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 367,154 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.

The Commissioner of Income-Tax vs. M/S Mind Tree Ltd

In the result, we do not find any merit in this

ITA/251/2013HC Karnataka25 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10BSection 260Section 260A

…ISSIONER OF INCOME-TAX VS. HCL TECHNOLOGIES LTD.’, (2018) 404 ITR 719 (SC), whereas the second substantial question of law has also been answered against the revenue by Supreme Court in ‘COMMISSIONER OF INCOME-TAX VS. YOKOGAWA INDIA LTD.’, (2017) 391 ITR 274 (SC). However, with reference to third substantial question of law, it is submitted that neither the Commissioner of Income Tax (Appeals) nor the Tribunal has recorded a finding that the expenditure was incurred for application of software and not system software. Therefore, the matter deserves to be remitted. 7 However, i…

Tata Consultancy Services Ltd, Mumbai vs. Addl CIT Large Tax Payer Unit, Mumbai

In the result the appeal of the assessee in AY 2008-09 is partly allowed and

ITA 794/MUM/2018[2010-11]Status: DisposedITAT Mumbai18 Aug 2020AY 2010-11

Bench: Shri Pawan Singh & Shri Rajesh Kumarvertual Court No. Iii It(Tp)A No. 3263/Mum/2017 For Ay 2008-09 It(Tp) No. 794/Mum/2018 For Ay 201-011 Tata Consultancy Services Vs Dcit Ltd.,9Th Floor, Nirmal Bldg, Large Tax Payer Unit-1, 29Th Floor, Wtc, Nariman Point. Mumbai – 21 Cufee Parade Pan Aaacr4849R Mumbai- 05. Appellant Respondednt

For Appellant: with Sh. Manish Kumar KanthFor Respondent: Shri Sanjay Singh, CIT (DR)
Section 40Section 90Section 90(1)(a)Section 92CSection 92C(3)

…R is factually incorrect and wrong. In para 48 of Wipro’s case Karnataka High Court considered the decision of Yokogava India Ltd (2012) 341 ITR 385. The revenue went in appeal before Supreme Court, wherein it was held that section 10A is deduction provision (391 ITR 274 SC). Thus the submissions of the ld DR that the decision of Karnataka High Court is contrary to the decision of Supreme Court in Yokogava India is misplaced and wrong. 21. On the other hand, the ld. DR for the revenue supported the order of lower authorities. The ld DR for the revenue in his written submissions after referring the decision of…

The Commissioner of Income Tax vs. M/S Mind Tree Ltd

In the result, the appeal is dismissed

ITA/50/2013HC Karnataka17 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10BSection 10B(1)Section 260

…ng.” 3. When the matter was taken up today, learned counsel for the revenue fairly submitted that the substantial question of law has been answered against the revenue by the Supreme Court in ‘COMMISSIONER OF INCOME-TAX Vs. YOKOGAWA INDIA LTD.’ (2017) 291 CTR 1 (SC). 4. In view of the aforesaid enunciation of law, the substantial question of law framed in this appeal is answered against the revenue and in favour of the assessee. In the result, the appeal is dismissed. Sd/- JUDGE Sd/- JUDGE RV…

General Mills India P.Ltd, Mumbai vs. Asst CIT RG 14(1)(2), Mumbai

ITA 1804/MUM/2015[2010-11]Status: DisposedITAT Mumbai27 Jul 2020AY 2010-11

Bench: Shri Saktijit Dey, Jm& Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No.1698/Mum/2015 (निर्धारणवर्ा / Assessment Year: 2010-11) Acit 14(1)(2) General Mills India Pvt. 460 Aayakarbhavan, 4Th Floor, Ltd. Alpha 8Th Floor, बिधम/ M. K. Marg, Main Street Hiranandani Vs. Mumbai-400 020. Garden, Powai,Mumbai- 400076. स्थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacg1773B & आयकरअपीलसं./ I.T.A. No. 1804/Mum/2015 (निर्धारणवर्ा / Assessment Year: 2010-11) General Mills India Pvt. Ltd. Acit 14(1)(2) बिधम/ Alpha 8Th Floor, Main Street 460 Aayakarbhavan, 4Th Hiranandani Garden, Powai, Floor, M. K. Marg, Vs. Mumbai-400076. Mumbai-400 020. अपीलाथीकीओरसे/ Appellant By : Sh. M. P. Lohia, Ar प्रत्यथीकीओरसे/Respondentby : Sh. Anani Mohan, Dr

