How many judgments cite CIT v. Orient Craft Ltd.?

366 judgments on BharatTax cite CIT v. Orient Craft Ltd. (354 ITR 536), spanning 2015 to 2025.

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

It is most often cited in judgments turning on Section 147, Section 143(3), Section 148, Section 143(2), Section 139, Section 143(1).

CIT v. Orient Craft Ltd.

354 ITR 536High Court2013#204 most cited

What is CIT v. Orient Craft Ltd. authority for?

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

366

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Orient Craft Ltd. · Section 147 · Section 148 · Section 143(1) · fresh tangible material · reason to believe · escapement of income · mere change of opinion · live link · reopening of assessment

Also reported as

29 Taxmann.com 392

Sections most often in play

Section 147 Section 143(3)Section 148 Section 143(2)Section 139 Section 143(1)Section 133A Section 142(1)

Issues it is cited on

fresh tangible material kelvinator beyond four years material facts necessary for assessment first proviso to section 147 mere change of opinion live link change of opinion tangible material short term capital gains reason to believe escapement of income

Judgments citing CIT v. Orient Craft Ltd.

Shri Thakker Paresh Harilal, Bhavnagar vs. The Income Tax Officer, Ward-1(3), Bhavnagar

In the result, all the three appeal of the assessee are allowed

ITA 1376/AHD/2016[2006-07]Status: DisposedITAT Ahmedabad18 Sept 2017AY 2006-07

Bench: Shri Mahavir Prasad & Shri, Manish Borad

For Respondent: Shri Mahesh Jiwade Sr. D.R

Section 143(1)Section 147Section 148

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ *,l *,l *,l-,e *,l ,e ,e-lh* ,e lh* lh* अहमदाबाद । lh* IN THE INCOME TAX APPELLATE TRIBUNAL “ SMC ” BENCH, AHMEDABAD सव"ी महावीर "साद, "या"यक सद"य एवं Ekuh’k cksjM, लेखा सद"य के सम" । Ekuh’k Ekuh’k cksjM Ekuh’k cksjM cksjM BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMBER And SHRI, MANISH BORAD, ACCOUNTANT MEMBER I.T.A. No.1376/Ahd/2016 for A.Y. 2006-07 i. I.T.A. No.1377/Ahd/2016 for A.Y. 2007-08 ii. I.T.A. No.1378/Ahd/2016 for A.Y. 2009-10 iii. Shri Thakker Paresh Harilal Income Tax Officer, बनाम/ Plot No.1528/A, Ward – 1(3), Vs. “NIDHI” Rupani, Bhavnagar. Behind Theosophical Ha…

M/S. Meditronics India Pvt. Ltd., Delhi vs. ITO, New Delhi

The appeal is allowed

ITA 6251/DEL/2012[2004-05]Status: DisposedITAT Delhi12 Sept 2017AY 2004-05

Bench: Shri I. C. Sudhir & Shri L. P. Sahui. T. Appeal No. 6251/Del/2012 Assessment Year : 2004-2005. M/S. Meditronics India Pvt. Ltd., Income Tax Officer, 41, Pocket–Ii, Jasola, Vs. Ward : 6 (3), D E L H I – 110 025. New Delhi. Pan : Aadcm 3622 Q (Appellant) (Respondent)

For Appellant: Shri Salil Aggarwal, Adv.; &For Respondent: Shri Gudrun Nehra, Sr. D. R

Section 147

…24/2013 dated 14.02.2014). 3. Unless there is fresh material, as distinguished from mere allegation in the form of information, recourse under section 147 of the Act cannot be resorted: Commissioner of Income-tax vs. M/s Orient Craft i) Limited reported in 354 ITR 536 (SLP filed by the revenue has been dismissed by the Apex Court) ii) COMMISSIONER OF INCOME TAX Vs. SHRI ATUL KUMAR SWAMI (ITA No. 112/2014 dated 18.03.2014); 9 I. T. Appeal No. 6251/Del/2012 Assessment Year : 2004-2005. MOHAN GUPTA (HUF) vs. CIT (W.P.(C) 7660/2012 dated iii. 28.01.2014) HC (Delhi) following Orient Craft. Bapalal & Co. Exports…

DCIT 9(1)(1), Mumbai vs. Acon Measurement P.Ltd, Mumbai

The appeal of the Revenue is dismissed and the

ITA 4736/MUM/2015[2009-10]Status: DisposedITAT Mumbai06 Sept 2017AY 2009-10

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2009-10 Dcit -9(1))(1), M/S Acon Measurement Pvt. Room No.260A, 02Nd Floor बनाम/ Limited, Aayakar Bhavan A-22, Nanddham Indl. Estate, Vs. M.K. Road Marol Maroshi Road, Mumbai-400020. Andheri (East), Mumbai-400059 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No. Aaaca5078K

