CIT v. Yokogawa India Ltd.

391 ITR 274Supreme Court of India2017#271 most cited

What is CIT v. Yokogawa India Ltd. authority for?

Deduction under Section 10A or 10AA of the Income-tax Act is computed on the profits of the eligible unit without first setting off losses from other units or non-eligible units. Conversely, losses incurred by an eligible unit are allowed to be set off against the assessee's other taxable business profits.

290

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Yokogawa India Ltd. · Section 10A · Section 10AA · Section 70 · set off of losses · eligible unit deduction · profits of SEZ unit · losses of other units · computation of 10A deduction · set off losses of 10AA units · gross total income

Also reported as

77 Taxmann.com 41291 CTR 1244 Taxmann 273

Sections most often in play

Section 10ASection 10AASection 139(1)Section 143(3)Section 10BSection 143(1)Section 115JBSection 139(5)
Read the full judgment

Issues it is cited on

section 70section 10aset off of lossessection 10bsection 10aasection 80hhunabsorbed depreciationsection 80hhccomputer softwaretested partyeligible businessgross total income

Judgments citing CIT v. Yokogawa India Ltd.

Zensar Technologies Ltd, Mumbai vs. ACIT 2(3), Mumbai

In the result, appeal by the assessee is allowed for statistical purpose

ITA 276/MUM/2013[2002-03]Status: DisposedITAT Mumbai14 Sept 2022AY 2002-03

Bench: Shri G.S. Pannuand Shri Sandeep Singh Karhail

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Anil Kumar Das
Section 10ASection 115JSection 143(3)Section 250Section 263Section 80HSection 92C

…nst the normal business income. 5 M/s. Zensar Technolgies Ltd. ITA No.955/Mum./2013 ITA No.276/Mum./2013 9. We find that this issue is now settled in favour of the taxpayer by the decision of Hon‟ble Supreme Court rendered in CIT v/s Yokogawa India, [2017] 391 ITR 274 (SC), wherein it has been held that deductions contemplated under section 10A of the Act is qua the profits of eligible undertaking of an assessee on a stand-alone basis and without reference to the other eligible or non-eligible units or undertakings of the assessee. The relevant observations of the Hon‟ble Supreme Court are as under: “16. From…

Assistant Commissioner of Income Tax, Circle - 1(1), Panaji vs. Shiffer and Menezes India Pvt. Ltd, Panaji

In the result, appeal of revenue is dismissed

ITA 232/PAN/2018[2009-10]Status: DisposedITAT Panaji02 Sept 2022AY 2009-10

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2009-10 Assistant Commissioner Of M/S. Schiffer & Menezes Income Tax, Circle-1(1), India (P) Ltd. Vs. Panaji, Goa Cmm Building, Rua De Ourem, Panaji, Goa (Pan: Aaccm0106E) (Appellant) (Respondent) Present For: Appellant By : Shri P. R. V. Raghavan, Ca Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: This Appeal By The Revenue Is Directed Against The Order Of Ld. Cit(A)-2, Panaji Vide

For Appellant: Shri P. R. V. Raghavan, CAFor Respondent: Shri Mayur Kamble, Sr. DR
Section 10BSection 143(3)Section 72Section 80ASection 80A(1)Section 80B(5)Section 80C

…d., A.Y: 2009-10 7. Per contra, Ld. Counsel for the assessee reiterated the submissions made before the authorities below. However, he brought to the notice of the bench, the decision of Hon’ble Supreme Court in the case of CIT Vs. Yokogawa India Ltd. (2017) 391 ITR 274 (SC) wherein the issue has been dealt with by the Hon’ble Supreme Court in respect of section 10A which according to the Ld. Counsel is equally applicable to cases governed by the provisions of section 10B in view of the said later provision being pari materia with section 10A of the Act though governing a different situation. The findings given…

Wns Global; Services Pvt Ltd., Mumbai vs. Dy CIT Circle- 14 (3)(1), Mumbai

In the result appeal filed by the assessee is partly allowed

ITA 295/MUM/2020[2015-16]Status: DisposedITAT Mumbai23 Aug 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

