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“Section 43(6)”

Section References (mined)Section 43Section 43(6)257 judgments

The decision most relied on for Section 43(6) is Union of India v. Tata Chemicals Ltd. (363 ITR 658), cited in 91 judgments on BharatTax.

Leading authorities on Section 43(6)

Union of India v. Tata Chemicals Ltd.
363 ITR 658 · 2014 · Supreme Court
91
citing judgments

The Department has a moral and legal obligation to refund excess tax collected from taxpayers, along with interest. An assessee is entitled to interest on the amount of taxes refunded, including interest on interest, as per Section 244A of the Income-tax Act.

Joint Commissioner. 10. In Shin Etsu Chemical Co. Ltd. v. Aksh Optifibre Ltd.
7 SCC 234 · 2005 · Reported
75
citing judgments

A statute prescribing a procedure using negative language (e.g., 'in no other manner') imposes absolute requirements, and failure to comply will invalidate the entire proceeding.

Sharp Business System v. CIT III
27 Taxmann.com 50 · 2012 · High Court
53
citing judgments

A non-compete fee, being a capital expenditure, is not allowable as a deduction from income and does not qualify for depreciation under Section 32(1)(ii) of the Income-tax Act, 1961.

Sharp Business System v. CIT
254 CTR 233 · 2012 · High Court
50
citing judgments

Depreciation is allowable on a non-compete fee as it constitutes an intangible asset, even if the right acquired cannot be transferred, provided it is treated as part of a block of assets.

Madhav Rao Jivaji Rao Scindia Bahadur v. Union of India
3 SCR 9 · 1971 · Reported
43
citing judgments

A word, clause, or sentence from a court judgment, when taken out of context, does not represent a complete exposition of the law on a question that the judgment did not explicitly address.

Marketing Pvt. Ltd. v. DCIT
122 Taxmann.com 40 · 2020 · Reported
41
citing judgments

Where goodwill is recorded pursuant to a merger based on purchase consideration determined by a valuation report, and no goodwill is transferred from the predecessor's books, the fifth proviso to section 32(1) of the Income-tax Act, 1961, is not applicable, and thus depreciation on such goodwill is not allowable.

United Breweries Ltd. v. ACIT
76 Taxmann.com 103 · 2016 · ITAT
41
citing judgments

Depreciation on goodwill arising from amalgamation is not admissible to the amalgamated company if no goodwill was admitted in the hands of the amalgamating company, applying Explanation 7 to Section 43(1) and the Sixth Proviso to Section 32(1)(ii).

194 Taxman 43 (Delhi) (ii) The Pr. CIT, Central-1 v. Adamine Construction (P.) Ltd.
99 Taxmann.com 45 · 2018 · Supreme Court
39
citing judgments

Where the Assessing Officer (AO) does not conduct any further inquiry or investigation to support additions made, and there is no positive evidence to confirm the AO's action, additions under section 68 cannot be sustained if the loan transaction was properly documented and repaid through banking channels.

Judgments citing Section 43(6)

DCIT CC 8(3)(Erstwhile DCIT, CC-46, Mumbai vs. Jsw Steels Ltd, Mumbai

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5327/MUM/2017[2011-12]Status: DisposedITAT Mumbai30 Jun 2023AY 2011-12
Section 14A

appreciating the detailed reasons recorded in the relevant assessment order and the AO analysis of the provision of Explanation (2) and (3) to section 43(6) and the provision of section 72A of the I.T. Act, 1961. 6.4.3. We have heard both the parties, perused the material available on record ... unabsorbed depreciation, i.e depreciation not given effect to, in the assessment of the amalgamating companies. The provisions of Explanation (2) and (3) to section 43(6), which explains what, will be the WDV of assets in the hands of amalgamated company, in the cases of amalgamation. Similarly, section

DCIT CC 8(3)(Erstwhile DCIT, CC-46, Mumbai vs. Jsw Steels Ltd, Mumbai

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5326/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2023AY 2010-11
Section 14A

appreciating the detailed reasons recorded in the relevant assessment order and the AO analysis of the provision of Explanation (2) and (3) to section 43(6) and the provision of section 72A of the I.T. Act, 1961. 6.4.3. We have heard both the parties, perused the material available on record ... unabsorbed depreciation, i.e depreciation not given effect to, in the assessment of the amalgamating companies. The provisions of Explanation (2) and (3) to section 43(6), which explains what, will be the WDV of assets in the hands of amalgamated company, in the cases of amalgamation. Similarly, section

