“unabsorbed depreciation”

DepreciationSection 32(2)Section 32(2)810 judgments

The decision most relied on for unabsorbed depreciation is Velayudhaswamy Spinning Mills (P) Ltd. v. ACIT (340 ITR 477), cited in 213 judgments on BharatTax.

Leading authorities on unabsorbed depreciation

Velayudhaswamy Spinning Mills (P) Ltd. v. ACIT

340 ITR 477 · 2012 · High Court

213

citing judgments

If unabsorbed depreciation or losses from years prior to the initial assessment year for Section 80-IA claim have already been set off against other income, they cannot be notionally carried forward again to reduce the profits of the eligible unit for computing deduction under Section 80-IA. The notional carry forward provision under Section 80-IA(5) applies only to unabsorbed depreciation or losses that have not yet been absorbed.

General Motors India (P) Ltd. v. DCIT

354 ITR 244 · 2013 · High Court

141

citing judgments

Unabsorbed depreciation from Assessment Year 1997-98 to 2001-02, carried forward to AY 2002-03, is governed by Section 32(2) as amended by the Finance Act, 2001, allowing its unlimited carry forward and set off against income of subsequent years. Reassessment proceedings under Section 148 challenging such set-off require valid reasons and new tangible material.

CIT v. Rittal India (P) Limited

380 ITR 423 · 2016 · High Court

121

citing judgments

Additional depreciation is allowable under section 32(1)(iia) for new machinery or plant even when put to use for less than 180 days, with the unabsorbed balance available for claim in the subsequent year.

CIT v. Himatasingike Seide Ltd.

286 ITR 255 · 2006 · High Court

citing judgments

Deduction under Section 10A of the Income-tax Act is to be allowed only after setting off unabsorbed depreciation and brought forward business losses against the profits of the business.

CIT v. Black & Veatch Consulting Pvt. Ltd.

348 ITR 72 · 2012 · High Court

citing judgments

Depreciation, including unabsorbed depreciation, should not be reduced from the profits of an undertaking eligible for deduction under Section 10A of the Income-tax Act, 1961, when computing the deduction amount.

Dy. CIT v. Binani Industries Ltd.

178 TTJ 658 · 2016 · ITAT

citing judgments

The lower of unabsorbed depreciation or business loss is deductible from book profits under Clause (iii) of Explanation 1 to Section 115JB. Capital receipts, such as forfeiture of share warrants, which do not have the character of income, are not liable for book profits tax under Section 115JB.

S.M.I.L.E. Microfinance Limited v. ACIT (VACIT

2024 SCC OnLine MAD 8416 · 2024 · Reported

citing judgments

The higher tax rate under Section 115BBE, increased to 60% effective from April 1, 2017, is not applicable to transactions that occurred prior to this date.

62. Further, in CIT v. Silical Metallurgic Ltd.

324 ITR 29 · 2010 · High Court

citing judgments

In a scenario involving amalgamation, the accumulated losses and unabsorbed depreciation of an undertaking can be carried forward by the amalgamating company if it continues the business of the undertaking.

Judgments citing unabsorbed depreciation

DCIT-2(3), Mumbai vs. M/S. Zensar Technologies Ltd., Mumbai

In the result, the appeal is partly allowed

ITA 5653/MUM/2009[2004-05]Status: DisposedITAT Mumbai19 Apr 2023AY 2004-05

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 10ASection 80Section 92

amount of income of that 17 ITA 5653/Mum/2009 M/s Zensar Technologies Ltd nature qualifying for computing deduction u/s 80HHE. Further, the set off of unabsorbed depreciation of Rs.26,27,443/- is also disallowed in view of the fact that the entire unabsorbed depreciation has been already

Sage International Inc., Usa vs. ACIT, Circle Int. Taxation 3(1)(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 2214/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Apr 2023AY 2018-19

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2018-19] Sage International Inc., Vs Acit, 105, Townline Road, 2 Pmb 332, Circle 3(1)(2), Vernon Hills, Foreign United International States, Usa. Taxation, Delhi. Pan-Aaycs9212R Appellant Respondent Appellant By Shri Pradeep Dinodia, Ca Respondent By Shri Bhuvnesh Kulshrestha, Cit Dr Date Of Hearing 28.02.2023 Date Of Pronouncement 10.04.2023 Order Per Kul Bharat: The Present Appeal Filed By The Assessee Is Directed Against The Order Of Assessing Officer Passed U/S 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (“The Act”) Dated 15.07.2022 For The Assessment Year (“Ay”) 2018-19 .

