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“section 80IC”

DeductionsSection 80ICSection 80IC591 judgments

The decision most relied on for section 80IC is ACB India Ltd. v. ACIT (374 ITR 108), cited in 364 judgments on BharatTax.

Leading authorities on section 80IC

ACB India Ltd. v. ACIT
374 ITR 108 · 2015 · High Court
364
citing judgments

When computing disallowance under Section 14A of the Income-tax Act using Rule 8D of the Income-tax Rules, only investments that have actually yielded exempt income during the relevant previous year are to be considered for the calculation.

Pandian Chemicals Ltd. v. CIT
262 ITR 278 · 2003 · Supreme Court
353
citing judgments

Income eligible for deduction under Section 80IA or 80IC must have a direct nexus with the eligible business activity of the industrial undertaking. Income merely incidental to the business, even if part of the assessee's overall business, is not considered "derived from" the eligible undertaking.

CIT v. Sterling Foods
237 ITR 579 · 1999 · Supreme Court
311
citing judgments

Income eligible for profit-linked deductions under sections like 80-IC or 10B must have a direct nexus to the eligible business activity or be derived from the industrial undertaking itself, and not merely attributable to it or arising from a post-manufacturing event.

TM) Vishnu Jaiswal v. CIT
357 ITR 146 · 2013 · High Court
272
citing judgments

If the Assessing Officer has not conducted any investigation and thus has not discharged their burden of proof, any addition made by the AO is unsustainable and must be deleted.

CIT v. Ashwani Gupta
322 ITR 396 · 2010 · High Court
262
citing judgments

Proceedings become fatal if principles of natural justice are violated, such as when seized material is not provided to the assessee or cross-examination of a person whose statement the Assessing Officer relies upon is denied.

CIT v. Meghalaya Steels Ltd.
383 ITR 217 · 2016 · Supreme Court
203
citing judgments

Subsidies and excise duty refunds that are accounted for in the Profit and Loss account are revenue in nature, form part of business income, and are eligible for deductions under Section 80IB/80IC. Such receipts cannot be reduced from the block of assets for depreciation calculation.

Textile Machinery Corporation Ltd. v. CIT
107 ITR 195 · 1977 · Supreme Court
165
citing judgments

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.

CIT v. Contimeters Electricals (P.) Ltd.
317 ITR 249 · 2009 · High Court
140
citing judgments

The requirement to file an audit report along with the return of income under section 80-IA(7) and similar provisions is directory, not mandatory. Such a report suffices if filed at any time before the assessment is framed.

Judgments citing section 80IC

DCIT, CC-7(2), Mumbai vs. Time Technoplast, Mumbai

Appeal of the Revenue is dismissed

ITA 6857/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Feb 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh Joshi,ARFor Respondent: Shri Ritesh Misra, (CIT DR)
Section 115JSection 133ASection 143(3)Section 69CSection 801CSection 80ISection 8o

IN THE INCOME-TAX APPELLATE TRIBUNAL“E” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER

Ganpati Industries, Roorkee vs. ITO, Roorkee

Appeal is allowed

ITA 199/DDN/2025[2016-17]Status: DisposedITAT Dehradun15 Jan 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing) Assessment Year: 2016-17 M/S. Ganpati Industries, Vs. Income Tax Officer, Plot No. 28, Shiv Ganga Indl. Ward-1(3)(4), Estate, Lakeshwari Roorkee Bhagwanpur, Roorkee, Haridwar, Uttarakhand Pan :Aamfg0380K (Appellant) (Respondent) Assessee By Sh. Sheeta Ram Agarwal, Adv. Department By Sh. Amar Pal Singh, Jcit

Section 139(1)Section 154Section 80ASection 80I

perused. 2. Coming to the sole substantive issue between the parties herein, we note that the learned lower authorities have rejected the assessee’s section 80IC deduction claim of Rs.5,24,460/- in their respective findings for the sole reason that it had failed to file/upload its return under section ... want of a valid return under section 139(1) of the Act. 3. The Revenue’s vehement contention in support of the impugned section 80IC deduction fail to evoke our concurrence. This is for the precise reason that we are in assessment year 2016- 17 whereas the legislature has amended

Frontline Electronics Limited, Pune vs. DCIT Central Circle 8, Pune

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

ITA 2064/PUN/2025[2011-12]Status: HeardITAT Pune07 Jan 2026AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2011-12 Frontline Electronics Ltd. Dcit, Circle – 8, Pune Plot No.E-7 B/2, Chakan Industrial Vs. Area, Phase Iii, Nighoje, Khed, Pune – 410501 Pan: Aaacf2689P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Basavaraj Hiremath, Addl.Cit Date Of Hearing : 05-01-2026 Date Of Pronouncement : 07-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Basavaraj Hiremath, Addl.CIT
Section 271(1)(c)Section 80Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals Colour Cosmetics, Delhi

In the result, ITA No.611/Del/2023 is dismissed

ITA 611/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member

Section 143(3)Section 801CSection 80I

No.611 & 1244/Del/2023 2. Both the appeals of the Revenue are on identical grounds of deletion of disallowance of assessee’s claim of deduction under section 80IC by the ld. Frist Appellate Authority which was made by the ld. Assessing Officer. Since, the facts of both the appeals are identical

DCIT Central Circle-20, New Delhi vs. Lotus Herbals Colour Cosmetics, New Delhi

In the result, ITA No.611/Del/2023 is dismissed

ITA 1244/DEL/2023[2019-20]Status: DisposedITAT Delhi07 Jan 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member

Section 143(3)Section 801CSection 80I

No.611 & 1244/Del/2023 2. Both the appeals of the Revenue are on identical grounds of deletion of disallowance of assessee’s claim of deduction under section 80IC by the ld. Frist Appellate Authority which was made by the ld. Assessing Officer. Since, the facts of both the appeals are identical

