2014 "नधा"रण वष" /Assessment Years : 2010-2011 & 2009-2010. The Assistant Commissioner M/S. Penguin Apparels P. Ltd. Of Income Tax, Vs. Plot No.2, Meenakshmi Nagar, Circle I(1) Gst Road, Pasumalai, Madurai Madurai 625 004. [Pan Aabcp 7832P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. A.V. Sreekanth, IRS, JCITFor Respondent: Shri. R. Srinivasan, Advocate
Section 115JSection 143(1)Section 143(2)Section 143(3)

…the ld. Authorised Representative being that the nature of job works are similar to the business and the assessee has rightfully claimed deduction in respect of Sec 80IB of the Act and we rely on the findings of CIT vs. Impel Forge & Allied Industries Ltd 326 ITR 27 were it was held that once it is found that the assessee is deriving income from eligible businesses covered by Sec.80IB, apart from other conditions, the assessee is at liberty to do manufacturing activity not only for himself but for others also. Consequently profits derived from job work done for others also quality for deduction under sec. 8…

ACIT, Madurai vs. M/S. Penguin Apparels P. Ltd., Madurai

In the result, the appeal of the Revenue in ITA

ITA 2230/CHNY/2013[2010-11]Status: DisposedITAT Chennai27 Apr 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2230/Mds/2013 & 390/Mds/2014 "नधा"रण वष" /Assessment Years : 2010-2011 & 2009-2010. The Assistant Commissioner M/S. Penguin Apparels P. Ltd. Of Income Tax, Vs. Plot No.2, Meenakshmi Nagar, Circle I(1) Gst Road, Pasumalai, Madurai Madurai 625 004. [Pan Aabcp 7832P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. A.V. Sreekanth, IRS, JCITFor Respondent: Shri. R. Srinivasan, Advocate
Section 115JSection 143(1)Section 143(2)Section 143(3)

…the ld. Authorised Representative being that the nature of job works are similar to the business and the assessee has rightfully claimed deduction in respect of Sec 80IB of the Act and we rely on the findings of CIT vs. Impel Forge & Allied Industries Ltd 326 ITR 27 were it was held that once it is found that the assessee is deriving income from eligible businesses covered by Sec.80IB, apart from other conditions, the assessee is at liberty to do manufacturing activity not only for himself but for others also. Consequently profits derived from job work done for others also quality for deduction under sec. 8…

Daman Plastics, Mumbai vs. Addl CIT Cir 15(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 7507/MUM/2012[2009-10]Status: DisposedITAT Mumbai16 Dec 2015AY 2009-10
For Appellant: Shri Anuj KisnadwalaFor Respondent: Shri Satyajit Mandal, DR
Section 80DSection 80I

…he case of Sadhu Forging Ltd (2011) 336 ITR 444 has held that sale of scrap / labour charges and job work charges are allowable as deduction u/s 80IB of the Act. Similar view has been expressed in the case of CIT vs. Impel Forge & Allied Industries Ltd (2010) 326 ITR 27 (P & H). In this case, the Hon‟ble Punjab & Haryana High Court has held that the assessee was engaged in manufacturing and trading of tractor and auto parts and also doing job works of similar nature. The assessee was at liberty to do manufacture for itself or for others, which makes no difference for the purposes of section 80IB of the Act. Accor…

CIT vs. Sadhu Forging Ltd

ITA - 351 / 2011HC Delhi03 Jun 2011
Section 37Section 80Section 80I

…of the decisions in the cases of (i) Commissioner of Income Tax v. Metalman Auto (P) Ltd., (2011) 52 DTR (P&H) 385; (ii) Commissioner of Income Tax v. Vallabh Yarns (P.) Ltd., (2011) 51 DTR (P&H) 236: (iii) CIT v. Impel Forge & Allied Industries Ltd., (2010) 326 ITR 27 (P&H), (iv) CIT v. Rane (Mad) Ltd., 238 ITR 377 (Mad), and (v) Dy. CIT v. Harjivandas Juthabhai Zaveri & Another, 258 ITR 785 (Gujarat). - 13. Keeping in view the activities of the assessee in giving heat treatment for which it had earned labour charges and job-work charges, it can thus be said that the appellant had done a process on the raw mate…

CIT vs. Sadhu Forging Ltd

ITA - 167 / 2011HC Delhi03 Jun 2011
Section 37Section 80Section 80I

…he decisions in the cases of (i) Commissioner of Income Tax v. Metalman Auto (P) Ltd., (2011) 52 DTR (P&H) 385; (ii) Commissioner of Income Tax v. Vallabh Yarns (P.) Ltd., (2011) 51 DTR (P&H) 236; (iii) CIT v. Impel Forge & Allied Industries Ltd., (2010) 326 ITR 27 (P&H), (iv) CIT v. Rane (Mad) Ltd., 238 ITR 377 (Mad), and (v) Dy. CIT v. Harjivandas Juthabhai Zaveri & Another, 258 ITR 785 (Gujarat). 13. Keeping in view the activities of the assessee in giving heat treatment for which it had earned labour charges and job-work charges, it can thus be said that the appellant had done a process on the raw…

CIT v. Impel Forge and Allied (326 ITR 27) — Cited in 20 Judgments | BharatTax