Madras v. Canara Workshops P.Ltd.

161 ITR 320Supreme Court of India1986#2094 most cited

What is Madras v. Canara Workshops P.Ltd. authority for?

For the purpose of computing profits eligible for a special deduction, such as under Section 80E or Section 10AA, losses from other independent divisions or ineligible businesses are not to be set off against the profits of the eligible unit. The profits of the eligible business must be computed independently.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2023.

Also referred to as

Madras v. Canara Workshops P.Ltd. · 161 ITR 320 · Supreme Court 1986 · Section 80E · Section 10AA · special deductions · eligible business profits · computation of deduction · set-off of losses · independent units · separate divisions · aggregation of losses

Judgments citing Madras v. Canara Workshops P.Ltd.

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

ITA 370/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jun 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sandeep Huilgol, AdvocateFor Respondent: Dr. Manjunath Karkihallli, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(2)Section 143(3)Section 80G

…by treating the cost of development of shrink wrap computer software as work in progress and therefore cannot set off the loss?” 163. The said substantial questions of law was considered by the apex court in the case of CIT v. Canara Workshops P. Ltd. (1986) 161 ITR 320 (SC) in favour of the assessee and against the Revenue. IT(TP)A No.370/Bang/2021 Page 56 of 110 164. Following the said judgement in the assessee’s case itself in ITA 1395 of 2006 connected with ITA 1394 of 2006, this court by its order dated November, 5, 2013 following the judgement of the Supreme Court answered the said substantial question o…

THE ACIT, CENTRAL-2, INDORE vs. M/S. SHAKTI PUMPS (INDIA) LTD., INDORE

ITA 1358/IND/2016[2010-11]Status: DisposedITAT Indore26 Apr 2023AY 2010-11

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2010-11 Acit (Central)-2, Shakti Pumps (India) Ltd. Indore 226, Shastri Market, बनाम/ M.G. Road, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Aaecs 5027 L Revenue By Shri P.K. Mishra, Cit-Dr Assessee By Ms. Nisha Lahoti & Vijay Bansal, Ars Date Of Hearing 23/11/2022 / 22.02.2023 Date Of Pronouncement 26.04.2023

Section 10ASection 143(2)Section 143(3)Section 145Section 263

…titative details - AO denied deduction holding that the deduction is to be allowed after setting off of loss from one division against profit of other division HELD- The units are totally independent-Decision of Supreme Court in Canara Workshop (P) Ltd (1986) 161 ITR 320 directly on issue- Deduction to be allowed." 2.43 The appellant further claimed that the Ld. AO drew certain inferences without any basis and profits of DTA units have been lowered as compared to SEZ Unit and reallocated the expenses so as to reduce the claim made u/s 10AA. 2.44 It was further submitted that the separate books are maintained and…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result, assessee’s appeal is partly allowed

ITA 417/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad10 Oct 2022AY 2014-15

Bench: Shri Pramod M. Jagtap & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 417/Ahd/2018 ("नधा"रण वष" / Assessment Year : 2014-15) M/S. Rajkamal Builders The D.C.I.T. बनाम/ Infrastructure Pvt. Ltd. Circle – 3(1)(2), Vs. Ahmedabad 54, Park Hill Society, Opp: Karnavati Club Nr. Heaven Park, Ramdevnagar, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcr0326A .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Shri Mehul K. Patel, Advocate अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Vijay Kumar Jaiswal, Cit. D.R. सुनवाई क" तार"ख / Date Of 13/07/2022 Hearing घोषणा क" तार"ख /Date Of 10/10/2022 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal Filed By The Assessee Is Directed Against The Order Dated 20.12.2017 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 9, Ahmedabad Arising Out Of The Order Dated 17.10.2016 Passed By The Dcit, Circle-3(1)(2), Ahmedabad Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As To ‘The Act’) For Assessment Year 2014-15, Whereby & Whereunder Mainly The Claim Under Section 80Ia(4) Of The Act Made By The

For Respondent: Shri Vijay Kumar Jaiswal, CIT. D.R
Section 143(3)Section 234ASection 36(1)Section 80Section 80I