For Appellant: Sh. M. P. Lohia, ARFor Respondent: Sh. Anani Mohan, DR
Section 143(2)Section 143(3)Section 144C(5)Section 92

…provider and comparable companies which will have variations in respect of working capital and risk factors. 20. With regard to revenue appeal, he submitted that the issue under challenge is squarely covered by Yokogawa decision of the Hon’ble Supreme Court (391 ITR 274). 21. On the other hand Ld DR submitted a detailed written submission before us and he brought to our notice all the submissions made by him in written form which is reproduced below: I. Ground No. 4 & 5 of Assessee’s Appeal 1. Why CG Vak Software and Exports Ltd. is not a valid comparable for A.Y. 2010-11 Argument no. 1 1. The assessee’s turnov…

The Commissioner of Income Tax vs. M/S Infosys Bpo Ltd

In the result, the appeals are dismissed

ITA/279/2012HC Karnataka11 Jun 2020

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 10ASection 260Section 263

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF JUNE 2020 PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND THE HON’BLE MR.JUSTICE HEMANT CHANDANGOUDAR I.T.A. NO.280 OF 2012 C/W I.T.A. NO.279 OF 2012 IN I.T.A. NO.280 OF 2012 BETWEEN 1. THE COMMISSIONER OF INCOME-TAX C R BUILDING, QUEENS ROAD, BANGALORE 2. THE COMMISSIONER OF INCOME TAX-I, CIRCLE-1 C R BUILDING, QUEENS ROAD, BANGALORE. ... APPELLANTS (BY SRI DILIP, ADV. FOR SRI. K V ARAVIND, ADV.) AND M/S. INFOSYS BPO LTD., 26/3, 26/4 & 26/6 ELECTRONIC CITY, HOSUR ROAD BANGAL…

The Commissioner of Income Tax vs. M/S Infosys Bpo Ltd

In the result, the appeals are dismissed

ITA/280/2012HC Karnataka11 Jun 2020

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 10ASection 260Section 263

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF JUNE 2020 PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND THE HON’BLE MR.JUSTICE HEMANT CHANDANGOUDAR I.T.A. NO.280 OF 2012 C/W I.T.A. NO.279 OF 2012 IN I.T.A. NO.280 OF 2012 BETWEEN 1. THE COMMISSIONER OF INCOME-TAX C R BUILDING, QUEENS ROAD, BANGALORE 2. THE COMMISSIONER OF INCOME TAX-I, CIRCLE-1 C R BUILDING, QUEENS ROAD, BANGALORE. ... APPELLANTS (BY SRI DILIP, ADV. FOR SRI. K V ARAVIND, ADV.) AND M/S. INFOSYS BPO LTD., 26/3, 26/4 & 26/6 ELECTRONIC CITY, HOSUR ROAD BANGAL…

Ramnath and Co vs. The Commissioner of Income Tax

C.A. No.-002506-002509 - 2020Supreme Court05 Jun 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 80

…to suggest the contrary.” 18 Apart from the principles already noticed hereinbefore, profitable it would be to point out that the basic principles of interpretation of taxing statutes have been re-condensed by this Court in CIT v. Yokogawa India Ltd.: (2017) 391 ITR 274 (SC) as follows : “The cardinal principles of interpretation of taxing statutes centres around the opinion of Rowlatt, J. in Cape Brandy Syndicate v. Inland Revenue Commissioners which has virtually become the locus classicus. The above would dispense with the necessity of any further elaboration of the subject notwithstanding the num…

Genesys International Corporation Ltd., Mumbai vs. Dy CIT 9(3)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 7574/MUM/2019[2011-12]Status: DisposedITAT Mumbai04 Mar 2020AY 2011-12

