IPCA Laboratories Ltd. v. DCIT

266 ITR 521Supreme Court of India2004#854 most cited

What is IPCA Laboratories Ltd. v. DCIT authority for?

When the provisions of a fiscal statute are unambiguous, they must be interpreted strictly, and benefits not explicitly provided cannot be conferred by ignoring or misinterpreting the clear words in the section.

122

judgments rely on this decision, according to BharatTax’s citation analysis of 367,514 Indian tax judgments — from 2007 to 2026.

Also referred to as

IPCA Laboratories Ltd. v. DCIT · 266 ITR 521 · statutory interpretation · fiscal statutes · unambiguous provisions · tax benefits · deductions · Section 80IB · Section 80HHC · strict construction · legislative intent

Sections most often in play

Section 143(3)Section 250Section 80IBSection 80IB(2)Section 80IB(4)

Issues it is cited on

section 80hhc(3)section 80hsection 28(iv)section 80hhsection 80hhcsection 115jamat creditretrospective amendmentsection 72section 36(2)deduction under section 80iasection 245

Judgments citing IPCA Laboratories Ltd. v. DCIT

Commissioner of Income Tax Del vs. M/S Dewan Kraft System P. Ltd

The appeals are dismissed

ITA/977/2005HC Delhi27 Feb 2007

Bench: HON'BLE MR. JUSTICE B.N.CHATURVEDI

Section 80

…ed as business income. 10. Learned counsel for the Appellant in support of its ITA NO.977/2005 & 186/2006 page 4 of 8 contention has cited decision of Apex court in IPCA Laboratory Ltd. v. Deputy Commissioner of Income Tax (2004) 266 ITR 521 and Commissioner of Income Tax v.Kotagiri Industrial Co-operative Tea Factory Ltd., (1997) 224 ITR 604. 11. On the other hand, it has been argued by learned counsel for the Respondent that the Assessing Officer while computing the income, restricted the deduction at Rs.11,80,952/- being the amount allowable to the extent of…

Commissioner of Income Tax-V N vs. Damanjit Singh

ITA/166/2000HC Delhi12 Jan 2007

…partment is that even if the interest earned is to be construed as part of the business income, the netting should not be permitted since the statute does not specifically say so. Reliance was placed on the judgment in IPCA Laboratory Ltd. v. DCIT (2004) 266 ITR 521, CIT v. Chinnapandi (2006) 282 ITR 389 and Rani Paliwal v. C.I.T. 2004 268 ITR 220. 28. In Rani Paliwal the High Court, without any detailed discussion simply held as follows: “A plain reading of clause (baa) of Explanation to section 80HHC of the Act makes this aspect quite clear and we are of the view that the Tribunal was right in dis…