Section 133(6)

…1) 336 ITR 59 (Raj.), vii. Emirates Shipping Line FZE vs Asst. DIT (2012) 349 ITR 493 (Del.). viii. Reference may also made to following judicial decisions:- ix. Safetag international India P. Ltd. (2011) 332 ITR 622 (Del.), x. CIT vs Orient Craft Ltd. (2013) 354 ITR 536 (Del.) xi. Acorus Unitech Wirelss Pvt. Ltd. vs ACIT (2014) 362 ITR 417 (Del.). xii. Praful Chunilal Patel: Vasant Chunilal Patel vs Asst. CIT (1999) 832, 843-44, 844-45 (Guj.), xiii. Venus Industrial Corporation vs Asst. CIT (1999) 236 ITR 742, 746 (Punj.), C.O. No.112/Mum/2017 xiv. Srichand Lalchand Talreja vs Asst. CIT (1998) 98 taxman 14, 19…

Sheetal V. Bhat, Chennai vs. ACIT, Chennai

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

ITA 272/CHNY/2017[2007-08]Status: DisposedITAT Chennai28 Jun 2017AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri AR.V. Sreenivasan, JCIT

Section 143(1)Section 147Section 148

…95 ITR 499), found that the assessment cannot be reopened without any material disclosing escapement of income. In fact, according to the Ld. counsel, the Madras High Court placed its reliance on the judgment of Delhi High Court in CIT v. Orient Craft Ltd. (354 ITR 546). Therefore, according to the Ld. counsel, the reopening of assessment is not justified. 3 I.T.A. No.272/Mds/17 3. On the contrary, Shri AR.V. Sreenivasan, the Ld. Departmental Representative, submitted that the return of income was admittedly processed under Section 143(1) of the Act. It is not a case that there was no material for opening…

Pitney Bowes India (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, out of the five appeals of the assessee, the ITA Nos

ITA 289/DEL/2013[2005-06]Status: DisposedITAT Delhi29 May 2017AY 2005-06

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

Section 143(3)Section 147Section 32

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’, NEW DELHI BEFORE SH. I.C. SUDHIR, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTANT MEMBER ITA Nos. 289 to 293/Del/2013 Assessment Years: 2005-06 to 2009-10 Vs. DCIT, Circle-14(1) / Addl.CIT, M/s. Pitney Bowes India (P) Ltd., 2nd Floor, 45, Okhla Industrial Range-14 / Income Tax Officer, Estate, Phase-III, New Delhi Ward -14(3), New Delhi PAN : AADCP3417C (Appellant) (Respondent) Appellant by S/sh. G.C. Srivastava, Adv.; Manoneet Dalal, Adv.; Anubhav Jain and Anshul Kumar, CA Respondent by Sh. F.R. Meena, Sr.DR Date of hearing 30.03.2017 Date of pronouncement 29.…

ACIT, CIT-2(1), Kolkata vs. M/S Bnk E Solution Pvt. Ltd., Kolkata

In the result, the appeal by the Revenue is dismissed and the C

ITA 1613/KOL/2016[2006-07]Status: DisposedITAT Kolkata19 May 2017AY 2006-07

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am]

For Appellant: Shri D.S.Damle, FCAFor Respondent: Shri Banibrata Dutta, Addl. CIT(DR)

Section 10ASection 143(3)Section 147Section 148Section 70(1)Section 72

…15 ) has taken the view that that even in the case of original assessment order having been passed u/s 143(1), it is mandatory for the AO to have in its possession, fresh tangible material before reopening of the case. In the case of CIT vs. Orient Craft Ltd. 354 ITR 536, it was held by Hon’ble Delhi High Court that reasons for reassessment disclosed that AO reached belief that there was escapement of income "on going through the return of income" filed by assessee after he accepted return u/s. 143(1) without scrutiny, and nothing more. In these facts, it was held by the Hon’ble High Court that it was nothing but…

Pr. Commissioner of Income Tax(Central)-3 vs. Ksa Chits Private Limited

ITA/522/2016HC Delhi19 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 148

…x, Delhi v. Kelvinator of India Ltd. [2010] 187 taxman 312 (SC). Reliance was also placed on the decisions of this Court in Mohan Gupta (HUF) v. Commissioner of Income Tax [2014] 366 ITR 115 (Del) and Commissioner of Income tax v. Orient Craft Ltd. [2013] 354 ITR 536 (Del) which was affirmed by the Supreme Court by the dismissal of the Special Leave Petition filed by the Revenue on 20th January, 2014. 16. In reply, Mr. Ashok Manchanda, learned counsel for the Revenue, submitted that although the Petitioner may have disclosed the BTA and the fact of claiming depreciation by allocating the professional…