DCIT CC 8(3), Mumbai vs. Jsw Steels Ltd, Mumbai

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 5325/MUM/2017[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 14A

appreciating the detailed reasons recorded in the relevant assessment order and the AO analysis of the provision of Explanation (2) and (3) to section 43(6) and the provision of section 72A of the I.T. Act, 1961. 6.4.3. We have heard both the parties, perused the material available on record ... unabsorbed depreciation, i.e depreciation not given effect to, in the assessment of the amalgamating companies. The provisions of Explanation (2) and (3) to section 43(6), which explains what, will be the WDV of assets in the hands of amalgamated company, in the cases of amalgamation. Similarly, section

DCIT CC 8(3), Mumbai vs. Jsw Steels Ltd, Mumbai

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 4632/MUM/2017[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 14A

appreciating the detailed reasons recorded in the relevant assessment order and the AO analysis of the provision of Explanation (2) and (3) to section 43(6) and the provision of section 72A of the I.T. Act, 1961. 6.4.3. We have heard both the parties, perused the material available on record ... unabsorbed depreciation, i.e depreciation not given effect to, in the assessment of the amalgamating companies. The provisions of Explanation (2) and (3) to section 43(6), which explains what, will be the WDV of assets in the hands of amalgamated company, in the cases of amalgamation. Similarly, section

Jsw Steel Limited, Mumbai vs. ACIT, CC-46, Mumbai

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

ITA 4287/MUM/2017[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 14A

appreciating the detailed reasons recorded in the relevant assessment order and the AO analysis of the provision of Explanation (2) and (3) to section 43(6) and the provision of section 72A of the I.T. Act, 1961. 6.4.3. We have heard both the parties, perused the material available on record ... unabsorbed depreciation, i.e depreciation not given effect to, in the assessment of the amalgamating companies. The provisions of Explanation (2) and (3) to section 43(6), which explains what, will be the WDV of assets in the hands of amalgamated company, in the cases of amalgamation. Similarly, section

Nitrex Chemicals India Ltd., Ahmedabad vs. DCIT, New Delhi

ITA 2860/DEL/2017[2012-13]Status: DisposedITAT Delhi30 Jun 2023AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaacit, Vs. M/S. Nitrex Chemicals India Circle 18(2), Ltd. New Delhi 1213, Ansal Towers, 38-Nehru Place, New Delhi 110019 Pan : Aaacf7820L M/S. Nitrex Chemicals India Vs. Dcit, Ltd. Circle 18(2), 1213, Ansal Towers, New Delhi 38-Nehru Place, New Delhi 110019 Pan : Aaacf7820L (Appellant) (Respondent)

Section 14Section 143(3)Section 14ASection 32Section 37(1)

deemed to be the full value of the consideration received or accruing as a result of the transfer of such capital asset. Next Section 43(6) (c) of the Act which defines the “written down values” provides : “(c) in the case of any block of assets,- (i) in respect ... explosion is required to be bifurcated into assets that got destroyed and those which got damaged. 7.10 According to provision of section 43(6)(c) the assets which were destroyed will be required to be removed from the block of assets and the WDV of the block will get reduced

ACIT, New Delhi vs. M/S. Nitrex Chemicals India Ltd., New Delhi

ITA 2536/DEL/2017[2012-13]Status: DisposedITAT Delhi30 Jun 2023AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaacit, Vs. M/S. Nitrex Chemicals India Circle 18(2), Ltd. New Delhi 1213, Ansal Towers, 38-Nehru Place, New Delhi 110019 Pan : Aaacf7820L M/S. Nitrex Chemicals India Vs. Dcit, Ltd. Circle 18(2), 1213, Ansal Towers, New Delhi 38-Nehru Place, New Delhi 110019 Pan : Aaacf7820L (Appellant) (Respondent)

Section 14Section 143(3)Section 14ASection 32Section 37(1)

deemed to be the full value of the consideration received or accruing as a result of the transfer of such capital asset. Next Section 43(6) (c) of the Act which defines the “written down values” provides : “(c) in the case of any block of assets,- (i) in respect ... explosion is required to be bifurcated into assets that got destroyed and those which got damaged. 7.10 According to provision of section 43(6)(c) the assets which were destroyed will be required to be removed from the block of assets and the WDV of the block will get reduced

Chhattisgarh State Power Generation Co. Ltd., Raipur vs. Dy. Commissioner of Income Tax-1(1), Raipur