For Appellant: ShriFor Respondent: Shri Tejandra Pal Singh, DR

…ITA Nos. 295/M/2020 & CO No.52/M/2020, 2383/M/2019 WNS Global Services P. Ltd; A.Ys. 15-16, 10-11 IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM Cross Objection No. 52/Mum/2020 (Arising in ITA No. 2383/Mum/2019 for A.Y. 10-11) WNS Global Services Private Limited The DCIT PL 10, Gate no,4 Circle 14(3)(1), Room No. 455, 4th Floor, Godrej & Boyce Complex Vs. Pirojshanagar, LBS Marg Aayakar Bhavan, M.K. Road, Vikhroli (West) Mumbai-400 020 Mumbai-400 079 (Appellant) (Respondent) PAN No. AAACW2598L WNS Global Services Private The DCIT Limited…

DCIT-14(3)(1), Mumbai vs. Wns Global Services Pvt Ltd., Mumbai

In the result appeal filed by the assessee is partly allowed

ITA 2383/MUM/2019[2010-11]Status: DisposedITAT Mumbai23 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

For Appellant: ShriFor Respondent: Shri Tejandra Pal Singh, DR

…ITA Nos. 295/M/2020 & CO No.52/M/2020, 2383/M/2019 WNS Global Services P. Ltd; A.Ys. 15-16, 10-11 IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM Cross Objection No. 52/Mum/2020 (Arising in ITA No. 2383/Mum/2019 for A.Y. 10-11) WNS Global Services Private Limited The DCIT PL 10, Gate no,4 Circle 14(3)(1), Room No. 455, 4th Floor, Godrej & Boyce Complex Vs. Pirojshanagar, LBS Marg Aayakar Bhavan, M.K. Road, Vikhroli (West) Mumbai-400 020 Mumbai-400 079 (Appellant) (Respondent) PAN No. AAACW2598L WNS Global Services Private The DCIT Limited…

M/S. Course5 Intelligence Private Limited (Formerly Cross Tab Marketing Services Private Limited), Bangalore vs. The Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the appeal filed by assessee stands allowed for statistical purposes

ITA 15/BANG/2020[2013-14]Status: DisposedITAT Bangalore18 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Course5 Intelligence Pvt. Ltd., (Formerly Cross Tab Marketing Services The Deputy Pvt. Ltd.) Commissioner Of No. 422, 80 Feet Income Tax, Road, Circle – 2(1)(1), 6Th Block, Vs. Bangalore. Koramangala, Bangalore – 560 095. Pan: Aabcc6525A Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca : Shri Srinivas Rao Bandaru, Revenue By Jcit Dr Date Of Hearing : 14-07-2022 Date Of Pronouncement : 18-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 14/10/2019 Passed By Ld.Cit(A)-2, Bangalore For A.Y. 2013-14 On Following Grounds Of Appeal: “1. The Learned Assessing Officer Had Erred In Passing The Order In The Manner Passed By Him & The Learned Cit (A) Has Erred In Partially Confirming The Same. The Orders Passed Being Bad In Law & Liable To Be Quashed.

For Respondent: Shri Padam Chand Khincha
Section 10ASection 143(2)Section 234B

…taxmann.com 66 (Delhi Trib.) [Page 160-163 of the paperbook]. 2.10 The conclusion of the learned AO that the deduction under section 10AA is to be given only after the setting off of loss of other units is also incorrect. The Supreme Court in Yokogawa's case 391 ITR 274 held that deduction under section 10AA has to be immediately on computing the income of the eligible undertaking under Chapter IV uninfluenced by the results of the other undertakings. The ratio of the Supreme Court decision in Yokogawa's case is applicable also to deduction under section 10AA. 2.11 On the basis of the above, the denial of deduct…

Addl CIT RG 10(2), Mumbai vs. Geometric Softwar Solutions Co. Ltd, Mumbai

In the result, ground no

ITA 6219/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Jul 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm M/S Geometric Software The Acit Solutions Company Ltd. Ward 10(2), [ Now Merged With Hcl Room No.432, 4Th Floor, Technologies Limited ] Vs. Aayakar Bhavan, M.K. Marg, 806, Sidharth, 96 Nehru Mumbai-400 020 Place, New Delhi 19 (Respondent) (Appellant) Pan No. Aabcg 0066 A Co No. 157/Mum/2011 (Arising In Ita No.6219/Mum/2010 For A.Y. 2005–06) M/S Geometric Software Solutions Company Ltd. The Acit (Now Gemetric Ltd.) [ Now Ward 10(2), Room No.432, 4Th Floor, Merged With Hcl Vs. Technologies Limited] Aayakar Bhavan, M.K. Marg, Mumbai-400 020 806, Sidharth, 96 Nehru Place, New Delhi 19 (Respondent) (Cross Objector) Assessee By : Shri Porus F. Kaka & Shri Manish Kanth, Ars‟ Revenue By : Shri Sumit Kumar, Dr Date Of Hearing: 21.07.2022 Date Of Pronouncement : 29.07.2022