DCIT, New Delhi vs. M/S. Federal Mogul Goetze India Ltd., Delhi

In the result, both the appeals filed by the revenue are dismissed

ITA 3441/DEL/2014[2004-05]Status: DisposedITAT Delhi20 Apr 2017AY 2004-05

Bench: Shri N.K. Saini & Shri Amit Shukla

For Appellant: Sh. Pradeep Dinsdia, AdvocateFor Respondent: Sh. Anil Kumar Sharma, Sr. DR

Section 143(1)Section 143(3)Section 144Section 147Section 147oSection 263Section 43Section 43BSection 44A

…tta and Ors. vs. Lakhmani Mewal Das 1976 (103) ITR 437 (Supreme Court) iv. Sri Krishna Pvt. Ltd. Etc. v. Income Tax Officer, Calcutta and Ors. (1996) 9 SCC 534 v. CIT vs. Kelvinator, (2010) 2CC 723 /320 ITR 561 (Supreme Court) vi. CIT vs. Orient Craft, (2013) 354 ITR 536 (Del) The final conclusion of the Learned CIT (Appeals) for quashing the reassessment order reads as under:- “In this case, the original assessment was completed by the Assessing Officer u/s 143(3) of the Act on 27.12.2006. The details of the interest payable were filed by the appellant before the Assessing Officer vide letter dated 24th March,…

The Pr. Commissioner of Income Tax-4 vs. M/S Home Linkers E-Services Pvt. Ltd

The appeal is allowed

ITA/90/2017HC Delhi22 Mar 2017

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 143Section 147Section 148Section 260ASection 47

…e to the tune of Rs.64,88,024/- has escaped assessment. Issue notice u/s 148 of the IT Act, 1961." The ITAT followed the ruling of the Supreme Court in CIT v. Kelvinator of India Ltd. 320 ITR 561 and the judgment of this Court in CIT v. Orient Craft Ltd. 354 ITR 536 and held as follows: “We have carefully considered the rival contentions as well as the order of the lower authorities on the basis of the reasons recorded which are reproduced above. Certainly it shows that reopening is made only on the basis of reappraisal of existing material though assessment is made u/s 14311) of the Act. There is no…

Disha N . Lalwani, Mumbai vs. ITO WD 23(2)(2), Mumbai

The appeal of the assessee is dismissed

ITA 6398/MUM/2012[2003-04]Status: DisposedITAT Mumbai22 Mar 2017AY 2003-04

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2003-04 Disha N. Lalwani, Income Tax Officer- J-301, Vardhaman Nagar 23(2)(2), बनाम/ Jn. Of R.P. Rd. & M.G. Rd. C-10-Pratyakshkar Vs. Mulund (W), Bhavan, 02Nd Floor, Mumbai-400080 Bandra Kurla Complex, Bandra, Mumbai-400007 ("नधा"रती/Assessee) (राज"व /Revenue) P.A. No. Aaapl6056H

Section 143(1)Section 143(3)Section 147Section 148

…1) 336 ITR 59 (Raj.), vii. Emirates Shipping Line FZE vs Asst. DIT (2012) 349 ITR 493 (Del.). viii. Reference may also made to following judicial decisions:- ix. Safetag international India P. Ltd. (2011) 332 ITR 622 (Del.), x. CIT vs Orient Craft Ltd. (2013) 354 ITR 536 (Del.) xi. Acorus Unitech Wirelss Pvt. Ltd. vs ACIT (2014) 362 ITR 417 (Del.). xii. Praful Chunilal Patel: Vasant Chunilal Patel vs Asst. CIT (1999) 832, 843-44, 844-45 (Guj.), xiii. Venus Industrial Corporation vs Asst. CIT (1999) 236 ITR 742, 746 (Punj.), xiv. Srichand Lalchand Talreja vs Asst. CIT (1998) 98 taxman 14, 19 (Bom.), xv. Usha Beltr…

Just Textiles Ltd, Ambernath vs. DCIT RG 10(3), Mumbai

In the result, appeal of the assessee is allowed in terms indicated hereinabove

ITA 1907/MUM/2015[2008-09]Status: DisposedITAT Mumbai21 Mar 2017AY 2008-09

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm M/S.Just Textiles Ltd., K-5, Vs. Dcit Rg 10 (3), Mumbai - Additional Midc Anand 400020 Nagar (E), Ambernath – 421506 Pan/Gir No. Aaacj1221D Appellant) .. Respondent)

