Textile Machinery Corporation Ltd. v. CIT

107 ITR 195Supreme Court of India1977#591 most cited

What is Textile Machinery Corporation Ltd. v. CIT authority for?

A new industrial undertaking is not considered a reconstruction of an existing business for tax deduction purposes if it is a separate, independent production unit manufacturing commercially tangible products that can operate without losing its identity in the old business. The transfer and substantial use of assets and manpower from an old business to a new one may indicate reconstruction.

165

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2008 to 2026.

Also referred to as

Textile Machinery Corporation Ltd. v. CIT · 107 ITR 195 · Section 80J · Section 80IC · new industrial undertaking · reconstruction of business · splitting up of business · tax deduction eligibility · independent production unit · transfer of substantial assets · tax benefits

Also reported as

2 SCC 368

Sections most often in play

Section 143(3)Section 263Section 80-ICSection 10(2A)Section 143(3A)Section 28(v)Section 40(b)Section 143(3B)

Issues it is cited on

section 2(29ba)software technology parksection 80jsection 80icsection 80hhcsection 80hhtax benefitsection 80isection 80iasection 10aarm's length pricegross total income

Judgments citing Textile Machinery Corporation Ltd. v. CIT

Addl. CIT, New Delhi vs. M/S. Mahle Filter Systems (India) Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3572/DEL/2017[2008-09]Status: DisposedITAT Delhi15 Jan 2020AY 2008-09

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2008-09

Section 143(3)Section 147Section 80Section 801CSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘E’, NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER Assessment Year: 2008-09 Addl. CIT, Vs. M/s. Mahle Filter Systems Special Range-6, (India) Ltd., C.R. Building, 1, Sri Aurbindo Marg, New Delhi New Delhi PAN :AAACP5890Q (Appellant) (Respondent) Appellant by Ms. Rakhi Vimal, Sr.DR Respondent by Shri Neeraj Jain, Adv.; Shri Anshul Sachar, CA; and Shri Karan Jain, CA Date of hearing 08.01.2020 Date of pronouncement 15.01.2020 ORDER PER O.P. KANT, AM: This appeal by the Revenue is directed against the order dated 31.0…

Cooper Bussmann India Pvt. Ltd., Pondicherry vs. JCIT, Pondicherry

In the result, the assessee’s appeals for the assessment years 2001-02, 2002-03, 2003-04, 2004-05, 2005-06, 2006-07, 2007-

ITA 178/CHNY/2017[2011-12]Status: DisposedITAT Chennai01 Nov 2019AY 2011-12

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1559 To 1563, 2592 - 2594/Chny/2014) (िनधा"रण वष" / Assessment Years: 2001-02 To 2008-09) Vs The Acit, M/S. Cooper Bussmann India Pvt. Ltd., Circle – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) & आयकर अपील सं./I.T.A.Nos. 1662 & 1663/Chny/2016 & 178/Chny/2017 (िनधा"रण वष" / Assessment Years: 2009-10 To 2011-12) Vs The Jcit, M/S. Cooper Bussmann India Pvt. Ltd., Range – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Vishal Kalra, Advocate ""यथ" क" ओर से/Respondent By : Shri M. Srinivasa Rao, Cit

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri M. Srinivasa Rao, CIT
Section 80ISection 80l

…noticing certain shortcomings in the quantum of the machinery purchased by the assesse and also holding that the assessee has not satisfied two major conditions as mentioned by the Supreme Court of India in the case of M/s Textile Machinery Corporation vs CIT 107 ITR 195 as under: 1. The manufacture of production or article or things by the so called new industrial undertaking with reference to the investment of substantial capital made in the so called new industrial undertaking. 2. The assessee company was not able to establish that the so called new industrial undertaking is a separate and distinct and identi…

Cooper Bussmann India Private Limited, Pondicherry vs. ACIT, Pondicherry

In the result, the assessee’s appeals for the assessment years 2001-02, 2002-03, 2003-04, 2004-05, 2005-06, 2006-07, 2007-

ITA 1563/CHNY/2014[2008-09]Status: DisposedITAT Chennai01 Nov 2019AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1559 To 1563, 2592 - 2594/Chny/2014) (िनधा"रण वष" / Assessment Years: 2001-02 To 2008-09) Vs The Acit, M/S. Cooper Bussmann India Pvt. Ltd., Circle – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) & आयकर अपील सं./I.T.A.Nos. 1662 & 1663/Chny/2016 & 178/Chny/2017 (िनधा"रण वष" / Assessment Years: 2009-10 To 2011-12) Vs The Jcit, M/S. Cooper Bussmann India Pvt. Ltd., Range – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Vishal Kalra, Advocate ""यथ" क" ओर से/Respondent By : Shri M. Srinivasa Rao, Cit