In the result, the appeal of the assessee in ITA No

ITA 24/RPR/2022[2018-19]Status: DisposedITAT Raipur15 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.16/Rpr/2017 "नधा"रण वष" / Assessment Year : 2009-10 Chhattisgarh State Power Generation Company Ltd. O/O. Executive Director-Finance Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.24/Rpr/2022 "नधा"रण वष" / Assessment Year : 2018-19 Chhattisgarh State Power Generation Company Ltd. Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 143(2)Section 143(3)Section 32

within the meaning of “Explanation 4” to Section 2(19AA) of the Act so as to invite the provisions of “Explanation 2B” to Section 43(6) of the Act for restricting the deprecation to the WDV of the erstwhile entity? It was observed by the Tribunal that as the assets ... CSEB were transferred to the State Government which in turn had transferred the same to the assessee company, therefore, the “Explanation 2B” to Section 43(6) of the Act which was triggered in a 8 Chhattisgarh State Power Generation Company Ltd. ITA No.24/RPR/2022 situation where there were only two parties

The Chhattisgarh State Power Generation Company Limited, Raipur, Raipur (Cg) vs. The Asstt. Commissioner of Income Tax 1(2), Raipur, Raipur (Cg)

In the result, the appeal of the assessee in ITA No

ITA 16/BIL/2017[2009-10]Status: DisposedITAT Raipur15 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.16/Rpr/2017 "नधा"रण वष" / Assessment Year : 2009-10 Chhattisgarh State Power Generation Company Ltd. O/O. Executive Director-Finance Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.24/Rpr/2022 "नधा"रण वष" / Assessment Year : 2018-19 Chhattisgarh State Power Generation Company Ltd. Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 143(2)Section 143(3)Section 32

within the meaning of “Explanation 4” to Section 2(19AA) of the Act so as to invite the provisions of “Explanation 2B” to Section 43(6) of the Act for restricting the deprecation to the WDV of the erstwhile entity? It was observed by the Tribunal that as the assets ... CSEB were transferred to the State Government which in turn had transferred the same to the assessee company, therefore, the “Explanation 2B” to Section 43(6) of the Act which was triggered in a 8 Chhattisgarh State Power Generation Company Ltd. ITA No.24/RPR/2022 situation where there were only two parties

DCIT 7(3), Mumbai vs. Wyeth Ltd ( Formerly Known As Wyeth Lederle Ltd), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 3508/MUM/2010[2004-05]Status: DisposedITAT Mumbai09 Jun 2023AY 2004-05

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blepfizer Limited V. Acit- Special Range 23 (Earlier Known As Wyeth Lederle Limited) [Now The Dcit-Circle 7(3)] The Capital, G-Block Aayakar Bhavan Bandra Kurla Complex Mumbai- 400020 Bandra (E), Mumbai -400012 Pan: Aaacp3334M (Appellant) (Respondent) Acit- Ltu V. M/S. Wyeth Limited 28Th Floor, Centre - 1 (Formerly Known As Wyeth Lederle Ltd) Rbc Mahindra Towers World Trade Centre 4Th Floor, A- Wing Cuffe Parade, Mumbai Dr G.M. Bhosale Road Worli, Mumbai- 400055 Pan: Aaacw2641Q (Appellant) (Respondent) Assessee Represented By : Shri Vishal Kalra Department Represented By : Smt. Sujatha Iyangar

Section 43(6)Section 80H

depreciation allowable to them. Your appellants submit that on the facts and circumstances of the case and having regard to the provision of Section 43(6) of the Income- tax Act, 1961 (the Act) the CIT(A) should have held that for the purposes of computing depreciation admissible under ... Aggrieved assessee is in appeal before us and Ld. AR of the assessee submitted that assessee ‘case fall under the Explanation 2A to section 43(6) of the Act (as amended vide Finance Act, 2000) as the same is applicable with retrospective effect which provides for reducing the written down

ACIT, New Delhi vs. M/S. the Fertilizer Corporation of India, Noida

In the result, the appeal of the revenue for A

ITA 3357/DEL/2016[2009-10]Status: DisposedITAT Delhi01 Jun 2023AY 2009-10

Bench: Shri C.M. Garg & Shri M. Balaganesh

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms Sarita Kumari, CIT, DR
Section 143Section 143(3)

5468/Del/2015 ITAs No.3354, 2719, 2798, 3355, 3356, 3357 & 2884/Del/2016 27. Along with the aforesaid amendment, definition of written down value as contained in section 43(6) has also been amended and the amended provisions read as under : "43(6) "Written down value" means :— (a) & (b) ** ** ** (c) In the case