Section 143(3)Section 234ASection 4Section 90

previous year, then, notwithstanding any thing contained in the Act, the provisions of the Act relating to the computation of total income, treatment of unabsorbed depreciation, set off or carry forward and set off of losses, collection and recovery and special provisions relating to avoidance of tax shall apply

Oriental Bank of Commerce, Gurgaon vs. ACIT, Spl. Range-07, New Delhi

In the result, the appeal filed by the Assessee stands allowed

ITA 740/DEL/2020[2016-17]Status: DisposedITAT Delhi31 Mar 2023AY 2016-17

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhryassessment Year: 2016-17

For Appellant: Sh. KVSR Krishna, Ld. CA &For Respondent: Ms. Sarita Kumar, Ld. CIT/DR

Section 115JSection 14ASection 250Section 36

amount of depreciation on account of revaluation of assets referred to in clause (iia); or] (iii) the amount of loss brought forward or unabsorbed depreciation, whichever is less as per books of account. Explanation.—For the purposes of this clause,— (a) the loss shall not include depreciation; (b) the provisions ... this clause shall not apply if the amount of loss brought forward or unabsorbed depreciation is nil; or] (iv) to (vi) [****] (vii) the amount of profits of sick industrial company for the assessment year commencing on and from the assessment year relevant to the previous year in which the said

Abhimanyu Sahu, Buxipalli vs. PCIT-1, Bhubaneswar

In the result, appeal filed by the assessee is allowed

ITA 30/CTK/2022[2016-17]Status: HeardITAT Cuttack24 Mar 2023AY 2016-17

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2016-17 Abhimanyu Sahu, Buxipalli, Abhimanyu Sahu, Buxipalli, Vs. Pr. Cit-1, Gopalpur On Sea. Gopalpur On Sea. Bhubaneswar Bhubaneswar Pan/Gir No. Pan/Gir No.Aokps 4011 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.N.Dave, Ca P.N.Dave, Ca Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 24 /0 03/2023 Date Of Pronouncement : 24 /0 /03/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee This Is An Appeal Filed By The Assessee Against The Order Against The Order Passed U/S 263 Of The Act 263 Of The Act Of The Ld Pr. Cit, Bhubaneswar-1 Dated Dated 10.3.2021 In Appeal No. Itba/Rev/ V/F/Rev5/2020-21/1031385941(1) For The Assessment Year For The Assessment Year 2016-17. 2. Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue. M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue. M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue.

For Appellant: Shri P.N.Dave, CAFor Respondent: Shri M.K.Gautam, Pr. CIT (OSD)

Section 143(3)Section 263

tune of Rs.16,91,91,234/- which were not enquired by the AO. 32. We also observe that the issue of brought forward unabsorbed depreciation of Rs.1,34,85,465/- and MAT credit of Rs.26,33,135/- was not under Limited Scrutiny, hence, the AO has not enquired into

Mithila Drugs Pvt. Ltd., Udaipur vs. ACIT, Circle-1, Udaipur

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

ITA 566/JODH/2018[2015-16]Status: DisposedITAT Jodhpur23 Mar 2023AY 2015-16

Bench: Shri Kul Bharatshri Manish Boradmithila Drugs Pvt.Ltd., Vs Acit, F-70, Road No.2, Circle-1, 102A, Mewar Industrial Area, Aaykar Bhawan, Sub Madri, Udaipur-313003. City Centre, Savina, Udaipur-313001. (Appellant) (Respondent) Pan No.Aaccm6767B Assessee By None (W/S) Revenue By Shri S.M.Joshi, Jcit Dr Date Of Hearing 22/03/2023 Date Of 23/03/2023 Pronouncement

Section 119(2)(b)Section 139(1)Section 143(3)Section 80

Income Tax Act, 1961 (“the Act”) vide order dated 16.11.2017 assessed the income of the assessee at INR NIL and no business loss or unabsorbed depreciation was determined for carry forward. 2 | P a g e 5. Aggrieved against this, the assessee preferred appeal before Ld.CIT(A) who after considering

Pvr Pictures Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3843/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

For Appellant: Shri V.K. Garg, Adv. & Shri ParveenFor Respondent: Ms. Beenu, Sr.DR

Section 115JSection 143(3)

