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 367,181 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.

The Supreme Industrial Ltd, Mumbai vs. Asst CIT Ltu Circle, Mumbai

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

ITA 7598/MUM/2019[2015-16]Status: DisposedITAT Mumbai03 Oct 2023AY 2015-16

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 7598/Mum/2019 (निर्धारण वर्ा / Assessment Year: 2015-16) The Supreme Industries Ltd. Acit Ltu, Circle, बिधम/ 612, Raheja Chambers, Free Mumbai Vs. Press Journal Marg, Room No. X, 29Th Floor, Nariman Point, Mumbai- World Trade Centre-1, 400021. Cuffee Parade, Mumbai- 400005. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact1344F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nitesh Joshi & Shri Harsh Shah Revenue By: Shri Manoj Kumar (Cit- Dr) सुनवाई की तारीख / Date Of Hearing: 07/07/2023 घोषणा की तारीख /Date Of Pronouncement: 03/10/2023 आदेश / O R D E R

For Appellant: Shri Nitesh Joshi & Shri Harsh ShahFor Respondent: Shri Manoj Kumar (CIT- DR)
Section 143(3)Section 17(1)Section 197Section 40ASection 40A(2)Section 40A(2)(b)Section 92BSection 92C

…the same i.e. capital in nature and thus not liable to tax. 13. We have considered the submissions of both the parties and perused the material placed before us. It is noted that the Hon’ble Supreme Court in the case of CIT vs. Ponni Sugar & Chemicals Ltd. (306 ITR 392) had held that whether the subsidy or grant given by the Government is in the nature of capital or revenue will have to be judged and decided with reference to the object and the purpose for which the subsidies are granted. If the principal object for grant of subsidy is to promote industry or to enable the assessee to set up or 15 A.Y. 2015-16 S…

DCIT, Circle- 1(1), Gurgaon vs. Cinepolis India Pvt. Ltd. (Successor to Fun Multiplex Pvt. Ltd.), Gurgaon

In the result Revenue’s appeal as well as assessee’s cross-objection stand dismissed

ITA 4021/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Aug 2023AY 2014-15

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2014-15

Section 143(3)

…t after analyzing the object and the purpose of the subsidy and came to the conclusion that it is a capital receipt. The Jurisdictional High Court has referred and relied upon the decision of the hon’ble Supreme Court in Pooni Sugar and Chemicals Ltd., [2008] 306 ITR 392 (SC) and Sahney Steel andPress Works Ltd. v/s CIT, [1997] 228 ITR 253 (SC). …… In view of the aforesaid decision of the Jurisdictional High Court which applies mutatis mutandis to the facts of the present case also, we do not find any merit in the ground raised by the revenue and, therefore, the findings given by the learned Commissioner (Appeals…

Deputy Commissioner of Income Tax, Circle-4, Guwahati vs. M/S. Shiv Steel Industries, Guwahati

In the result, appeal of the revenue is dismissed

ITA 176/GTY/2019[2013-14]Status: DisposedITAT Guwahati24 Aug 2023AY 2013-14

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 176/Gty/2019 Assessment Year: 2013-14 Dy. Commissioner Of Income-Tax, M/S. Shiv Steel Industries Circle-4 Vs Block Dhanuka Complex S.J. Road Athgaon, Kamrup Guwahati - 781001 [Pan : Abefs6132J] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Jay Prakash Gupta, Fca Revenue By : Shri P.S. Thuingaleng, Acit, Sr. D/R & Shri Arun Bhowmick, Jcit, D/R सुनवाई क" तारीख/Date Of Hearing : 23/08/2023 घोषणा क" तारीख /Date Of Pronouncement: 24/08/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) Guwahati -2, (Hereinafter The “Ld. Cit(A)”) Dt. 28/02/2019, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act’), For Assessment Year 2013-14. 2. Facts In Brief Are That The Assessee Is A Partnership Firm Engaged In Manufacturing Of Tmt Bars. Income Of Rs.20,58,660/- Declared In The E-Return Filed On 29/09/2013. Case Selected For Scrutiny Through Cass Followed By Validly Serving Notice U/S 143(2) & 142(1) Of The Act. While Computing The Total Income, The Assessee Claimed Deduction U/S 80Ie Of The Act In Respect Of Vat Remission At Rs. 1,99,13,704/-. The Assessee Filed Form 10Ccb Eligibility Certificate, Registration Certificate From Inspector Of Factories, Assam & Other Details.