ACIT, New Delhi vs. M/S. the Fertilizer Corporation of India, Noida

In the result, the appeal of the revenue for A

ITA 3356/DEL/2016[2008-09]Status: DisposedITAT Delhi01 Jun 2023AY 2008-09

Bench: Shri C.M. Garg & Shri M. Balaganesh

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms Sarita Kumari, CIT, DR
Section 143Section 143(3)

5468/Del/2015 ITAs No.3354, 2719, 2798, 3355, 3356, 3357 & 2884/Del/2016 27. Along with the aforesaid amendment, definition of written down value as contained in section 43(6) has also been amended and the amended provisions read as under : "43(6) "Written down value" means :— (a) & (b) ** ** ** (c) In the case

ACIT, New Delhi vs. M/S. the Fertilizer Corporation of India, Noida

In the result, the appeal of the revenue for A

ITA 3355/DEL/2016[2007-08]Status: DisposedITAT Delhi01 Jun 2023AY 2007-08

Bench: Shri C.M. Garg & Shri M. Balaganesh

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms Sarita Kumari, CIT, DR
Section 143Section 143(3)

5468/Del/2015 ITAs No.3354, 2719, 2798, 3355, 3356, 3357 & 2884/Del/2016 27. Along with the aforesaid amendment, definition of written down value as contained in section 43(6) has also been amended and the amended provisions read as under : "43(6) "Written down value" means :— (a) & (b) ** ** ** (c) In the case

DCIT, New Delhi vs. M/S. the Fertilizer Corporation of India Ltd, Noida

In the result, the appeal of the revenue for A

ITA 5468/DEL/2015[2004-05]Status: DisposedITAT Delhi01 Jun 2023AY 2004-05

Bench: Shri C.M. Garg & Shri M. Balaganesh

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms Sarita Kumari, CIT, DR
Section 143Section 143(3)

5468/Del/2015 ITAs No.3354, 2719, 2798, 3355, 3356, 3357 & 2884/Del/2016 27. Along with the aforesaid amendment, definition of written down value as contained in section 43(6) has also been amended and the amended provisions read as under : "43(6) "Written down value" means :— (a) & (b) ** ** ** (c) In the case

DCIT, New Delhi vs. M/S. the Fertilizer Corporation of India Ltd, Noida

In the result, the appeal of the revenue for A

ITA 5467/DEL/2015[2003-04]Status: DisposedITAT Delhi01 Jun 2023AY 2003-04

Bench: Shri C.M. Garg & Shri M. Balaganesh

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms Sarita Kumari, CIT, DR
Section 143Section 143(3)

5468/Del/2015 ITAs No.3354, 2719, 2798, 3355, 3356, 3357 & 2884/Del/2016 27. Along with the aforesaid amendment, definition of written down value as contained in section 43(6) has also been amended and the amended provisions read as under : "43(6) "Written down value" means :— (a) & (b) ** ** ** (c) In the case

Dy. Commissioner of Income Tax Circle 13(2)(2), Mumbai vs. Sodexo Facilities Management Services India Pvt Ltd, Mumbai

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

ITA 2945/MUM/2022[2012-13]Status: DisposedITAT Mumbai25 May 2023AY 2012-13

Bench: Shri Om Prakash Kant & Ms.Kavitha Rajagopaldcit, Sodexo Facilities Circle-13(2)(2), Management Services बनाम/ Mumbai. India Pvt.Ltd., 1St Floor, Vs. Gemstar Commercial Complex, Ramchandra Lane, Extension Kanchpada, Malad West, Mumbai-400064. "थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aabcs4166M (अपीलाथ"/Appellant) (""थ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri A.N.Bhalekar, Sr.Ar ""थ" की ओर से/Respondent By: Shri Mrunal Parekh सुनवाई की तारीख/ Date Of Hearing 16/05/2023 घोषणा की तारीख /Date Of Pronouncement 25/05/2023 आदेश / Order Per Om Prakash Kant- Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 20.09.2022 Passed By Ld Commissioner Of Income-Tax (Appeals)-National Faceless Appeal Centre, Delhi [“In Short The Ld. Cit(A)”]For Assessment Year (“Ay”) 2012-13, Raised Following Grounds: -

For Appellant: Shri A.N.Bhalekar, Sr.ARFor Respondent: Shri Mrunal Parekh
Section 139(1)Section 143(3)Section 147Section 148Section 151(1)Section 43(6)(c)Section 50B(3)

Amount Net worth of the business being 75,51,873 transferred: Written Down value of Depreciable Assets of the said business determined under section 43(6)(c)(i)(c) Book value of other Assets 14,28,79,591 15.04,31,464 Less: Liabilities of the said business