Bench: Shri G. Manjunatha & Shri Ravish Soodgenesys International Vs. Dcit-9(3)(2) Corporation Limited Aaykar Bhawan 73A, Sdf Iii, 2Nd Floor M.K.Road Seepz, Andheri Mumbai-400 020 Mumbai-400 096 Pan/Gir No.Aaaca4528L Appellant) .. Respondent)

Section 10ASection 143Section 148

…on'ble CIT(A) erred in not allowing of set off of losses of non-eligible unit against the income of eligible unit before claiming deduction u/s-10AA of the Act without considering the facts that Hon'ble Apex court in case of CIT vs. Yokogawa India Ltd. (2017) 391 ITR 274 3 Genesys International Corporation (SC) had decided the issue in favour of the Assessee after examining Circular No.7 dated 16.07.2013 10. Without Prejudice to above, on the facts and circumstances of the case and in law, the Hon'ble CIT(A) erred in not applying the Principle of Judicial Precedent by following the decision of the Supreme Court…

ITO Corporate Ward 4(1), Chennai vs. Medusa Services Private Limited, Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 2416/CHNY/2018[2010-11]Status: DisposedITAT Chennai19 Feb 2020AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Duvvuru R.L. Reddyआयकर अपील सं./I.T.A. No. 2416/Chny/2018 िनधा"रण वष"/Assessment Year: 2010-11 The Income Tax Officer, M/S. Medusa Services Pvt. Ltd., Corporate Ward 4(1), Vs. No. 93, First Floor, Lakshmi Tower, Chennai 600 034. Arcot Road, Kodambakkam, Chennai 600 024. [Pan:Aaecm1187F] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. R. Anita, Jcit ""थ" की ओर से/Respondent By : Shri Vepa Krishna, C.A. सुनवाई की तारीख/ Date Of Hearing : 06.02.2020 घोषणा की तारीख /Date Of Pronouncement : 19.02.2020 आदेश /O R D E R Per Duvvuru Rl Reddy:

For Appellant: Ms. R. Anita, JCITFor Respondent: Shri Vepa Krishna, C.A
Section 10ASection 10BSection 143(3)Section 147

…he sides, perused the materials available on record and gone through the orders of authorities below. While affirming the decision of the Hon’ble Karnataka High Court in the case of CIT v. Yokogawa India Ltd. 341 ITR 385, the Hon’ble Supreme Court reported in 391 ITR 274 has observed and held as under: “16. From a reading of the relevant provisions of Section 10A it is more than clear to us that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of dedu…

East Wind Footwear Company Limited - India Branch, Thiruvannamalai vs. DCIT International Taxation 1(1) & 1(2), Chennai

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

ITA 1655/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Jan 2020AY 2014-15

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No.1655/Chny/2017 िनधा"रण वष"/Assessment Year:2014-15 M/S. East Wind Footwear Company The Deputy Commissioner Of Vs. Limited – India Branch, Plot No. 3, Income Tax, D&E, Sipcot Industrial Park, Mathur, International Taxation 1(1) & 1(2), Mangal Village, Cheyyar T.K., Chennai. Thiruvannamalai, Tamil Nadu 631 701. [Pan: Aacce5043N] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से/Respondent By : Shri S. Ramakrishnan, Cit सुनवाई की तारीख/ Date Of Hearing : 29.01.2020 घोषणा की तारीख /Date Of Pronouncement : 31.01.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Passed Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] Dated 28.04.2017 Relevant To The Assessment Year 2014-15. The Effective Grounds Raised In The Appeal Of The Assessee Are That The Assessing Officer & The Drp Have Erred In Law In Not Allowing The Deduction Under Section 10Aa Of The Act & Computation Of Tax Payable & Levy Of Interest Under Section 234D Of The Act.