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri M. Srinivasa Rao, CIT
Section 80ISection 80l

…noticing certain shortcomings in the quantum of the machinery purchased by the assesse and also holding that the assessee has not satisfied two major conditions as mentioned by the Supreme Court of India in the case of M/s Textile Machinery Corporation vs CIT 107 ITR 195 as under: 1. The manufacture of production or article or things by the so called new industrial undertaking with reference to the investment of substantial capital made in the so called new industrial undertaking. 2. The assessee company was not able to establish that the so called new industrial undertaking is a separate and distinct and identi…

Cooper Bussmann India Private Limited, Pondicherry vs. ACIT, Pondicherry

In the result, the assessee’s appeals for the assessment years 2001-02, 2002-03, 2003-04, 2004-05, 2005-06, 2006-07, 2007-

ITA 1559/CHNY/2014[2001-02]Status: DisposedITAT Chennai01 Nov 2019AY 2001-02

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1559 To 1563, 2592 - 2594/Chny/2014) (िनधा"रण वष" / Assessment Years: 2001-02 To 2008-09) Vs The Acit, M/S. Cooper Bussmann India Pvt. Ltd., Circle – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) & आयकर अपील सं./I.T.A.Nos. 1662 & 1663/Chny/2016 & 178/Chny/2017 (िनधा"रण वष" / Assessment Years: 2009-10 To 2011-12) Vs The Jcit, M/S. Cooper Bussmann India Pvt. Ltd., Range – 1, 34, Evr Street, Sedarapet, Pondicherry. Pondicherry - 605 111. Pan: Aabcs 0431R (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Vishal Kalra, Advocate ""यथ" क" ओर से/Respondent By : Shri M. Srinivasa Rao, Cit

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri M. Srinivasa Rao, CIT
Section 80ISection 80l

…noticing certain shortcomings in the quantum of the machinery purchased by the assesse and also holding that the assessee has not satisfied two major conditions as mentioned by the Supreme Court of India in the case of M/s Textile Machinery Corporation vs CIT 107 ITR 195 as under: 1. The manufacture of production or article or things by the so called new industrial undertaking with reference to the investment of substantial capital made in the so called new industrial undertaking. 2. The assessee company was not able to establish that the so called new industrial undertaking is a separate and distinct and identi…

Oil India Ltd., Dibrugarh vs. The Assistant Commissioner of Income Tax, Circle-2, Dibrugarh

ITA 33/GTY/2018[2008-09]Status: DisposedITAT Guwahati26 Aug 2019AY 2008-09

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

Oil India Ltd., Dibrugarh vs. Assistant Commissioner of Income Tax, Circle -2, Dibrugarh

ITA 9/GTY/2014[2010-11]Status: DisposedITAT Guwahati26 Aug 2019AY 2010-11

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

Oil India Ltd., Dibrugarh vs. Assistant Commissioner of Income Tax, Range -2, Dibrugarh

ITA 325/GTY/2013[2009-10]Status: DisposedITAT Guwahati26 Aug 2019AY 2009-10

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

Oil India Ltd., Dibrugarh vs. Additional Commissioner of Income Tax, Range -2, Dibrugarh

ITA 87/GTY/2010[2007-08]Status: DisposedITAT Guwahati26 Aug 2019AY 2007-08

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

The Assistant Commissioner of Income Tax, Circle-2, Dibrugarh vs. Oil India Ltd., Dibrugarh

ITA 123/GTY/2008[2006-07]Status: DisposedITAT Guwahati26 Aug 2019AY 2006-07

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

The Assistant Commissioner of Income Tax, Circle-2, Dibrugarh vs. Oil India Ltd., Dibrugarh

ITA 122/GTY/2008[2005-06]Status: DisposedITAT Guwahati26 Aug 2019AY 2005-06

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

The Assistant Commissioner of Income Tax, Circle-2, Dibrugarh vs. Oil India Ltd., Dibrugarh

ITA 121/GTY/2008[2004-05]Status: DisposedITAT Guwahati26 Aug 2019AY 2004-05

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

The Assistant Commissioner of Income Tax, Circle-2, Dibrugarh vs. Oil India Ltd., Dibrugarh

ITA 120/GTY/2008[2003-04]Status: DisposedITAT Guwahati26 Aug 2019AY 2003-04

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 143(3)Section 251Section 80I

…ally undertaken for the production or distribution of goods or for rendering of material service to the community at large or a part of such community with the help of the employee is an undertaking. In the case of Textile Corporation Ltd. Vs. CIT reported in 107 ITR 195, the question asked was what constitutes a new industrial undertaking which is eligible for deduction under Section 15C of the Income Tax Act, 1922 (corresponding provision is 80J and 84). The Supreme Court pointed out at page 204 that a new industrial undertaking should be separate physically from than the old one, the capital of which and the p…