Section 143(3)Section 148Section 48Section 50

…165 (Delhi) • Asian Paints Ltd. v. CIT [2009] 308 ITR 195 (Bom.) • CIT v. Jet Speed Audio Pvt. Ltd. (2015) 372 ITR 762 (Bom.) • Yash Raj Films P. Ltd. v. ACIT (2011) 332 ITR 428 (Bom.) • Mohan Gupta (HUF) vs. CIT 366 ITR 115(Delhi) • CIT vs. Orient Craft Ltd. 354 ITR 536(Delhi) • Housing Development Finance Corporation Ltd. v. J. P. Janjid 5 M/s. Just Textiles Ltd., (2014) 225 Taxman 81(Mag.) (Bom) 9. It was also contended by learned AR that subsequently Assessing Officer cannot improve upon the reasons which were originally communicated to the assessee. Our attention was also invited to the order of the AO wher…

M. Pallonji & Co. P.Ltd, Mumbai vs. Jt, CIT RG 2(2), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 1594/MUM/2013[2004-05]Status: DisposedITAT Mumbai23 Jan 2017AY 2004-05

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Year: 2004-05 M. Pallonji & Co. Pvt. Ltd. Jcit, C/O- Taj Printing Works, Range-2(2), बनाम/ 46/A, Cawasji Patel Street, Aayakar Bhavan, Vs. Fort, M.K. Road, Mumbai-400001 Mumbai-400020 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No.Aaacm3525B

Section 139Section 142Section 143Section 147Section 148Section 80I

…Shipping Line FZE vs Asst. DIT (2012) 349 ITR 493 (Del.). viii. Reference may also made to following judicial decisions:- ix. Safetag international India P. Ltd. (2011) 332 ITR 622 (Del.), 10 M/s M. Pallonji & Co. Pvt. Ltd. x. CIT vs Orient Craft Ltd. (2013) 354 ITR 536 (Del.) xi. Acorus Unitech Wirelss Pvt. Ltd. vs ACIT (2014) 362 ITR 417 (Del.). xii. Praful Chunilal Patel: Vasant Chunilal Patel vs Asst. CIT (1999) 832, 843-44, 844-45 (Guj.), xiii. Venus Industrial Corporation vs Asst. CIT (1999) 236 ITR 742, 746 (Punj.), xiv. Srichand Lalchand Talreja vs Asst. CIT (1998) 98 taxman 14, 19 (Bom.), xv. Usha Beltr…

Nishit Saxena, New Delhi vs. ITO, New Delhi

In the result, the appeal filed by the Assessee stand allowed

ITA 2971/DEL/2016[2009-10]Status: DisposedITAT Delhi03 Jan 2017AY 2009-10

Bench: Shri H.S. Sidhuay: 2009-10

For Appellant: Sh. Ved Jain, CA &For Respondent: Anil Kumar Sharma, Sr. DR

Section 147Section 148Section 192B

…being any live nexus between the reasons recorded and the belief formed by the assessing officer that any income has escaped assessment. To support this contention he relied upon the Hon’ble Delhi High Court decision in the case of CIT vs. Orient Craft Ltd. 354 ITR 536 (Delhi). Ld. Counsel of the assessee further stated that AO has grossly erred in reopening the assessment of the assessee only on the basis of Form 26AS and the TDS certificate issued by the employer of the assessee, hence, no tangible material was before the AO apart from the TDS certificate, to form a belief that income has escaped assessme…

DDIT (E) 1(1), Mumbai vs. Matunga Gymkhana, Mumbai

In the result, while of appeals of the Revenue are dismissed, that of assessee is allowed, as above

ITA 4768/MUM/2013[2006-07]Status: DisposedITAT Mumbai30 Nov 2016AY 2006-07

Bench: Shri G.S.Pannu & Shri Amarjit Singh

For Appellant: S/ Shri Arvind Sonde/For Respondent: Shri M.Rajan

Section 11Section 11(4)Section 12ASection 13Section 13(1)Section 143(3)

…that certain income chargeable to tax has escaped assessment, has to be complied with. In fact, at the time of hearing, Ld. Representative for the assessee had relied upon the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Orient Craft Ltd., 354 ITR 536(Del), wherein it has been held that the finality of intimation under section 143(1) of the Act can be disturbed under section 147/148 of the Act only if the Assessing Officer has reason to believe that certain income chargeable to tax has been escaped. The Hon'ble Delhi High Court duly considered the judgment of the Hon'ble Supreme Court in the c…