For Appellant: Shri Ashik Shah, C.AFor Respondent: Shri S. Ramakrishnan, CIT
Section 10ASection 115JSection 143(1)Section 143(3)Section 234D

…ing off the brought forward loss and unabsorbed depreciation. 3. On being aggrieved, the assessee is in appeal before the Tribunal against the final assessment order. By filing various case law including the decision in the case of CIT v. Yokogawa India Ltd. 391 ITR 274 (SC), the ld. 3 Counsel for the assessee has submitted that the deduction under section 10AA of the Act has to be granted and thereafter set off from remaining profit if any brought forward losses and unabsorbed depreciation should be made. On the other hand, the ld. DR supported the orders of authorities below. 4. We have heard both the sides,…

Logix Microsystems Limited, Bangalore vs. ITO, Bangalore

In the result, the appeal is partly allowed

ITA 186/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Jan 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B R Baskaranit(Tp)A No.453/Bang/2015 & It(Tp)A No.186/Bang/2016 Assessment Years : 2010-11 & 2011-12

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

…ence this ground of appeal by the Assessee before the Tribunal. 27. At the time of hearing it was agreed by the parties before us that this issue is no longer res integra and has been concluded by the Hon’ble Supreme Court in the case of Yokogawa India Ltd., 391 ITR 274 by its order dated 16.12.2016 and in the aforesaid decision the Hon’ble Supreme Court took the following view :- • That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the IT(TP)A No.453/B/2015 & IT(TP)A No.186/B/2016 Page 20 of 28 eligible undertaking of an assessee s…

Logix Microsystems Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeal is partly allowed

ITA 453/BANG/2015[2010-11]Status: DisposedITAT Bangalore29 Jan 2020AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B R Baskaranit(Tp)A No.453/Bang/2015 & It(Tp)A No.186/Bang/2016 Assessment Years : 2010-11 & 2011-12

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

…ence this ground of appeal by the Assessee before the Tribunal. 27. At the time of hearing it was agreed by the parties before us that this issue is no longer res integra and has been concluded by the Hon’ble Supreme Court in the case of Yokogawa India Ltd., 391 ITR 274 by its order dated 16.12.2016 and in the aforesaid decision the Hon’ble Supreme Court took the following view :- • That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the IT(TP)A No.453/B/2015 & IT(TP)A No.186/B/2016 Page 20 of 28 eligible undertaking of an assessee s…

Niit Technologies Ltd., New Delhi vs. ACIT, New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5525/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…/801A has to be computed with reference to profits of the eligible business / undertaking, unaffected by the profits / losses suffered in other eligible/ ineligible business owned by the assessee. Hon’ble Karnataka High Court in the CIT v. Yokogawa India Ltd. 314 ITR 385/ 246 CTR 226 while dealing with the issue of deduction u/s 10A of the Act, observed that the relief under this section is with reference to the STP undertakings and not ITA Nos. 5524 & 5525/Del/2013 to the assessee. It was held that the phrase “total income” used in sec 10A(1) is to be understood as the total income of the STP unit. Special Benc…

Niit Technologies Ltd., New Delhi vs. ACIT, New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5524/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…/801A has to be computed with reference to profits of the eligible business / undertaking, unaffected by the profits / losses suffered in other eligible/ ineligible business owned by the assessee. Hon’ble Karnataka High Court in the CIT v. Yokogawa India Ltd. 314 ITR 385/ 246 CTR 226 while dealing with the issue of deduction u/s 10A of the Act, observed that the relief under this section is with reference to the STP undertakings and not ITA Nos. 5524 & 5525/Del/2013 to the assessee. It was held that the phrase “total income” used in sec 10A(1) is to be understood as the total income of the STP unit. Special Benc…

ACIT, New Delhi vs. M/S Niit Technologies Ltd., New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5492/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…/801A has to be computed with reference to profits of the eligible business / undertaking, unaffected by the profits / losses suffered in other eligible/ ineligible business owned by the assessee. Hon’ble Karnataka High Court in the CIT v. Yokogawa India Ltd. 314 ITR 385/ 246 CTR 226 while dealing with the issue of deduction u/s 10A of the Act, observed that the relief under this section is with reference to the STP undertakings and not ITA Nos. 5524 & 5525/Del/2013 to the assessee. It was held that the phrase “total income” used in sec 10A(1) is to be understood as the total income of the STP unit. Special Benc…