Explanation-1 to Section 115JB(2) of the Act. 4. In the first appeal, the assessee reiterated adjustment of carried forward business loss or unabsorbed depreciation whichever is lower, against ‘Book Profit’ for the purposes of Section 115JB of the Act. The CIT(A) observed that the assessee ... ground that u/s 115JB under Explanation 1 to clause (iii), the Book Profit can be reduced by the amount of loss brought forward or unabsorbed depreciation whichever is less as per books of accounts. Based on the above said working, the appellant has contended that the amount of loss brought

Deputy Commisioner of Income Tax, Rajahmahendravaram vs. Andhra Paper Limited, Rajahmahendravaram

In the result, appeal of the Revenue is partly allowed for statistical

ITA 189/VIZ/2022[2013-14]Status: DisposedITAT Visakhapatnam28 Feb 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. Nos. 162/Viz/2022 & 189/Viz/2022 ("नधा"रणवष"/ Assessment Years : 2012-13 & 2013-14) Deputy Commissioner Of Income Vs. M/S. Andhra Paper Limited Tax, Circle-1, (M/S. International Paper Rajamahendravaram. Appm Ltd), Sri Ram Nagar, Rajamahendravaram. Pan: Aact 8849 D (अपीलाथ"/ Appellant) (""यथ"/ Respondent) Co Nos: 22 & 23/Viz/2022 (In आयकरअपीलसं./ I.T.A. Nos. 162/Viz/2022 & 189/Viz/2022) ("नधा"रणवष"/ Assessment Years : 2012-13 & 2013-14) M/S. Andhra Paper Limited Vs. Deputy Commissioner Of (M/S. International Paper Appm Income Tax, Circle-1, Ltd), Rajamahendravaram. Sri Ram Nagar, Rajamahendravaram. Pan: Aact 8849 D (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri K. Chakrapani ""याथ"क"ओरसे/ Revenue By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri K. ChakrapaniFor Respondent: Sri MN Murthy Naik, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 14ASection 35D

assessee, the Ld. AO made following disallowances: (i) Depreciation on Goodwill - Rs. 27,22,713/- (ii) Expenditure U/s. 35D - Rs. 5,14,730/- (iii) Unabsorbed depreciation - Rs. 48,78,000/- (iv) Disallowance of Miscellaneous Expenses - Rs. 36,47,979/- (v) Disallowance of sundry creditors - Rs. 30,35,000/- (vi) Disallowance

Deputy Commissioner of Income Tax, Circle-1, Rajamahendravaram vs. Andhra Paper Limited, Rajamahendravaram

In the result, appeal of the Revenue is partly allowed for statistical

ITA 162/VIZ/2022[2012-13]Status: DisposedITAT Visakhapatnam28 Feb 2023AY 2012-13

For Appellant: Sri K. ChakrapaniFor Respondent: Sri MN Murthy Naik, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 14ASection 35D

The ITO, Ward-1 (2) (2), Rajkot-Gujarat vs. M/S Srv Metals Private Limited, Rajkot-Gujarat

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

ITA 428/RJT/2015[2009-10]Status: DisposedITAT Rajkot15 Feb 2023AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri B.D. Gupta, Sr. DR

Section 10BSection 142(1)Section 143(3)Section 40Section 43BSection 68

interfere with the same. Ground no.9 is thus dismissed. 16. As regards to ground no.10 relating to set of of brought forward loss/ unabsorbed depreciation allowance, the same needs to be verified as the CIT(A) has not considered the comments of the remand report and, therefore, ground no.10 relating

ACIT Circle 25-(1), Delhi vs. Value First Digital Media Pvt. Ltd., Gurgaon Haryana

In the result, ITA No. 3143/Del/2019 [A

ITA 2050/DEL/2021[2014-15]Status: PendingITAT Delhi08 Feb 2023AY 2014-15

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

facts and in the circumstances of the case, the Ld. CIT(A) erred in allowing set-off of brought forward business losses and unabsorbed depreciation pertaining to the demerged undertaking (M/s Gingersoft Media pvt. Ltd.) for the period 01.04.2011 to 29.02.2012 amounting to Rs. 4,76,08,087/-, in allowing ... claim of set-off of Rs. 18,50,582/- pertaining to the brought forward unabsorbed depreciation of the demerged undertaking M/s Gingersoft Media Pvt. Ltd. for the period prior to 01.04.2011 and in allowing claim of carry forward of business losses of Rs. 8,32,95,763/- pertaining to brought