For Appellant: Shri Jay Prakash Gupta, FCAFor Respondent: Shri P.S. Thuingaleng, ACIT, Sr. D/R & Shri Arun
Section 143(2)Section 250Section 28Section 80I

…rnment treasury and the remaining is utilized by the assessee for its business. The Hon’ble Supreme Court in the case of CIT v. Ponni I.T.A. No. 176/GTY/2019 Assessment Year: 2013-14 M/s. Shiv Steel Industries 4 Sugars & Chemicals Ltd. [2008] 174 Taxman 87/306 ITR 392 held that “…..the character of the receipt in the hands of the assessee has to be determined with respect to the purpose for which the subsidy is given. In other words, in such cases, one has to apply the purpose test. The point of time at which the subsidy is paid is not relevant. The source is immaterial. The form of subsidy is immaterial….” Th…

Everest Industries Ltd., Noida vs. Dy CIT Circle- 1, Thane

In the result, the appeal of the Revenue is dismissed whereas

ITA 717/MUM/2020[2006-07]Status: DisposedITAT Mumbai21 Aug 2023AY 2006-07

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2006-07 Everest Industries Ltd., Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- Vs. 201301, Uttar Pradesh, India. Wing 16-Z, Wagle Industrial Estate, Thane (W)-400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2006-07 Dcit, Circle-1, Everest Industries Ltd., Ashar I.T. Park, 6Th Floor, B- G-1, A-32, Genesis Mohan Vs. Wing 16-Z, Wagle Industrial Coop. Industries, Mathura Estate, Thane (W)-400 604. Road, New Delhi-110044. Pan No. Aaace 7550 N Appellant Respondent

For Appellant: Mr. Yogesh Thar a/w Mr. Chaitanya JoshiFor Respondent: Mr. Alok Kumar, CIT-DR

…our decision we have relied upon the decision of honourable supreme court in the case of CIT Vs Ponny Sugars and onourable supreme court in the case of CIT Vs Ponny Sugars and onourable supreme court in the case of CIT Vs Ponny Sugars and Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held in a number of judicial pronouncements that modality or the source of in a number of judicial pronouncements that modality or the source of in a number of judicial…

DCIT, Circle-1, Thane vs. Everest Industries Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed whereas

ITA 1421/MUM/2020[2006-07]Status: DisposedITAT Mumbai21 Aug 2023AY 2006-07

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2006-07 Everest Industries Ltd., Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- Vs. 201301, Uttar Pradesh, India. Wing 16-Z, Wagle Industrial Estate, Thane (W)-400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2006-07 Dcit, Circle-1, Everest Industries Ltd., Ashar I.T. Park, 6Th Floor, B- G-1, A-32, Genesis Mohan Vs. Wing 16-Z, Wagle Industrial Coop. Industries, Mathura Estate, Thane (W)-400 604. Road, New Delhi-110044. Pan No. Aaace 7550 N Appellant Respondent

For Appellant: Mr. Yogesh Thar a/w Mr. Chaitanya JoshiFor Respondent: Mr. Alok Kumar, CIT-DR

…our decision we have relied upon the decision of honourable supreme court in the case of CIT Vs Ponny Sugars and onourable supreme court in the case of CIT Vs Ponny Sugars and onourable supreme court in the case of CIT Vs Ponny Sugars and Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held Chemical Ltd (2008) 306 ITR 392 (S.C). In this regard, it has been held in a number of judicial pronouncements that modality or the source of in a number of judicial pronouncements that modality or the source of in a number of judicial…

M/S. Bridgestone India Pvt. Ltd., Pune vs. The ACIT NFAC, Delhi

In the result, appeal of assessee is partly allowed

ITA 84/IND/2022[2017-18/]Status: DisposedITAT Indore17 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 43(1)

…Pradesh has attained finality as settled by the Hon’ble Supreme Court in the said judgment. This view of the Hon’ble Supreme Court in case of Sahney Steel & Press Works Ltd. vs. CIT (supra) has been reiterated in case of CIT vs. Ponni Sugars & Chemicals Ltd. 306 ITR 392 as under: “14. In our view, the controversy in hand can be resolved if we apply the test laid down in the judgment of this Court in the case of Sahney Steel and Press Works Ltd. (supra). In that case, on behalf of the assessee, it was contended that the subsidy given was up to 10% of the capital investment calculated on the basis of the quantum…