ACIT, New Delhi vs. M/S Niit Technologies Ltd., New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5491/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…/801A has to be computed with reference to profits of the eligible business / undertaking, unaffected by the profits / losses suffered in other eligible/ ineligible business owned by the assessee. Hon’ble Karnataka High Court in the CIT v. Yokogawa India Ltd. 314 ITR 385/ 246 CTR 226 while dealing with the issue of deduction u/s 10A of the Act, observed that the relief under this section is with reference to the STP undertakings and not ITA Nos. 5524 & 5525/Del/2013 to the assessee. It was held that the phrase “total income” used in sec 10A(1) is to be understood as the total income of the STP unit. Special Benc…

Gateway Internet Protocol Management Pvt. Ltd., Pune vs. Principal Commissioner of Income-Tax : 1

In the result, the appeal of the assessee is allowed

ITA 1600/PUN/2016[2011-12]Status: DisposedITAT Pune19 Dec 2019AY 2011-12

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.1600/Pun/2016 "नधा"रण वष" / Assessment Year : 2011-12

For Appellant: Shri Ketan DhootFor Respondent: Shri S.B. Prasad
Section 10ASection 143(3)Section 263

…/-. He submitted that the deduction u/s 10A of the Act is to be allowed from the total income of the assessee before giving effect to the provisions of the said section and that Hon’ble Apex Court in the case of CIT Vs. Yokogawa India Ltd., reported in (2017) 391 ITR 274 has held the loss or unabsorbed depreciation is to be set off against profits of eligible units after the deduction u/s 10A of the Act has been allowed. He further submitted that the Hon’ble Apex Court has further held that the provisions of Sec.10A of the Act is a provision for deduction and the stage of deduction would be while computing the…

Commnr.of Income Tax vs. Indian Metals and Ferr

ITA/19/2014HC Orissa04 Dec 2019

Bench: MR. JUSTICE K. S. JHAVERI (CJ),MR. JUSTICE K.R.MOHAPATRA

Deputy Commissioner of Income Tax 1 (1), Indore vs. M/S Agrawal Coal Corp. Pvt. Ltd., Indore

In the result all the three appeals of the revenue are

ITA 803/IND/2018[2014-15]Status: DisposedITAT Indore28 Nov 2019AY 2014-15

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

Section 143(3)Section 14A

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE HON’BLE KUL BHARAT, JUDICIAL MEMBER AND HON’BLE MANISH BORAD, ACCOUNTANT MEMBER ITA Nos. 801 to 803/Ind/2018 Assessment Years 2012-13 to 2014-15 DCIT 1(1) M/s. Agrawal Coal Corporation Indore Vs. Pvt.Ltd, 5, Yashwant Niwas Road, Indore (Revenue) (Respondent ) PAN No. AACCA8468K ITA Nos. 778/Ind/2018 & C.O.No.23 & 24/Ind/2019 Assessment Years 2013-14 & 2014-15 M/s. Agrawal Coal Corporation DCIT 1(1) Pvt.Ltd, Vs. Indore 5, Yashwant Niwas Road, Indore (Appellant) (Respondent ) PAN No. AACCA8468K Revenue by…

DCIT !(1) Indore, Indore vs. Agrawal Coal Corporation (P) Ltd., Indore

In the result all the three appeals of the revenue are

ITA 802/IND/2018[2013-14]Status: DisposedITAT Indore28 Nov 2019AY 2013-14

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

Section 143(3)Section 14A

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE HON’BLE KUL BHARAT, JUDICIAL MEMBER AND HON’BLE MANISH BORAD, ACCOUNTANT MEMBER ITA Nos. 801 to 803/Ind/2018 Assessment Years 2012-13 to 2014-15 DCIT 1(1) M/s. Agrawal Coal Corporation Indore Vs. Pvt.Ltd, 5, Yashwant Niwas Road, Indore (Revenue) (Respondent ) PAN No. AACCA8468K ITA Nos. 778/Ind/2018 & C.O.No.23 & 24/Ind/2019 Assessment Years 2013-14 & 2014-15 M/s. Agrawal Coal Corporation DCIT 1(1) Pvt.Ltd, Vs. Indore 5, Yashwant Niwas Road, Indore (Appellant) (Respondent ) PAN No. AACCA8468K Revenue by…