DCIT 3(3)(2), Mumbai vs. Parkar Markewel Industries P.Ltd, Navi Mumbai

In the result, both the appeals of Revenue are dismissed

ITA 769/MUM/2016[2006-07]Status: DisposedITAT Mumbai15 Jun 2018AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri Dr. SK Shivram &For Respondent: Shri Rajat Mittal, DR
Section 10BSection 143(3)Section 254Section 263

…Aayakr ApIlaIya AiQakrNa “C” nyaayapIz maMuba[- mao. IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SRI MAHAVIR SINGH, JM AND SRI G MANJUNATHA, AM Aayakr ApIla saM./ ITA No. 768/Mum/2016 (inaQa-arNa baYa- / Assessment Year 2004-05) Aayakr ApIla saM./ ITA No. 769/Mum/2016 (inaQa-arNa baYa- / Assessment Year 2006-07) The Dy. Commissioner of M/s Parkar Markwel Income Tax 3(2)(2), Mumbai Industries P. Ltd (Formerly known as Markwel Hose Industries Pvt. Ltd.) Vs. Plot No. EL-25, MIDC, TTC Industrial Area, Navi Mumbai-400 709 .. (p`%yaqaaI- / Respondent) (ApIlaaqaI- / Appellant) PAN No. AAACM9967D R…

DCIT 3(3)(2), Mumbai vs. Parkar Markewel Industries P.Ltd, Navi Mumbai

In the result, both the appeals of Revenue are dismissed

ITA 768/MUM/2016[2004-05]Status: DisposedITAT Mumbai15 Jun 2018AY 2004-05

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri Dr. SK Shivram &For Respondent: Shri Rajat Mittal, DR
Section 10BSection 143(3)Section 254Section 263

…Aayakr ApIlaIya AiQakrNa “C” nyaayapIz maMuba[- mao. IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SRI MAHAVIR SINGH, JM AND SRI G MANJUNATHA, AM Aayakr ApIla saM./ ITA No. 768/Mum/2016 (inaQa-arNa baYa- / Assessment Year 2004-05) Aayakr ApIla saM./ ITA No. 769/Mum/2016 (inaQa-arNa baYa- / Assessment Year 2006-07) The Dy. Commissioner of M/s Parkar Markwel Income Tax 3(2)(2), Mumbai Industries P. Ltd (Formerly known as Markwel Hose Industries Pvt. Ltd.) Vs. Plot No. EL-25, MIDC, TTC Industrial Area, Navi Mumbai-400 709 .. (p`%yaqaaI- / Respondent) (ApIlaaqaI- / Appellant) PAN No. AAACM9967D R…

Mahabir Industries vs. Principal Commissioner of Income Tax

C.A. No.-004765-004766 - 2018Supreme Court18 May 2018

Bench: Stating The Question Of Law, It May Be Necessary To Mention In Brief The Background Under Which The Said Question Of Law Has Arisen Civil Appeal No(S). 4765-4766 Of 2018 & Anr. Page 1 Of 15 Digitally Signed By Sushil Kumar Rakheja Date: 2018.05.18 17:05:49 Ist Reason: Signature Not Verified

Section 80

…the endeavour of learned senior counsel was that the assessee cannot be treated as an industrial undertaking which has reconstructed the business i.e. made substantial expansion. This argument has to be rejected for at least two reasons: 1 (1977) 2 SCC 368 Civil Appeal No(s). 4765-4766 of 2018 & Anr. Page 13 of 15 (i) Section 15C of the 1922 Act provided exemption from tax to newly established industrial undertaking if they are not ‘formed by reconstruction of business already in existence’. Thus, under the said provision, if it was found that an industrial undertaking is formed by reconstruction…

Saf Yeast Company P.Ltd, Mumbai vs. Asst CIT Cen Cir 40, Mumbai

In the result the appeal of the assessee for AY 2009-10 is partly allowed

ITA 1875/MUM/2014[2009-10]Status: DisposedITAT Mumbai16 May 2018AY 2009-10

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 80I

…esent and, therefore, the Cooling Power and Steam Power generation undertakings have been setup for generation of power. The CIT(A) has correctly held so in the assessee's case. Hon'ble Supreme Court in the case of Textile Machinery Corpn. Ltd. vs. CIT [1977] 107 ITR 195 held that in order to be entitled to the benefit under Section 15C of the Act, the following facts have to be established by the assessee, subject always to time- schedule in the Section: 1. Investment of substantial fresh capital in the industrial undertaking set up, 2. Employment of requisite labour therein, 3. Manufacture or production of art…