For Appellant: Shri Porus F. Kaka &For Respondent: Shri Sumit Kumar, DR
Section 10ASection 14A

…other eligible unit. The learned Authorized Representative submitted that this issue is squarely covered in favour of the assessee by the decision of Hon'ble Supreme Court in assessee‟s own case in case of CIT v. Yokogawa India Ltd. [2017] 77 taxmann.com 41, 391 ITR 274. 014. The learned Departmental Representative supported the orders of the lower authorities. 015. We have carefully considered the rival contentions and found that in assessee own case Hon'ble Supreme Court has held that from reading provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible unde…

Geometric Software Solutins Co. Ltd ( Now Gemetric Ltd), Mumbai vs. Addl CIT RG 10(2), Mumbai

In the result, ground no

ITA 5975/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Jul 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm M/S Geometric Software The Acit Solutions Company Ltd. Ward 10(2), [ Now Merged With Hcl Room No.432, 4Th Floor, Technologies Limited ] Vs. Aayakar Bhavan, M.K. Marg, 806, Sidharth, 96 Nehru Mumbai-400 020 Place, New Delhi 19 (Respondent) (Appellant) Pan No. Aabcg 0066 A Co No. 157/Mum/2011 (Arising In Ita No.6219/Mum/2010 For A.Y. 2005–06) M/S Geometric Software Solutions Company Ltd. The Acit (Now Gemetric Ltd.) [ Now Ward 10(2), Room No.432, 4Th Floor, Merged With Hcl Vs. Technologies Limited] Aayakar Bhavan, M.K. Marg, Mumbai-400 020 806, Sidharth, 96 Nehru Place, New Delhi 19 (Respondent) (Cross Objector) Assessee By : Shri Porus F. Kaka & Shri Manish Kanth, Ars‟ Revenue By : Shri Sumit Kumar, Dr Date Of Hearing: 21.07.2022 Date Of Pronouncement : 29.07.2022

For Appellant: Shri Porus F. Kaka &For Respondent: Shri Sumit Kumar, DR
Section 10ASection 14A

…other eligible unit. The learned Authorized Representative submitted that this issue is squarely covered in favour of the assessee by the decision of Hon'ble Supreme Court in assessee‟s own case in case of CIT v. Yokogawa India Ltd. [2017] 77 taxmann.com 41, 391 ITR 274. 014. The learned Departmental Representative supported the orders of the lower authorities. 015. We have carefully considered the rival contentions and found that in assessee own case Hon'ble Supreme Court has held that from reading provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible unde…

Sitel India Ltd, Mumbai vs. DCIT RG 8(3), Mumbai

In the result, appeal by the Revenue is partly allowed

ITA 1777/MUM/2012[2007-08]Status: DisposedITAT Mumbai15 Jul 2022AY 2007-08

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ajit Jain a/wFor Respondent: Shri Tejinder Pal Singh
Section 10ASection 250

…in appeal before us. 43. During the course of hearing, learned Representatives appearing for both the parties fairly agreed that this issue is now settled in favour of the taxpayer by the decision of Hon’ble Supreme Court in CIT vs Yokogawa India Ltd, [2017] 391 ITR 274 (SC). 44. Thus, respectfully following the aforesaid decision of Hon’ble Supreme Court in Yokogawa India Ltd. (supra), we find no infirmity in the impugned order passed by the learned CIT(A) on this issue. Accordingly, ground No. 4 raised in Revenue’s appeal is dismissed. Sitel India Ltd. ITA No.1777/Mum./2012 and ITA no.1426/Mum./2012 45. In t…

