CIT v. Ponni Sugars & Chemicals Ltd.

306 ITR 392Supreme Court of India2008#107 most cited

What is CIT v. Ponni Sugars & Chemicals Ltd. authority for?

The "Purpose Test" determines whether an incentive or subsidy is a capital or revenue receipt for income tax purposes. If the incentive's purpose is to enable an assessee to set up a new industry or make investments in capital assets, it is a capital receipt and not taxable.

577

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. Ponni Sugars & Chemicals Ltd. · 306 ITR 392 · capital receipt vs revenue receipt · subsidy taxability · incentive scheme purpose test · sales tax incentive capital receipt · excise duty exemption capital receipt · section 2(24)(xviii) · section 43(1) · investment incentive taxability · purpose test subsidy · nature of receipt

Also reported as

174 Taxmann 87219 CTR 105

Sections most often in play

Section 115JBSection 143(3)Section 14ASection 2(24)(xviii)Section 37(1)Section 80P(2)(d)Section 80P(4)Section 43(1)
Read the full judgment

Issues it is cited on

section 2(24)(xviii)section 43(1)initial assessment yearsection 80hhcsection 80hhsection 2(24)additional depreciationbook profitswritten down valueblock of assetssection 32(1)liable to tax

Judgments citing CIT v. Ponni Sugars & Chemicals Ltd.

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

…employment generation by the company connected to the export of goods and mercantile. It is linked with capital in nature. The CITT(A) has placed reliance upon the decision of the Hon'ble Supreme Court in the care of CIT IS Ponni Sugars& Chemicals Lad (2008) 306 ITR 392 (SC). Eastman Exports Global Clothing Pet Lad in ITA No 47 MDS 2016 dated 17.03.2016 and Sutlej Textiles & Industries Lad (ITA. No. 5142 Del 2013) and Mix. Gloster Jute Mills Laud. Vs. All CIT in ITA. No 687/Kol 2010 These issues have duly been examined and discussed by CITA) his order. The copy of scheme has also been filed by t. Representative…

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

…employment generation by the company connected to the export of goods and mercantile. It is linked with capital in nature. The CITT(A) has placed reliance upon the decision of the Hon'ble Supreme Court in the care of CIT IS Ponni Sugars& Chemicals Lad (2008) 306 ITR 392 (SC). Eastman Exports Global Clothing Pet Lad in ITA No 47 MDS 2016 dated 17.03.2016 and Sutlej Textiles & Industries Lad (ITA. No. 5142 Del 2013) and Mix. Gloster Jute Mills Laud. Vs. All CIT in ITA. No 687/Kol 2010 These issues have duly been examined and discussed by CITA) his order. The copy of scheme has also been filed by t. Representative…

Deputy Commissioner of Income Tax, Circle - 7(1), Kolkata, Aayakar Bhawan vs. West Bengal Industrial Development Corporation Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 623/KOL/2025[2015-2016]Status: DisposedITAT Kolkata12 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita No.623 & 748/Kol/2025 (Assessment Year: 2015-16) Dcit, Circle-7(1), Kolkata………...……………..……….……….……….……Appellant Vs. West Bengal Industrial Development Corporation Limited......……...…..…..Respondent 23, A N Thakur Sarani, Circus Avenue, Kol - 700017.. [Pan: Aaacw3043Q] Appearances By: Shri B R Dutta, Fca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 21, 2026 Date Of Pronouncing The Order : February 12, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against An Order Dated 09.08.2024 Of The Nfac, Delhi [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Both The Appeals Relate To The Same Assessee & Arise From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Ita No.623 & 748/Kol/2025 Filed By The Revenue With A Delay Of 139 & 159 Days Respectively & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 115JSection 143(2)Section 250Section 36(1)(viia)

…ate Government was income of the assessee and therefore it is taxable under the Income-tax Act, 1961. 2. That the Ld. CIT (A) has erred in holding that the orders of the Hon'ble Supreme Court of India in the case of CIT v. Ponni Sugars & Chemicals Ltd. [2008] 306 ITR 392/174 Taxman 87 are squarely applicable in the case of the assessee overlooking the fact that the facts and circumstances concerning both these cases are altogether different. 3. That the appellant craves leave to add to and/or alter, amend, modify or rescind the grounds hereinabove before or hearing of this appeal.” 5. Contrary to that, the ld. AR…