The ACIT Cir 6(3), Mumbai vs. M/S. Grasim Industries Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3854/MUM/2006[2005-2006]Status: DisposedITAT Mumbai04 Jul 2023AY 2005-2006

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishor Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43B

…ived in the instant case would only have to be construed as capital receipts not chargeable to income tax. In this regard, we find that ld. AR placed reliance on the decision of Hon‟ble Supreme Court in the case of Ponni Sugars and Chemicals Ltd., reported in 306 ITR 392, wherein the incentive conferred under that scheme were two fold. First, in the nature of higher free sale sugar quota and second, in allowing the manufacturer to collect Excise duty on sale price on the free sale sugar in excess of the normal quota, but to pay to the Government only the Excise duty payable on the price of levy sugar. The Hon‟ble…

M/S. Grasim Industries Ltd., Mumbai vs. DCIT Cir - 6(3), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3517/MUM/2006[2005-2006]Status: DisposedITAT Mumbai04 Jul 2023AY 2005-2006

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishor Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43B

…ived in the instant case would only have to be construed as capital receipts not chargeable to income tax. In this regard, we find that ld. AR placed reliance on the decision of Hon‟ble Supreme Court in the case of Ponni Sugars and Chemicals Ltd., reported in 306 ITR 392, wherein the incentive conferred under that scheme were two fold. First, in the nature of higher free sale sugar quota and second, in allowing the manufacturer to collect Excise duty on sale price on the free sale sugar in excess of the normal quota, but to pay to the Government only the Excise duty payable on the price of levy sugar. The Hon‟ble…

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

…and examined is the purpose for which the subsidy has been given, and not the timing of the subsidy or the manner in which it has been given to the industry’, as is also held by Hon’ble Supreme Court in the case of CIT Vs Ponni Sugar and Chemicals Ltd [(2008) 306 ITR 392 (SC)]. A large number of judicial precedents have been cited in this context. Learned CIT(A) has then held that so far as the object and purpose for which the subsidy is given, only the subsidy schemes of the Maharashtra and Punjab State specifically state that the subsidies in question are for achieving dispersal of industries outside Mumbai, to…

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

…and examined is the purpose for which the subsidy has been given, and not the timing of the subsidy or the manner in which it has been given to the industry’, as is also held by Hon’ble Supreme Court in the case of CIT Vs Ponni Sugar and Chemicals Ltd [(2008) 306 ITR 392 (SC)]. A large number of judicial precedents have been cited in this context. Learned CIT(A) has then held that so far as the object and purpose for which the subsidy is given, only the subsidy schemes of the Maharashtra and Punjab State specifically state that the subsidies in question are for achieving dispersal of industries outside Mumbai, to…

Everest Industries Ltd., Noida vs. Dy CIT Circle- 1, Thane

In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the assessee are a...

ITA 720/MUM/2020[2016-17]Status: DisposedITAT Mumbai30 Jun 2023AY 2016-17

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant ()

For Appellant: Mr. Yogesh Thar/For Respondent: Mr. Biswanath Das, CIT-DR/

…thus it was a capital receipt in view of purposive test in view of purposive test held by the hon’ble held by the hon’ble supreme court in the case of CIT Vs Ponni Sugars and Chemicals CIT Vs Ponni Sugars and Chemicals supreme court in the case of Ltd (2008) 306 ITR 392(SC) Ltd (2008) 306 ITR 392(SC). According to the Assessing Officer According to the Assessing Officer, since the unit was exempt from unit was exempt from excise duty, the assessee was not assessee was not authorised to collect excise duty ect excise duty from customers at all. A at all. As no duty was collected from customers was collected from…

Everest Industries Ltd., Noida vs. Dy CIT Circle- 1, Thane

In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the assessee are a...

ITA 719/MUM/2020[2015-16]Status: DisposedITAT Mumbai30 Jun 2023AY 2015-16

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant ()

For Appellant: Mr. Yogesh Thar/For Respondent: Mr. Biswanath Das, CIT-DR/

…thus it was a capital receipt in view of purposive test in view of purposive test held by the hon’ble held by the hon’ble supreme court in the case of CIT Vs Ponni Sugars and Chemicals CIT Vs Ponni Sugars and Chemicals supreme court in the case of Ltd (2008) 306 ITR 392(SC) Ltd (2008) 306 ITR 392(SC). According to the Assessing Officer According to the Assessing Officer, since the unit was exempt from unit was exempt from excise duty, the assessee was not assessee was not authorised to collect excise duty ect excise duty from customers at all. A at all. As no duty was collected from customers was collected from…

DCIT Circle-1, Thane vs. M/S Everest Industries Ltd., Delhi

In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the assessee are a...

