Which sections of the Income Tax Act does IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai come up under?

It is most often cited in judgments turning on Section 80-I(1), Section 80-I(6), Section 80A(2), Section 80AB, Section 80B(5).

IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai

Q: How many judgments cite IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai?

10 judgments on BharatTax cite IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai (12 SCC 742), spanning 2005 to 2024.

12 SCC 742Reported decision2004#10102 most cited

What is IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai authority for?

When computing deductions under Section 80HHC, profits from the export of self-manufactured goods and trading goods cannot be considered separately if there is a loss in one, and the deduction is admissible if the overall business income is positive after set-off.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2005 to 2024.

Also referred to as

IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax · 80HHC · export house certificate · self-manufactured goods · trading goods · deduction · set-off of losses

Sections most often in play

Section 80-I(1)Section 80-I(6)Section 80A(2)Section 80AB Section 80B(5)

Judgments citing IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai

Medley Pharmaceuticals Ltd., Mumbai vs. Dy.C.I.T., Cent.Cir.44, Mumbai

In the result, the captioned appeals filed by the assessee are allowed

ITA 1387/MUM/2009[2002-2003]Status: DisposedITAT Mumbai09 Dec 2024AY 2002-2003

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Ravi Sawana, Adv., Ms. Neha Sharma & Shri Apurva Chudhry, A/RFor Respondent: Shri Kailash C. Kanojiya, CIT, D/R

Section 80I

…ition of gross total income as given under section 80B(5) the Delhi High Court has held that while computing the income, all provisions are required to be applied and only thereafter the deductions have to be allowed. In IPCA Laboratory Ltd. v. Dy. CIT [2004] 12 SCC 742 the appellant was a holder of an Export House Certificate. It exported self-manufactured goods as well as goods manufactured by supporting manufacturers. It had earned a I.T.A. No. 1387 to 1390/Mum/2009 8 profit from the export of self-manufactured goods and had suffered loss from the export of trading goods. In its return for assessment year 199…

Commissioner of Income Tax Del vs. M/S Arya Exports & Industries

ITA/206/2005HC Delhi18 Aug 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MS. JUSTICE PRATHIBA M. SINGH

Section 260ASection 80Section 80H

…n the first place have got a deduction, the Assessee as a supporting manufacturer afortiori cannot. The main plank of the case of the Revenue is the decision of the Supreme Court in IPCA Laboratory Ltd. v. Deputy Commissioner of Income Tax, Mumbai (2004) 12 SCC 742 and, in particular, the observations recorded in para 15 therein. Analysis of Section 80 HHC 16. Before discussing the said decision it is important to refer to Sections 80 HHC (1) and 80 HHC (1A) of the Act, which read as under: "Deduction in respect of profits retained for export business. 80 HHC (1) Where an assessee, being an Indian co…

Jeyar Consultant & Investment Pvt. Ltd vs. Commissioner of Income Tax, Madras

C.A. No.-008912-008912 - 2003Supreme Court01 Apr 2015

Section 80H

…term “profit of business” would not confine to profit from export business but income both from export business as well as from domestic business, had to be taken into consideration. Therefore, even if there was a loss from the export 1 (2004) 12 SCC 742 2 (2007) 9 SCR 831 Civil Appeal No. 8912 of 2003 Page 7 of 24 Page 8 JUDGMENT business, but there was profit from the business done within the country and on adjustment of loss from the export business against the profits from the business in India, in the balance sheet, it was still profit resulting into positive income, the benefit…

Jeyar Consultant & Investment Pvt. Ltd vs. Commissioner of Income Tax, Madras

C.A. No.-008912-008912 - 2003Supreme Court01 Apr 2015

Section 80H

M/S. Synco Industries Ltd vs. Assessing Officer, Income Tax Mumbai &Anr

C.A. No.-004190-004191 - 2002Supreme Court13 Mar 2008

For Respondent: Assessing Officer, Income Tax,Mumbai & Anr

Section 260Section 80Section 80ASection 80GSection 80HSection 80J

…under Section 80B(5) the Delhi High Court has held that while computing the income, all provisions are required to be applied and only thereafter the deductions have to be allowed. In IPCA Laboratory Ltd. V. Dy. Commissioner of Income-Tax, Mumbai (2004) 12 SCC 742 the appellant was a holder of an Export House certificate. It exported self-manufactured goods as well as goods manufactured by supporting manufacturers. It had earned a profit from the export of self-manufactured goods and had suffered loss from the export of trading goods. In its return for assessment year 1996-97, it claimed deduction u…