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

…roducts manufactured by assessee are fallen under that category, therefore, it satisfied the conditions for availing the incentives. It is seen that Ld. CIT(A) has placed reliance on various judgments which are as under:  Ponni Sugars & Chemicals Ltd. (2008) 306 ITR 392  Shree Balaji Alloy & Others v. CIT (2011) 333  PCIT -vs.- M/s Nitin Spinners Limited (116 taxmann.com 26)  Bharat Rasayan Ltd vs ACIT (ITA No. 1231/Del/2019 vide order da 02.02.2021) 32. Before us, the Ld. Sr. DR failed to controvert the findings given by the Ld. CIT(A) and did not bring on record any contrary materials to hold that such rew…

DCIT Circle 4(2), New Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2330/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

…roducts manufactured by assessee are fallen under that category, therefore, it satisfied the conditions for availing the incentives. It is seen that Ld. CIT(A) has placed reliance on various judgments which are as under:  Ponni Sugars & Chemicals Ltd. (2008) 306 ITR 392  Shree Balaji Alloy & Others v. CIT (2011) 333  PCIT -vs.- M/s Nitin Spinners Limited (116 taxmann.com 26)  Bharat Rasayan Ltd vs ACIT (ITA No. 1231/Del/2019 vide order da 02.02.2021) 32. Before us, the Ld. Sr. DR failed to controvert the findings given by the Ld. CIT(A) and did not bring on record any contrary materials to hold that such rew…

The India Cements Limited, Chennai vs. DCIT Corporate Circle 2(1) Chennai, Chennai

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

ITA 2174/CHNY/2024[2017-18]Status: DisposedITAT Chennai02 Jan 2026AY 2017-18
Section 10(39)Section 115JSection 14A

…her hand, if the object of the assistance under the subsidy scheme was to enable the assessee to set up a new unit or to expand the existing unit then the receipt of the subsidy was on capital account”. Similarly, in CIT Vs Ponni Sugars and Chemicals Limited (306 ITR 392), it was held that, if the subsidy's purpose was to help the assessee run the business more profitably or meet daily business expenses, it was considered a revenue receipt (and thus taxable). Conversely, if the subsidy aimed at setting up a new unit or expanding an existing unit, it was deemed a capital receipt (and not taxable). The above amendm…

JCIT Cent. Cir. - 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

The appeal is allowed

ITA 1561/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar / Ms SukanyaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 153CSection 250Section 43BSection 80I

…. In any case, the assessee submits that it has been settled by various judicial pronouncements, including the decision of the Hon’ble Supreme Court in Sahney Steel and Press Works Ltd. and Ors. V CIT (228 ITR 253) (SC), CIT Vs. Ponni Sugars & Chemicals Ltd. (306 ITR 392) (SC), the form of mechanism through which subsidy is given is irrelevant; the crucial determining factor is the purpose for which the subsidy is given. The purpose of the subsidy under which the assessee has been granted an incentive is accepted to be for rapid industrialisation and to encourage a balanced growth of industries in the State of Gu…

Grasim Industries Ltd, Mumbai vs. DCIT Cent. Cir. - 1(4), Mumbai

The appeal is allowed

ITA 1056/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

Section 153CSection 250Section 43BSection 80I

…. In any case, the assessee submits that it has been settled by various judicial pronouncements, including the decision of the Hon'ble Supreme Court in Sahney Steel and Press Works Ltd. and Ors. V CIT (228 ITR 253) (SC), CIT Vs. Ponni Sugars & Chemicals Ltd. (306 ITR 392) (SC), the form of mechanism through which subsidy is given is irrelevant; the crucial determining factor is the purpose for which the subsidy is given. The purpose of the subsidy under which the assessee has been granted an incentive is accepted to be for rapid industrialisation and to encourage a balanced growth of industries in the State of Gu…