ITA 652/MUM/2020[2014-15]Status: DisposedITAT Mumbai30 Jun 2023AY 2014-15

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant ()

For Appellant: Mr. Yogesh Thar/For Respondent: Mr. Biswanath Das, CIT-DR/

…thus it was a capital receipt in view of purposive test in view of purposive test held by the hon’ble held by the hon’ble supreme court in the case of CIT Vs Ponni Sugars and Chemicals CIT Vs Ponni Sugars and Chemicals supreme court in the case of Ltd (2008) 306 ITR 392(SC) Ltd (2008) 306 ITR 392(SC). According to the Assessing Officer According to the Assessing Officer, since the unit was exempt from unit was exempt from excise duty, the assessee was not assessee was not authorised to collect excise duty ect excise duty from customers at all. A at all. As no duty was collected from customers was collected from…

DCIT, Circle-1, Thane vs. Everest Industries Ltd., Mumbai

In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the In the result, appeals of the Revenue as well appeals of the assessee are a...

ITA 1424/MUM/2020[2015-16]Status: DisposedITAT Mumbai30 Jun 2023AY 2015-16

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant ()

For Appellant: Mr. Yogesh Thar/For Respondent: Mr. Biswanath Das, CIT-DR/

…thus it was a capital receipt in view of purposive test in view of purposive test held by the hon’ble held by the hon’ble supreme court in the case of CIT Vs Ponni Sugars and Chemicals CIT Vs Ponni Sugars and Chemicals supreme court in the case of Ltd (2008) 306 ITR 392(SC) Ltd (2008) 306 ITR 392(SC). According to the Assessing Officer According to the Assessing Officer, since the unit was exempt from unit was exempt from excise duty, the assessee was not assessee was not authorised to collect excise duty ect excise duty from customers at all. A at all. As no duty was collected from customers was collected from…

Puri Oil Mills Ltd, New Delhi vs. ACIT, Circle-20(1), New Delhi

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

ITA 7726/DEL/2019[2013-14]Status: DisposedITAT Delhi30 Jun 2023AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(3)Section 2(24)Section 44A

…g up of the SHPS, is in the nature of capital receipt. Also, such treatment is in accordance with the Accounting Standard 12 "Accounting for Government Grants" issue by ICAI The assessee's case is squarely covered by the decision of the Apex Court reported in 306 ITR 392 (SC) in the case of CIT V Ponni Sugars and Chemicals Ltd. It was held that: 14 ITA. 6971/Del/2018 AND ITA. 7726/Del/2019 Puri Oil Mills Ltd., New Delhi. The character of the receipt of subsidy in the hands of the assessee under scheme has to be determined with respect to the purpose for which subsidy is granted. In other words, one has to appl…

Puri Oil Mills Ltd., New Delhi vs. ACIT, Circle- 20(1), New Delhi

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

ITA 6971/DEL/2018[2012-13]Status: DisposedITAT Delhi30 Jun 2023AY 2012-13

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(3)Section 2(24)Section 44A

…g up of the SHPS, is in the nature of capital receipt. Also, such treatment is in accordance with the Accounting Standard 12 "Accounting for Government Grants" issue by ICAI The assessee's case is squarely covered by the decision of the Apex Court reported in 306 ITR 392 (SC) in the case of CIT V Ponni Sugars and Chemicals Ltd. It was held that: 14 ITA. 6971/Del/2018 AND ITA. 7726/Del/2019 Puri Oil Mills Ltd., New Delhi. The character of the receipt of subsidy in the hands of the assessee under scheme has to be determined with respect to the purpose for which subsidy is granted. In other words, one has to appl…

Parag Milk Foods Pvt. Ltd, Pune vs. Deputy Commissioner of Income-Tax, Central Circle -1 (1), Pune

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

ITA 757/PUN/2019[2014-15]Status: DisposedITAT Pune27 Jun 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury, Hon.