…assed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

THE JCIT(OSD), CIRCLE-3(1)(2),, AHMEDABAD vs. M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

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

ITA 90/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad08 Jun 2022AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalassessment Year : 2012-13 Jcit, Cir.3(1)(2) Shri Rajkamal Builders Ahmedabad. Vs Infrastructure P.Ltd. Pan : Aabcr 0326 A 54, Park Hill, Nr.Heaven Park Ramdevnagar Ahmedabad 380 015. अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) Assessee By : Shri M.K. Patel, Ar Revenue By : Shri Vijay Kumar, Jaiswal,Cit- Dr सुनवाई क" तार"ख/Date Of Hearing : 19/05/2022 घोषणा क" तार"ख /Date Of Pronouncement: 8/06/2022 आदेश/O R D E R Per Waseem Ahmed, Accounant Member: This Is Revenue’S Appeal Against The Order Of Ld.Cit(A)-9, Ahmedabad Dated 19.11.2018 Vide Which The Ld.Cit(A) Has Deleted Penalty Of Rs.1,05,74,312/- Imposed Under Section 271(1)(C) Of The Income Tax Act, 1961 ("The Act" For Short) For The Asst.Year 2012-13. 2. Sole Ground Raised By The Revenue Reads As Under: “1. The Ld.Cit(A) Has Erred In Law & On Facts In Deleting The Penalty Of Rs.1,05,74,312/- Imposed U/S.271(1)(C) Of The Act On Issue Of Disallowance Of Losses Set Off & Deduction Under Section 80Ia Of The Act Of Rs.3,11,10,071/-.”

For Appellant: Shri M.K. Patel, ARFor Respondent: Shri Vijay Kumar, Jaiswal,CIT-
Section 143(3)Section 271(1)(c)Section 274Section 80Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R
Section 143(3)

…by treating the cost of development of shrink wrap computer software as work in progress and therefore cannot set off the loss?” 163. The said substantial questions of law was considered by the apex court in the case of CIT v. Canara Workshops P. Ltd. (1986) 161 ITR 320 (SC) in favour of the assessee and against the Revenue. 164. Following the said judgement in the assessee’s case itself in ITA 1395 of 2006 connected with ITA 1394 of 2006, this court by its order dated November, 5, 2013 following the judgement of the Supreme Court answered the said substantial question of law in favour of the assessee and again…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2202/AHD/2018[2016-17]Status: DisposedITAT Ahmedabad13 May 2022AY 2016-17

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2201/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad13 May 2022AY 2015-16

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1499/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad13 May 2022AY 2011-12

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2917/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad13 May 2022AY 2010-11

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2916/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad13 May 2022AY 2013-14

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD vs. M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2706/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad13 May 2022AY 2010-11

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

THE ACIT, CIRCLE-5,, AHMEDABAD vs. M/S. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 199/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad13 May 2022AY 2009-10

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1281/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad13 May 2022AY 2012-13

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

THE ACIT, CIRCLE-5,, AHMEDABAD vs. M/S. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2765/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad13 May 2022AY 2008-09

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ACIT, CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2334/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad13 May 2022AY 2011-12

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ACIT, CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 3126/AHD/2013[2010-11]Status: DisposedITAT Ahmedabad13 May 2022AY 2010-11

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

THE ACIT, CIRCLE-5,, AHMEDABAD vs. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1966/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad13 May 2022AY 2007-08

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE JT.CIT.,(OSD)CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1385/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad13 May 2022AY 2009-10

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 442/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad13 May 2022AY 2007-08

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 441/AHD/2011[2004-05]Status: DisposedITAT Ahmedabad13 May 2022AY 2004-05

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…ssed by the Hon’ble jurisdictional High Court. While dealing with this particular aspect of the matter the Hon’ble Court was pleased to observed as follows: “5. In the case of Commissioner of Income tax(Central) Madras vs. Canara Workshops P.Ltd. Reported in 161 ITR 320, in the context of deductions provided under section 80E of the Act, the Supreme Court held that the merit earned by one industry not to be lost or diminished for loss by some other industry when assessee was carrying on two priority industries. It was held that loss in one industry is not to be set off against profits from the other and the dedu…

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