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5417/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…sidy: Rs.3,17,62,359/- The cases relied by the assessee and endorsed by the CIT(A) of the following cases are not applicable in this case. The facts of the following cases are different from the facts of this case. i) CIT Vs.Ponnis Sugars and Chemicals Ltd., (306 ITR 392(SC)) ii) CIT Vs. Reliance Industries Ltd.(339 ITR 0632(Bom HC)) iii)CIT Vs.Maruti Suzuki India Ltd.(ITA No.1927/Del/2010-ITAT-Delhi iv) CIT Vs. Meghala Steels Ltd v)Shree Balaji Alloys Vs.CIT(2011) 333 ITR 335(J&K) 4.1) Further the Commissioner(Appeals) erred by endorsing the inference of the assessee a that the subsidy is of capital nature based…

Dalmia Cement (Bharat) Ltd., New Delhi vs. ACIT, Central Circle- 26, New Delhi

ITA 5416/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…sidy: Rs.3,17,62,359/- The cases relied by the assessee and endorsed by the CIT(A) of the following cases are not applicable in this case. The facts of the following cases are different from the facts of this case. i) CIT Vs.Ponnis Sugars and Chemicals Ltd., (306 ITR 392(SC)) ii) CIT Vs. Reliance Industries Ltd.(339 ITR 0632(Bom HC)) iii)CIT Vs.Maruti Suzuki India Ltd.(ITA No.1927/Del/2010-ITAT-Delhi iv) CIT Vs. Meghala Steels Ltd v)Shree Balaji Alloys Vs.CIT(2011) 333 ITR 335(J&K) 4.1) Further the Commissioner(Appeals) erred by endorsing the inference of the assessee a that the subsidy is of capital nature based…

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3158/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…sidy: Rs.3,17,62,359/- The cases relied by the assessee and endorsed by the CIT(A) of the following cases are not applicable in this case. The facts of the following cases are different from the facts of this case. i) CIT Vs.Ponnis Sugars and Chemicals Ltd., (306 ITR 392(SC)) ii) CIT Vs. Reliance Industries Ltd.(339 ITR 0632(Bom HC)) iii)CIT Vs.Maruti Suzuki India Ltd.(ITA No.1927/Del/2010-ITAT-Delhi iv) CIT Vs. Meghala Steels Ltd v)Shree Balaji Alloys Vs.CIT(2011) 333 ITR 335(J&K) 4.1) Further the Commissioner(Appeals) erred by endorsing the inference of the assessee a that the subsidy is of capital nature based…

ACIT Circle 1, Trichy vs. Dalmia Cement Bharat Ltd., Dalmiapuram

ITA 3157/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…sidy: Rs.3,17,62,359/- The cases relied by the assessee and endorsed by the CIT(A) of the following cases are not applicable in this case. The facts of the following cases are different from the facts of this case. i) CIT Vs.Ponnis Sugars and Chemicals Ltd., (306 ITR 392(SC)) ii) CIT Vs. Reliance Industries Ltd.(339 ITR 0632(Bom HC)) iii)CIT Vs.Maruti Suzuki India Ltd.(ITA No.1927/Del/2010-ITAT-Delhi iv) CIT Vs. Meghala Steels Ltd v)Shree Balaji Alloys Vs.CIT(2011) 333 ITR 335(J&K) 4.1) Further the Commissioner(Appeals) erred by endorsing the inference of the assessee a that the subsidy is of capital nature based…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. ITO Ward6(1), Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. National Faceless Appeal Centre, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. ITO Ward 6(1), Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025

Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

Shriniwas Engineering Auto Components Pvt. Ltd, Pune vs. National Faceless Appeal Centre, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

Shriniwas Engineering Auto Components Pvt. Ltd., Pune vs. ACIT, Circle-5, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

Dy. Commissioner of Income-Tax, Circle-5, Pune vs. Shriniwas Engineering Auto Components Pvt. Ltd., Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

ACIT, Circle-5, Pune vs. Shriniwas Engineering Auto Components Private Limited, Pune

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon’ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…

ACIT, Pune vs. Shriniwas Engineering Auto Components Private Limited, Pune

In the result, ITA Nos.154 to 156/PUN/2025 filed by the

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025

Section 2(24)(xviii)Section 43

…incentives received under the Scheme of Govt. of Maharashtra, ld.CIT(A) has further referred to the judgments of Hon'ble Apex Court in the case of Sahney Steel and Press Works Limited 228 ITR 253 (SC) and in the case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot be reduced from the actual cost of the assets provided in Explanation 10 to section 43(1) of the Act and therefore taxable i…