Sap Labs India Pvt. Ltd., Bangalore vs. Addl.C.I.T

In the result, the appeal filed by the assessee as well as the revenue is partly allowed

ITA 981/BANG/2013[2008-09]Status: DisposedITAT Bangalore06 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: S/ShriKanchun Kaushal &For Respondent: Shri Ch.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 80JSection 92C

…ope for speaking about any reconstruction of an existing business." 9. The judgment of the Division Bench of this court in Gaekwar Foam [1959] 35 ITR 662 (Bom) was approved by the Supreme Court in a judgment in Textile Machinery Corporation Ltd. v. CIT [1977] 107 ITR 195 (SC). The Supreme Court, in that case, dealt with the issue as to whether within the meaning of section 15C(2)(i) of the Indian Income-tax Act, 1922, the industrial undertakings which consisted of a steel foundry division and jute mill division were not formed by the reconstruction of a business already in existence. The Supreme Court observed th…

DCIT vs. M/S Sap Labs India Pvt. Ltd., Bangalore

In the result, the appeal filed by the assessee as well as the revenue is partly allowed

ITA 1070/BANG/2013[2008-09]Status: DisposedITAT Bangalore06 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: S/ShriKanchun Kaushal &For Respondent: Shri Ch.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 80JSection 92C

…ope for speaking about any reconstruction of an existing business." 9. The judgment of the Division Bench of this court in Gaekwar Foam [1959] 35 ITR 662 (Bom) was approved by the Supreme Court in a judgment in Textile Machinery Corporation Ltd. v. CIT [1977] 107 ITR 195 (SC). The Supreme Court, in that case, dealt with the issue as to whether within the meaning of section 15C(2)(i) of the Indian Income-tax Act, 1922, the industrial undertakings which consisted of a steel foundry division and jute mill division were not formed by the reconstruction of a business already in existence. The Supreme Court observed th…

Asst.C.I.T., Bellary vs. M/S Hothur Traders 100% Eou, Bellary

In the result, Revenue’s appeals for asst

ITA 32/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2018AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazita No.32/Bang/2016 (Asst. Years 2010-11 & 2011-12) The Asst. Commissioner Of Income-Tax, Circle-1, Bellary. . Appellant Vs. M/S Hothur Traders 100% Eou, No.85,6,7&8, Infantry Road, Cantonment, Bellary. . Respondent Pan –Aaefh7705H. Co No.55/Bang/2016 (By Assessee) Appellant By : Shri Nagendra Prasad, Cit Respondent By : Shri B.S Balachandran, Advocate Date Of Hearing : 22-11-2017 Date Of Pronouncement : 19-01-2018

For Appellant: Shri Nagendra Prasad, CITFor Respondent: Shri B.S Balachandran, Advocate
Section 10ASection 10BSection 143(3)Section 40

…as drawn between reconstruction of a business and sale of the business and it was held that in the case of a sale there can be no question of reconstruction. This decision was approved by the Supreme Court in Textile Machinery Corporation Ltd. vs. CIT. (1977) 107 ITR 195. Reliance was also placed on a ITA Nos.20/B/15 & 32/B/16 CO No.55/B/16 29 Circular issued by the Board under the provisions of Section 84 stating that the benefit under the provision attaches not to the ownership of the undertaking but to the undertaking itself. On further appeal by the Revenue to the Hon'ble High Court, the Hon'ble High Court…

The Deputy Commissioner of Income Tax Circle 11 (1) Bangalore vs. M/S Ace Multi Axes Systems Ltd

Appeals are disposed of in the same terms

C.A. No.-020854-020854 - 2017Supreme Court05 Dec 2017

Bench: HON'BLE MR. JUSTICE ADARSH KUMAR GOEL

Section 263Section 33BSection 80

…1 REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 20854 OF 2017 (ARISING OUT OF SPECIAL LEAVE PETITION (CIVIL) NO.4565 OF 2015) DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 11 (1), BANGALORE …APPELLANT VERSUS M/S. ACE MULTI AXES SYSTEMS LTD. ...RESPONDENTS WITH CIVIL APPEAL NO. 20856 OF 2017 (ARISING OUT OF SPECIAL LEAVE PETITION (CIVIL) NO.8331 OF 2016) WITH CIVIL APPEAL NO. 20857 OF 2017 (ARISING OUT OF SPECIAL LEAVE PETITION (CIVIL) NO.3323 OF 2016) WITH CIVIL APPEAL NO. 20855 OF 2017 (ARISING OUT OF SPECIAL LEAVE PETITION (CIVIL) NO.148 OF 2016) J U…