ACIT, Circle-26(1), New Delhi vs. Value First Digital Media Pvt. Ltd., New Delhi

In the result, ITA No. 3143/Del/2019 [A

ITA 5127/DEL/2019[2016-17]Status: DisposedITAT Delhi08 Feb 2023AY 2016-17

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

ACIT, Circle-26(1), New Delhi vs. Value First Digital Media Pvt. Ltd., New Delhi

In the result, ITA No. 3143/Del/2019 [A

ITA 3143/DEL/2019[2012-13]Status: DisposedITAT Delhi08 Feb 2023AY 2012-13

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

Kendrapara Urban Co-Operative Bank Ltd., Kendrapada vs. Pr.Commissioner of Income Tax, Cuttack

In the result, appeal of the assessee stands allowed

ITA 163/CTK/2020[2015-16]Status: HeardITAT Cuttack30 Jan 2023AY 2015-16

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.163/Ctk/2020 (ननधाारण वषा / Assessment Year :2015-2016) Kendrapara Urban Co-Operative Vs Pr.Cit, Cuttack Bank Ltd., College Square, Tinimuhani, Kendrapara-754211 Pan No. :Aaatk 8347 E (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri P.C.Sethi, Advocate राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 30/01/2023 घोषणा की तारीख/Date Of Pronouncement : 30/01/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit, Cuttack, Dated 24.03.2020, Passed In Din & Order No.Itba/Com/F/17/2019-20/1026884702(1) For The Assessment Year 2015-2016. 2. The Appeal Of The Assessee Is Barred By 8 Days. The Assessee Through Its Secretary Has Filed An Application Dated 13.07.2020 Stating Therein Sufficient Reasons For Condonation Of Delay, To Which Ld. Cit-Dr Did Not Object. In View Of The Above, Delay Of 8 Days In Filing The Present Appeal Is Condoned & The Appeal Of The Assessee Is Heard Finally. 3. It Was Submitted By The Ld. Ar That The Original Assessment In The Case Of The Assessee Was Completed U/S.143(3) Of The Act On 20.11.2017. It Was The Submission That The Assessment Was A Limited Scrutiny

For Appellant: Shri P.C.Sethi, AdvocateFor Respondent: Shri M.K.Gautam, CIT-DR

Section 143(3)Section 14ASection 263Section 36(1)(viia)Section 40

tune of Rs.16,91,91,234/- which were not enquired by the AO. 32. We also observe that the issue of brought forward unabsorbed depreciation of Rs.l,34,85,465/- and MAT credit of Rs.26,33,135/- was not under Limited Scrutiny, hence, the AO has not enquired into

Haier Appliances India P.Ltd, New Delhi vs. ACIT, Circle-11(1), New Delhi

ITA 1458/DEL/2022[2015-16]Status: DisposedITAT Delhi24 Jan 2023AY 2015-16

Section 115JSection 143(3)Section 250Section 37(1)

That the CIT(A) erred on facts and in law in upholding the action of the assessing officer by not allowing set off of unabsorbed depreciation of Rs.9,90,89,986/- against the income earned during the year under consideration, allegedly holding that the appellant has already availed ... unabsorbed depreciation in the preceding years. 5.1 That the CIT(A) erred on facts and in law in passing ex-parte order for the year under consideration without disposing the appeal for preceding assessment years 2013-14 and 2014-15, not appreciating that decision in appeal for earlier years have

M/S.Roads and Bridges Development Corpn of Kerala Ltd, Ernakulam vs. The ACIT, Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 33/COCH/2021[2016-17]Status: DisposedITAT Cochin20 Jan 2023AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2016-17

For Appellant: Ms. Remya S Menon, CAFor Respondent: Smt. J M Jamuna Devi, Sr DR

Section 139(1)Section 139(3)Section 143(3)Section 263Section 32(2)Section 72(1)

Learned AO has made all necessary inquiries and has verified the same and correctly allowed the loss under the head 'Unabsorbed Depreciation' as can be seen from Para 5 of the assessment order issued u/s 143(3) of the Income Tax Act, 1961. Thus, the order of the learned ... that the losses carried forward in its return by the company are not in the nature of business losses but in the nature of unabsorbed depreciation. Only business loss u/s 72(1) is ineligible to be carried forward u/s 139(3). The said section is not applicable in case

Satya Narayan Dhoot, Jodhpur vs. Pr. CIT-1, Jodhpur

In the result, the appeal of the assessee is allowed in respect of above said three issues