For Appellant: Shri Suhas P. Bora, CAFor Respondent: Shri M.G. Jasnani, DR
Section 14ASection 28Section 43(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE „B‟ BENCHES :: PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER & SHRI PARTHA SARATHI CHAUDHURY, HON.JUDICIAL MEMBER ITA Nos.756 & 757/PUN/2019 (A.Ys. 2013-14 & 2014-15) Parag Milk Foods Pvt. Ltd., vs DCIT, Central Circle-1(1) Awasari Phata, Village Pune. Manchar, Tal – Ambegaon, Dist - Pune PAN: AABCP 0425 G Assessee Respondent /Revenue ITA Nos.488 & 489/PUN/2019 (A.Ys. 2013-14 & 2014-15) ACIT, Circle-4, Pune. vs Parag Milk Foods Pvt. Ltd., Awasari Phata, Village Manchar, Tal – Ambegaon, Dist – Pune. PAN: AABCP 0425 G Appellant/Revenue Assessee Assessee by : Shri Suh…

Parag Milk Foods Pvt. Ltd, Pune vs. Deputy Commissioner of Income-Tax, Central Circle -1 (1), Pune

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

ITA 756/PUN/2019[2013-14]Status: DisposedITAT Pune27 Jun 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury, Hon.

For Appellant: Shri Suhas P. Bora, CAFor Respondent: Shri M.G. Jasnani, DR
Section 14ASection 28Section 43(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE „B‟ BENCHES :: PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER & SHRI PARTHA SARATHI CHAUDHURY, HON.JUDICIAL MEMBER ITA Nos.756 & 757/PUN/2019 (A.Ys. 2013-14 & 2014-15) Parag Milk Foods Pvt. Ltd., vs DCIT, Central Circle-1(1) Awasari Phata, Village Pune. Manchar, Tal – Ambegaon, Dist - Pune PAN: AABCP 0425 G Assessee Respondent /Revenue ITA Nos.488 & 489/PUN/2019 (A.Ys. 2013-14 & 2014-15) ACIT, Circle-4, Pune. vs Parag Milk Foods Pvt. Ltd., Awasari Phata, Village Manchar, Tal – Ambegaon, Dist – Pune. PAN: AABCP 0425 G Appellant/Revenue Assessee Assessee by : Shri Suh…

Assistant Commissioner of Income-Tax, Circle - 4, Pune vs. Parag Milk Foods Pvt.Ltd, Pune

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

ITA 489/PUN/2019[2014-15]Status: DisposedITAT Pune27 Jun 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury, Hon.

For Appellant: Shri Suhas P. Bora, CAFor Respondent: Shri M.G. Jasnani, DR
Section 14ASection 28Section 43(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE „B‟ BENCHES :: PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER & SHRI PARTHA SARATHI CHAUDHURY, HON.JUDICIAL MEMBER ITA Nos.756 & 757/PUN/2019 (A.Ys. 2013-14 & 2014-15) Parag Milk Foods Pvt. Ltd., vs DCIT, Central Circle-1(1) Awasari Phata, Village Pune. Manchar, Tal – Ambegaon, Dist - Pune PAN: AABCP 0425 G Assessee Respondent /Revenue ITA Nos.488 & 489/PUN/2019 (A.Ys. 2013-14 & 2014-15) ACIT, Circle-4, Pune. vs Parag Milk Foods Pvt. Ltd., Awasari Phata, Village Manchar, Tal – Ambegaon, Dist – Pune. PAN: AABCP 0425 G Appellant/Revenue Assessee Assessee by : Shri Suh…

Assistant Commissioner of Income-Tax, Circle - 4, Pune vs. Parag Milk Foods Private Limited, Pune

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

ITA 488/PUN/2019[2013-14]Status: DisposedITAT Pune27 Jun 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury, Hon.

For Appellant: Shri Suhas P. Bora, CAFor Respondent: Shri M.G. Jasnani, DR
Section 14ASection 28Section 43(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE „B‟ BENCHES :: PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER & SHRI PARTHA SARATHI CHAUDHURY, HON.JUDICIAL MEMBER ITA Nos.756 & 757/PUN/2019 (A.Ys. 2013-14 & 2014-15) Parag Milk Foods Pvt. Ltd., vs DCIT, Central Circle-1(1) Awasari Phata, Village Pune. Manchar, Tal – Ambegaon, Dist - Pune PAN: AABCP 0425 G Assessee Respondent /Revenue ITA Nos.488 & 489/PUN/2019 (A.Ys. 2013-14 & 2014-15) ACIT, Circle-4, Pune. vs Parag Milk Foods Pvt. Ltd., Awasari Phata, Village Manchar, Tal – Ambegaon, Dist – Pune. PAN: AABCP 0425 G Appellant/Revenue Assessee Assessee by : Shri Suh…