Dy.CIT-8(3), Mumbai vs. Sitel India Ltd., Mumbai

In the result, appeal by the Revenue is partly allowed

ITA 1426/MUM/2012[2007-08]Status: DisposedITAT Mumbai15 Jul 2022AY 2007-08

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ajit Jain a/wFor Respondent: Shri Tejinder Pal Singh
Section 10ASection 250

…in appeal before us. 43. During the course of hearing, learned Representatives appearing for both the parties fairly agreed that this issue is now settled in favour of the taxpayer by the decision of Hon’ble Supreme Court in CIT vs Yokogawa India Ltd, [2017] 391 ITR 274 (SC). 44. Thus, respectfully following the aforesaid decision of Hon’ble Supreme Court in Yokogawa India Ltd. (supra), we find no infirmity in the impugned order passed by the learned CIT(A) on this issue. Accordingly, ground No. 4 raised in Revenue’s appeal is dismissed. Sitel India Ltd. ITA No.1777/Mum./2012 and ITA no.1426/Mum./2012 45. In t…

The ITO, Alappuzha vs. M/S.Extraweave P. Ltd, Alappuzha

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

ITA 448/COCH/2016[2010-11]Status: DisposedITAT Cochin24 Jun 2022AY 2010-11

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Extraweave Pvt. Ltd. Arattukulangara Complex 264B/Cmc 1 Vs. A.N. Puram, Alapuzha 688011 Sakteeswara Junction Cherthala 688524 Pan – Aabce5438L Appellant Respondent

For Appellant: Shri R. Krishan, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 10BSection 10B(3)Section 143(2)Section 195Section 195(6)Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri George George K., Judicial Member and Shri Laxmi Prasad Sahu, Accountant Member M/s. Extraweave Pvt. Ltd. Arattukulangara Complex 264B/CMC 1 Vs. A.N. Puram, Alapuzha 688011 Sakteeswara Junction Cherthala 688524 PAN – AABCE5438L Appellant Respondent Appellant by: Shri R. Krishan, CA Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 22.06.2022 Date of Pronouncement: 24.06.2022 O R D E R Per: L.P. Sahu, A.M. This is an appeal filed by the Revenue against the order of the learned CIT(A), Kottayam dated 21.07.2016 for AY 2010-11.…

ACIT, Circle- 5(1), New Delhi vs. Birla Soft India Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5346/DEL/2019[2008-09]Status: DisposedITAT Delhi09 Jun 2022AY 2008-09

Bench: Sh. Anil Chaturvedi & Sh. Narender Kumar Choudhryacit Vs. Birla Soft India Ltd. Circle – 5(1), 8Th Floor, Birla Tower, 25, New Delhi Barakhamba Road, New Delhi-110 001 Pan : Aaacb 2769 E (Appellant) (Respondent)

Section 10ASection 143(3)Section 254

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SH. ANIL CHATURVEDI, ACCOUNTANT MEMBER AND SH. NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER ACIT Vs. Birla Soft India Ltd. Circle – 5(1), 8th Floor, Birla Tower, 25, New Delhi Barakhamba Road, New Delhi-110 001 PAN : AAACB 2769 E (APPELLANT) (RESPONDENT) Assessee by Shri Sheetal Kumar, Adv. Revenue by Shri Zahid Parvez, Sr. D.R. Date of hearing: 09.06.2022 Date of Pronouncement: 09.06.2022 ORDER PER ANIL CHATURVEDI, AM : The present appeal filed by the Revenue is directed against the order dated 11.03.2019 of the Commissioner of Income Tax…

Inventurus Knowledge Solutions Pvt Ltd, Mumbai vs. PCIT, Mumbai 6

ITA 246/MUM/2022[2016-17]Status: DisposedITAT Mumbai03 Jun 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman आअसं.246/मुं/2022 ("न.व. 2016-17) Inventurus Knowledge Solutions Pvt. Ltd. 801, Mindspace Business Park Pvt. Ltd., Building No.5 & 6, Thane Belapur Road, Airoli East, Navi Mumbai – 400 708. Pan: Aabci-5573-J ...... अपीलाथ" /Appellant बनाम Vs. Pcit,Mumbai -6 Circle 15(1)(2) Aaykar Bhavan, M.K.Road, Mumbai 400 020. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri S.C.Tiwari, Advocate ""तवाद" "वारा/Respondent By : Shri Jayant Jhaveri सुनवाई क" "त"थ/ Date Of Hearing : 09/03/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 03/06/2022 आदेश/ Order Per Vikas Awasthy, Jm:

For Appellant: Shri S.C.Tiwari, AdvocateFor Respondent: Shri Jayant Jhaveri
Section 10ASection 143(2)Section 143(3)Section 263

…passed the impugned order. The ld.Authorized Representative for the assessee further pointed that even on merits the case of assessee is squarely covered by the decision of Hon'ble Supreme Court of India in the case of CIT vs. Yokogawa India Ltd. reported as 391 ITR 274 and in the case of PCIT vs. Rangsons Electronics Pvt. Ltd., 398 ITR 619. The ld.Authorized Representative for the assessee to further buttress his submissions placed reliance on the decision in the case of Kelvinator of India Ltd., 123 Taxaman433 to contend that when assessment order u/s. 143(3) is passed a presumption can be raised that such an…

Hewlett-Packard Globalsoft Private Limtied, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

ITA 835/BANG/2016[2011-12]Status: DisposedITAT Bangalore03 Jun 2022AY 2011-12

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI. CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 810/Bang/2016 Assessment Year : 2011-12 M/s. EIT Services India Pvt. Ltd., The Assistant Formerly known as Commissioner of Hewlett Packard Global Income Tax, Soft Pvt. Ltd., Circle 3 (1)(2), No. 39, 40, Bangalore. Vs. Electronic City, Phase – I, Bangalore – 560 100. PAN: AAACD4078L APPELLANT RESPONDENT & IT(TP)A No. 835/Bang/2016 Assessment Year : 2011-12 (By Assessee) : Shri Padam Chand Khincha, Assessee by CA : Dr. Manjunath Karkihalli, Revenue by CIT DR D…

DCIT, Bangalore vs. M/S Hewlett Packard Globalsoft Pvt. Ltd., Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

ITA 810/BANG/2016[2011-12]Status: DisposedITAT Bangalore03 Jun 2022AY 2011-12

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI. CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 810/Bang/2016 Assessment Year : 2011-12 M/s. EIT Services India Pvt. Ltd., The Assistant Formerly known as Commissioner of Hewlett Packard Global Income Tax, Soft Pvt. Ltd., Circle 3 (1)(2), No. 39, 40, Bangalore. Vs. Electronic City, Phase – I, Bangalore – 560 100. PAN: AAACD4078L APPELLANT RESPONDENT & IT(TP)A No. 835/Bang/2016 Assessment Year : 2011-12 (By Assessee) : Shri Padam Chand Khincha, Assessee by CA : Dr. Manjunath Karkihalli, Revenue by CIT DR D…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1408/CHNY/2016[2007-2008]Status: DisposedITAT Chennai25 May 2022AY 2007-2008

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1407/CHNY/2016[2008-2009]Status: DisposedITAT Chennai25 May 2022AY 2008-2009

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1254/CHNY/2016[2006-2007]Status: DisposedITAT Chennai25 May 2022AY 2006-2007

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1253/CHNY/2016[2005-2006]Status: DisposedITAT Chennai25 May 2022AY 2005-2006

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1252/CHNY/2016[2004-2005]Status: DisposedITAT Chennai25 May 2022AY 2004-2005

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…

International Agricultural Processing (P) Ltd., Chennai vs. ACIT, Madurai

In the result, the appeals filed by the assessee for the AYs 2003-04

ITA 1251/CHNY/2016[2003-2004]Status: DisposedITAT Chennai25 May 2022AY 2003-2004

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Banusekar, CAFor Respondent: Mr.P.Sajit Kumar, JCIT
Section 10BSection 133ASection 143(2)Section 143(3)Section 147Section 148

…deduction claimed u/s.10B of the Act. 4.1 The Ld.AR for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the Hon’ble Supreme Court in the case of CIT & Anr. v. Yokogawa India Ltd., reported in [2017] 391 ITR 274 (SC), wherein, the Hon’ble Supreme Court had considered very similar issue and held that the stage of deduction under Chapter-IV of the Act, would be while computing gross total income of the eligible undertaking and not at the stage of the computation of total income under Chapter-VI of the Act. Therefore, he submitted that the assessee is ent…