ITA 49/JODH/2022[2017-18]Status: DisposedITAT Jodhpur17 Jan 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Gosain (Jm) I.T.A. No. 49/Jodh/2022 (A.Y. 2017-18) Vs. Pcit-1 Satya Narayan Dhoot C/O Rajendra Jain Advocate Jodhpur 106, Akshay Deep Complex 5Th B Road, Sardarpura Jodhpur, Rajasthan-342 001. Pan : Aanpd4945L (Appellant) (Respondent) Assessee By Shri Rajendra Jain Department By Smt. Alka Rajvanshi Jain Date Of Hearing 03.11.2022 Date Of Pronouncement 17 .01.2023 O R D E R Per B.R.Baskaran (Am) :-

Section 10(38)Section 143(3)Section 14ASection 263Section 80I

properly examined the following issues:- (a) AO has allowed deduction u/s 80IA of the Act without setting off brought forward unabsorbed depreciation of wind mill as required u/s 80IA(5) of the Act. (b) AO has allowed brought forward losses without proper details of unabsorbed loss brought forward from ... Satya Narayan Dhoot (c) AO has allowed set off of unabsorbed depreciation of Rs.71,31,099/- pertaining to M-77 unit, which was not eligible for set off, since this unit commenced operation from current year, i.e., AY 2017-18 only. (d) The AO has allowed benefit of exemption

Jitf Urban Infrastructure Services Ltd, New Delhi vs. ACIT, Circle-13(2), New Delhi

ITA 6632/DEL/2018[2015-16]Status: DisposedITAT Delhi16 Jan 2023AY 2015-16

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No.6632/Del/2018, A.Y. 2015-16 M/S. Jitf Urban Infrastructure Vs. Asst. Commissioner Of Income Services Limited Tax 28, Shivaji Marg, West Delhi, Circle 13(2), Central Revenue P.O: Ramesh Nagar Building Room No. 316A 3Rd Floor, New Delhi- 110015 Pan : Aaccj4785G I.P.Estate, New Delhi-110002

Section 143(2)Section 143(3)Section 14ASection 2

thereto. Further, upon the Scheme coming into effect on the Effective Date and with effect from the Appointed Date I, all business losses and unabsorbed depreciation of the Demerged Company- relating to the Demerged Undertaking ] shall be treated as business loss and unabsorbed depreciation of the Resulting Company ] and shall ... claim arising out of operations of the assessee company but only consequential to the Hon’ble company court judgement. So the business losses and unabsorbed depreciation of the demerged company became statutory claim in the hands of assessee company. Thus Ld. AO could have taken note of the same even

DCIT, Circle-13(2), New Delhi vs. Jitf Urban Infrastructure Services Ltd, New Delhi

ITA 6423/DEL/2018[2015-16]Status: DisposedITAT Delhi16 Jan 2023AY 2015-16

Section 143(2)Section 143(3)Section 14ASection 2

M/S. Cellcast Interactive India Pvt. Ltd., Delhi vs. DCIT, New Delhi

In the result, this appeal filed by the assessee stands allowed for statistical purposes only

ITA 3492/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Jan 2023AY 2013-14

Bench: Shri Shamim Yahya & Ms Astha Chandra

For Appellant: NoneFor Respondent: Shri Gurpreet Shah Singh, Sr. DR

Section 143(3)Section 271Section 271(1)(c)Section 274

case are that the assessee filed its return of income on 26.09.2013 with total brought forward losses of Rs. 54,87,16,226/- including unabsorbed depreciation. Later, the assessee revised its return of income on 20.02.2015 declaring income of Rs. 4,77,12,227/- with brought forward losses of Rs.38 ... unabsorbed depreciation of Rs.3,23.47,939/-. Assessment in the case of the assessee was completed u/s 143(3) of the Act on 30.10.2015 determining loss at Rs. 38,97,06,040/- and brought forward loss was restricted to Rs.4,98,41,995/- and unabsorbed depreciation to be carried forward Rs.3

Addi. CIT Special Range - 6, New Delhi vs. National Fertilizers Ltd., Noida

In the result appeal of the Revenue is dismissed

ITA 7966/DEL/2019[2016-17]Status: DisposedITAT Delhi06 Jan 2023AY 2016-17

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhary

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR

Section 115JSection 143(3)Section 145Section 36(1)Section 37(1)

filed its return of income for A.Y. 2016-17 on 05.10.2016, declaring taxable income at Rs. NIL after adjustment of brought forward losses and unabsorbed depreciation. Assessee also declared income of Rs. 2,84,42, 61,344/- u/s. 115JB of the Act. The case of the assessee was selected