Palco Tex Fab Limited, Delhi vs. ACIT, Circle 19(2)

In the result, the appeal of the assessee is allowed

ITA 992/DEL/2021[2015-16]Status: DisposedITAT Delhi10 May 2023AY 2015-16
For Appellant: Shri Deepak Bansal, CAFor Respondent: Shri Raghunath, Sr. DR
Section 143(3)Section 32Section 43(6)Section 50

machinery for Rs.1,05,00,000/- and accordingly showcaused as to why the said transaction be not treated as transfer in terms of section 43(6) of the Act treating it as assets discarded and accordingly calculate depreciation u/s 32 of the Act, business loss and short-term capital gain/short-term ... loss in audited final accounts; (e) The asset is no more being used in business by the assessee; (f) The provisions of section 43(6) of the Act uses the word ‘discarded.’ 5. Accordingly, the ld. AO concluded that the discarded price of plant & machinery was Rs.1

Indorama Industries Ltd., Chandigarh vs. ACIT, Circle- 12(1), New Delhi

In the result, the appeal is allowed

ITA 6926/DEL/2019[2016-17]Status: DisposedITAT Delhi10 May 2023AY 2016-17

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2016-17

Section 143(3)Section 32Section 43(6)(c)

electricity connection and service tax registration etc. 8. Without prejudice, learned counsel submitted, as per the definition of block of assets under Section 43(6)(c) of the Act, there is no condition of put to use once the asset falls within a particular block. The only condition ... Assessing Officer has allowed assessee’s claim of depreciation on the capitalized plant and machinery of the pilot project. On a reading of section 43(6)(c) of the Act, we find that as per the definition of block of assets therein, there is no condition that the plant

Sunbeam Auto Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 235/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Apr 2023AY 2013-14

Bench: Shri G.S. Pannu, Hon’Dble & Ms. Astha Chandraassessment Year: 2011-12 Sunbeam Auto Ltd. Vs. Addl. Cit, S-323, Panchsheel Park, Range-9, New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent) Assessment Year: 2011-12 Addl. Cit Vs. Sunbeam Auto Ltd. Special Range-8, S-323, Panchsheel Park, Room No. 199A, New Delhi 110 017 C.R. Building, Pan Aabcs2948F New Delhi. (Appellant) (Respondent) Assessment Year: 2013-14 Sunbeam Auto Ltd. Vs. Dcit, S-323, Panchsheel Park, Circle-24(2) New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent)

For Appellant: Ms. Shashi M Kapila, AdvocateFor Respondent: Shri Umesh Takyar, Sr. DR
Section 143(1)Section 143(3)Section 14ASection 264Section 37(1)Section 40Section 43(1)

assessee’s application, holding that the subsidy was revenue receipt. Alternatively, the Ld. Pr. CIT also held that the Explanation 10 to section 43(6) was applicable. 5.2 The Ld. AR further submitted that the assessee filed writ petition before the Hon’ble Delhi High Court

Addl. CIT, New Delhi vs. M/S. Sunbeam Auto Pvt. Ltd., New Delhi

In the result, the appeal of the assessee in ITA No

ITA 5127/DEL/2016[2011-12]Status: DisposedITAT Delhi06 Apr 2023AY 2011-12

Bench: Shri G.S. Pannu, Hon’Dble & Ms. Astha Chandraassessment Year: 2011-12 Sunbeam Auto Ltd. Vs. Addl. Cit, S-323, Panchsheel Park, Range-9, New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent) Assessment Year: 2011-12 Addl. Cit Vs. Sunbeam Auto Ltd. Special Range-8, S-323, Panchsheel Park, Room No. 199A, New Delhi 110 017 C.R. Building, Pan Aabcs2948F New Delhi. (Appellant) (Respondent) Assessment Year: 2013-14 Sunbeam Auto Ltd. Vs. Dcit, S-323, Panchsheel Park, Circle-24(2) New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent)

For Appellant: Ms. Shashi M Kapila, AdvocateFor Respondent: Shri Umesh Takyar, Sr. DR
Section 143(1)Section 143(3)Section 14ASection 264Section 37(1)Section 40Section 43(1)

assessee’s application, holding that the subsidy was revenue receipt. Alternatively, the Ld. Pr. CIT also held that the Explanation 10 to section 43(6) was applicable. 5.2 The Ld. AR further submitted that the assessee filed writ petition before the Hon’ble Delhi High Court