A.M. Moosa vs. Commnr of Income Tax, Trivandrum

C.A. No.-004144-004144 - 2007Supreme Court10 Sept 2007

For Respondent: COMMISSIONER OF INCOME TAX, TRIVANDRUM

Section 28Section 80Section 80HSection 8O

…ection (3) means a positive profit worked out after taking into consideration the losses, if any. Thus the word "profit" has the same meaning in Sections 80-HHC(1) and (3). 13. In IPCA Laboratory Ltd. Vs. Dy. Commissioner of Income Tax, Mumbai, (2004) 12 SCC 742), after analyzing the position in the manner done above, it was held that the profit as contemplated under Section 80-HHC (1) and Section 80-HHC (3) means positive profit. Said view was reiterated in Income Tax Officer, Bangalore Vs. Induflex Products (P) Ltd., (2006 (1) SCC 458). We are in respectful agreement with the view. 14. Above…

Commnr. of Income Tax, Pune vs. Shirke Construction Equipment Ltd

The appeal stands allowed accordingly

C.A. No.-006758-006758 - 2001Supreme Court17 May 2007

For Respondent: Shirke Construction Equipment Ltd

Section 29Section 72Section 80Section 80H

…oods manufactured by it. This decisions of the Bombay High Court in the present case and the High Court of Kerala in C.I.T. v. T.C. Usha (supra) have been overruled by this Court in IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai [(2004) 12 SCC 742]. 5. The facts in the present case are similar as that http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 2 of 4 in IPCA Laboratory Ltd. (supra), hence the same are not restated herein. In IPCA Laboratory Ltd. (supra), the counsel appearing for the assessee had placed reliance on two judgments, i.e., one by the Bombay High Court in CI…

Commnr.of Income Tax, Thiruvananthapuram vs. M/S Baby Marine Exports Kollam

Appeals stand disposed of in terms of our

C.A. No.-006146-006146 - 2005Supreme Court30 Mar 2007

For Respondent: M/s Baby Marine Exports, Kollam

Section 80Section 80H

…ge. This Court in Sea Pearl Industries v. CIT Cochin (2001) 2 SCC 33 also observed that the object of Section 80HHC is to grant incentive to earners of foreign exchange. In IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai reported in (2004) 12 SCC 742 this Court has taken the same view. This Court in the said judgment observed that Section 80HHC has been incorporated with a view to provide incentive to export houses and this Section must receive liberal interpretation. In Bajaj Tempo Ltd. v. Commissioner of Income Tax, Bombay reported in (1992) 3 SCC 78, this Court while interpre…

P.R. Prabhakar vs. Commnr. of Income Tax, Coimbatore

C.A. No.-000877-000877 - 2006Supreme Court18 Jul 2006

For Respondent: Commissioner of Income Tax, Coimbatore

Section 80H

…andise manufactured or processed by the assessee but also of trading goods. The Parliament, therefore, intended to provide incentive when a positive profit is earned by an exporter. [See IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai, [2004] 12 SCC 742.] The question again came up for consideration before a Division Bench of this Court in Income Tax Officer, Bangalore v. M/s. Induflex Products (P) Ltd., (2005) 10 SCALE 132, wherein: it was opined. "...It is no doubt true that the term ‘profit’ implies positive profit which has to be arrived at after taking into consideration the profit earned…

Income Tax Officer, Bangalore vs. M/S. Induflex Products (P) Ltd

C.A. No.-007307-007307 - 2005Supreme Court08 Dec 2005

For Respondent: Induflex Products (P) Ltd

Section 143(3)Section 260ASection 263Section 28Section 80H

…which can be the subject-matter of exemption. A fortiori if a profit is not earned, the question of claiming exemption would not arise. The question came up recently before this Court in IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai., [2004] 12 SCC 742. In that case, the taxable income before the deductions under Chapter VI-A came to Rs. 4.39 crores. The Appellants therein, however, claimed various deductions in terms of Section 80HHC to the extent of Rs. 3.78 crores. It was found that the sun of Rs. 3.78 crores claimed for deduction was the profit for exports of self-manufactured goods. It was…