Sterling Agro Products Processing (P) Ltd. v. ACIT

ACIT Cir 4(2), Mumbai vs. M .M. Poonjiaji Spices Ltd, Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

DCIT., Cir.-4(2), Mumbai vs. M.M. Poonjiaji Spices Ltd, Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

DCIT Cir 4(2), Mumbai vs. M.M. Poonjilaji Spices Ltd, Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufac…

Income Tax Officer 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

ITO - 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

ITO - 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

I.T.O-4(2)(4), Mumbai vs. M/S M.M.Poonjiaji Spices Ltd, Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

ITO - 4(2)(2), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

…nd different process can be said to engaged in manufacturing activity or not which is entitled for deduction under section 10 B of the act. Identical issue arose in case of Sterling Agro Products Processing (P.) Ltd. [2011] 13 taxmann.com 174 (Chennai)/[2011] 48 SOT 80 wherein the coordinate bench has held as under:- "3.ITA Nos. 598 to 600/Mds/2011: It was submitted by the learned authorised representative that the only issue in the assessee's appeals was as to whether the assessee is entitled to the benefit of deduction u/s 10B of the Income-tax Act, 1961 ('the Act' in short) in regard to its business of manufa…

Rohda Specialtiy Chemicals India Ltd, Mumbai vs. Addl CIT Cir 6(1), Mumbai

Appeal stands dismissed for want of substantial question of law

Bench: Shri Shamim Yahya & Shri C.N. Prasadita No. 830/Mum/2014 : (A.Y : 2009-10) M/S Rhodia Specialty Chemicals Vs. Addl. Cit – Circle 6(1) India Ltd. (Formerly Known As Room No.511, Aayakar Bhawan M/S Albright & Wilson Chemicals Mk Road India Ltd.), Phoenix House, A Wing New Marine Lines 4Th Floor, 462 Senapati Bapat Marg Mumbai – 400 020 Lower Parel (West) Mumbai – 400 013 Pan : Aaaca3841L Ita No. 622/Mum/2014 : (A.Y : 2009-10) Dcit -7(2) Vs. M/S Rhodia Specialty Chemicals Room No.624, Mk Road India Ltd. (Formerly Known As Mumbai – 400 020 M/S Albright & Wilson Chemicals India Ltd.), Phoenix House, A Wing 4Th Floor, 462 Senapati Bapat Marg Lower Parel (West) Mumbai – 400 013 (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent)

…ot arise. 18. Ld Counsel in support of his above contentions placed reliance on the following cases 1. CIT Vs. Woodward Governor India (P) Ltd. [312 ITR 254] 2. CIT Vs. Mysore Sugar Co-Ltd [46 ITR 649] 3. Sterling Agro Products Processing Pvt. Ltd. Vs. ACIT [48 SOT 80] 19. The Ld. DR on the other hand vehemently supported the orders of the authorities below. 20. We have heard the rival submissions, perused the orders of the authorities below. The Assessing Officer disallowed this amount as the Assessee in the assessment proceedings did not give proper explanation as to how this amount is allowable deduction an…

DCIT 7(2), Mumbai vs. Albright & Wilson Chemicals India Ltd, Mumbai

Appeal stands dismissed for want of substantial question of law

Bench: Shri Shamim Yahya & Shri C.N. Prasadita No. 830/Mum/2014 : (A.Y : 2009-10) M/S Rhodia Specialty Chemicals Vs. Addl. Cit – Circle 6(1) India Ltd. (Formerly Known As Room No.511, Aayakar Bhawan M/S Albright & Wilson Chemicals Mk Road India Ltd.), Phoenix House, A Wing New Marine Lines 4Th Floor, 462 Senapati Bapat Marg Mumbai – 400 020 Lower Parel (West) Mumbai – 400 013 Pan : Aaaca3841L Ita No. 622/Mum/2014 : (A.Y : 2009-10) Dcit -7(2) Vs. M/S Rhodia Specialty Chemicals Room No.624, Mk Road India Ltd. (Formerly Known As Mumbai – 400 020 M/S Albright & Wilson Chemicals India Ltd.), Phoenix House, A Wing 4Th Floor, 462 Senapati Bapat Marg Lower Parel (West) Mumbai – 400 013 (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent)

…ot arise. 18. Ld Counsel in support of his above contentions placed reliance on the following cases 1. CIT Vs. Woodward Governor India (P) Ltd. [312 ITR 254] 2. CIT Vs. Mysore Sugar Co-Ltd [46 ITR 649] 3. Sterling Agro Products Processing Pvt. Ltd. Vs. ACIT [48 SOT 80] 19. The Ld. DR on the other hand vehemently supported the orders of the authorities below. 20. We have heard the rival submissions, perused the orders of the authorities below. The Assessing Officer disallowed this amount as the Assessee in the assessment proceedings did not give proper explanation as to how this amount is allowable deduction an…