Matunga Gymkhana, Mumbai vs. ADIT (E) -I-(1), Mumbai

In the result, while of appeals of the Revenue are dismissed, that of assessee is allowed, as above

ITA 4468/MUM/2013[2009-10]Status: DisposedITAT Mumbai30 Nov 2016AY 2009-10

Bench: Shri G.S.Pannu & Shri Amarjit Singh

For Appellant: S/ Shri Arvind Sonde/For Respondent: Shri M.Rajan

Section 11Section 11(4)Section 12ASection 13Section 13(1)Section 143(3)

DDIT (E)-1(1), Mumbai vs. Matunga Gymkhana, Mumbai

In the result, while of appeals of the Revenue are dismissed, that of assessee is allowed, as above

ITA 1809/MUM/2010[2005-06]Status: DisposedITAT Mumbai30 Nov 2016AY 2005-06

Bench: Shri G.S.Pannu & Shri Amarjit Singh

For Appellant: S/ Shri Arvind Sonde/For Respondent: Shri M.Rajan

Section 11Section 11(4)Section 12ASection 13Section 13(1)Section 143(3)

Commissioner of Income Tax (C)-I vs. Shri Suresh Nanda

ITA/761/2016HC Delhi28 Nov 2016

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 148

The Sri Kannikaparameshwari Co-Op Bank Limited, Davangere vs. Income-Tax Officer, Davangere

In the result, the appeal of the assessee is dismissed

ITA 1364/BANG/2016[2004-05]Status: DisposedITAT Bangalore23 Sept 2016AY 2004-05

Bench: Shri A.K.Garodia, Accounant Member

For Appellant: Shri S. Ramasubramanian, CAFor Respondent: Shri G. Manoj Kumar, Addl. CIT

Section 143(3)Section 147Section 148Section 80PSection 80P(2)

…-opening is based on change of opinion and therefore, not valid. In support of this contention, he placed reliance on the following judicial pronouncements a) Sheo Nath Singh Vs Appellate Asst. Commissioner of IT 82 ITR 147(SC) b) CIT Vs Orient Crafts Ltd., 354 ITR 536(Del.) c) CIT Vs Ramakrishna Hegde 326 ITR 347(Kar.) 4. The ld. DR of the revenue supported the orders of the authorities below. 5. I have considered the rivals submissions. First, I reproduce the reasons recorded by the AO for re-opening which are available on page- 189 of the paper book. 3 ITA No.1364(Bang)2016 F.No.AADTS3885J/ITO/W-3/DVG/…

Sobha Suburbia Apartments Owners Welfare Association, Bangalore vs. ITO, Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 627/BANG/2014[2008-09]Status: DisposedITAT Bangalore23 Sept 2016AY 2008-09

Bench: Shri Vijay Pal Rao & Shri S. Jayaraman

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Shri Vijay Kumar N, Addl.CIT (D.R)

Section 143(1)Section 148

…thing but a change of opinion of the Assessing Officer on the material already available with the Assessing Officer in the shape of return of income. The ld. AR has relied upon the judgment of Hon'ble Delhi High Court in the case of CIT Vs. Orient Craft Ltd. 354 ITR 536 (Del) and submitted that when there is no whisper in the reasons recorded by of the Assessing Officer after the order under Section 143(1)(a) then the reassessment is based only on reappraisal of the information already on record. Thus the reopening is invalid as held by the Hon'ble High Court of Delhi. The ld. AR has relied upon the decision o…

M/S. A.T. Kearney India Private Limited, Gurgaon vs. ITO, New Delhi

In the result the ground No

ITA 511/DEL/2014[2007-08]Status: DisposedITAT Delhi23 Sept 2016AY 2007-08

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Sh. Amit Ray, Sr. DR

Section 10ASection 10A(7)Section 115JSection 147Section 148Section 80I

…he assessment. Hon'ble Delhi High Court in the above case has also considered the decision of the Hon'ble Supreme Court in case of CIT Vs. Kelvinator India Ltd. 320 ITR 561 (SC) and decision of the Hon'ble Delhi High Court in case of CIT Vs. Orient Craft Ltd. 354 ITR 546 (Del). In view of this we uphold the reopening of the assessment in the case of the assessee u/s 147 of the Act. In the result, Ground No. 1 of the appeal of the assessee is dismissed. 12. Ground No. 2 of the appeal of the assessee is against the reduction in deduction available u/s 10A of the Act of Rs. 11374842/- as against Rs. 39280361/- claim…