Aarti Singal Foundation, New Delhi vs. Centralized Processing Center, Bengaluru

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

ITA 89/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Dec 2025AY 2021-22

Bench: Shri M. Balaganesh & Shri Vimal Kumarassessment Year : 2021-22 Aarti Singal Foundation, Vs. Cpc, 4, Amrita Shergil Marg, Bengaluru Delhi – 110 003. Pan: Aacta1263F

For Appellant: Shri Ashwani Kumar, CA &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 11(1)Section 143(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : A : NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

apportion the AMP expenses in the hands of its two sisterly concerns because these were enjoying tax holidays under the provisions of section 80IC(7) r.w.s. 801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that ... apportioned and borne by the two manufacturing entities, that too, simply on the ground that the said two entities were claiming tax holiday under section 80IC of the Act and the AO, on conjectures surmises, concluded that AMP expenses have not been apportioned to show higher profits in the said

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

apportion the AMP expenses in the hands of its two sisterly concerns because these were enjoying tax holidays under the provisions of section 80IC(7) r.w.s. 801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that ... apportioned and borne by the two manufacturing entities, that too, simply on the ground that the said two entities were claiming tax holiday under section 80IC of the Act and the AO, on conjectures surmises, concluded that AMP expenses have not been apportioned to show higher profits in the said

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

apportion the AMP expenses in the hands of its two sisterly concerns because these were enjoying tax holidays under the provisions of section 80IC(7) r.w.s. 801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that ... apportioned and borne by the two manufacturing entities, that too, simply on the ground that the said two entities were claiming tax holiday under section 80IC of the Act and the AO, on conjectures surmises, concluded that AMP expenses have not been apportioned to show higher profits in the said

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

apportion the AMP expenses in the hands of its two sisterly concerns because these were enjoying tax holidays under the provisions of section 80IC(7) r.w.s. 801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that ... apportioned and borne by the two manufacturing entities, that too, simply on the ground that the said two entities were claiming tax holiday under section 80IC of the Act and the AO, on conjectures surmises, concluded that AMP expenses have not been apportioned to show higher profits in the said

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

apportion the AMP expenses in the hands of its two sisterly concerns because these were enjoying tax holidays under the provisions of section 80IC(7) r.w.s. 801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that ... apportioned and borne by the two manufacturing entities, that too, simply on the ground that the said two entities were claiming tax holiday under section 80IC of the Act and the AO, on conjectures surmises, concluded that AMP expenses have not been apportioned to show higher profits in the said

M/S. Mahle Filters Systems (India) Ltd., New Delhi vs. DCIT, New Delhi

ITA 4621/DEL/2016[2010-11]Status: DisposedITAT Delhi15 Dec 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Krinwant Sahaydcit, Circle 16(1), Vs. Mahle Filters Systems (India) C.R. Bldg., New Delhi Ltd., 1, Sri Aurobindo Marg, New Delhi – 16 (Pan: Aaacp5890Q) (Appellant) (Respondent)

For Appellant: Sh. Neeraj Jain, Adv. & Sh. Tavish Verma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 391Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’ NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI KRINWANT

DCIT, New Delhi vs. M/S Mahle Filter Systems (India) Pvt. Ltd., New Delhi

ITA 4240/DEL/2016[2010-11]Status: DisposedITAT Delhi15 Dec 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Krinwant Sahaydcit, Circle 16(1), Vs. Mahle Filters Systems (India) C.R. Bldg., New Delhi Ltd., 1, Sri Aurobindo Marg, New Delhi – 16 (Pan: Aaacp5890Q) (Appellant) (Respondent)

For Appellant: Sh. Neeraj Jain, Adv. & Sh. Tavish Verma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 391Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’ NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI KRINWANT

ACIT, Circle-2, Noida vs. Noida Special Economic Zone Authority, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6732/DEL/2018[2012-13]Status: DisposedITAT Delhi12 Dec 2025AY 2012-13

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

also find that Delhi Tribunal in Fibrefill Engineers vs ACIT (2017) 83 taxmann.com 34 (Delhi-Trib) also held that deduction under section 80IC cannot be denied only on the basis of filing a belated return of income. It was also held that language of section 139 makes it clear that

Noida Special Economic Zone Authority, Noida vs. DCIT, Circle-2, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6541/DEL/2018[2012-13]Status: DisposedITAT Delhi12 Dec 2025AY 2012-13

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

also find that Delhi Tribunal in Fibrefill Engineers vs ACIT (2017) 83 taxmann.com 34 (Delhi-Trib) also held that deduction under section 80IC cannot be denied only on the basis of filing a belated return of income. It was also held that language of section 139 makes it clear that

Noida Special Economic Zone Authority, Noida vs. DCIT, Circle-2, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6540/DEL/2018[20101-11]Status: DisposedITAT Delhi12 Dec 2025

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

also find that Delhi Tribunal in Fibrefill Engineers vs ACIT (2017) 83 taxmann.com 34 (Delhi-Trib) also held that deduction under section 80IC cannot be denied only on the basis of filing a belated return of income. It was also held that language of section 139 makes it clear that

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 491/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 92C

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI VIJAY

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 490/HYD/2022[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 92C

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI VIJAY

Unipatch Rubber Limited, Delhi vs. DCIT/ACIT, Circle 25(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 4439/DEL/2025[2014-15]Status: DisposedITAT Delhi10 Dec 2025AY 2014-15

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.4439/Del/2025 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Unipatch Rubber Limited, Dcit/Acit, Building No.10, Community Centre, Vs. Circle 25(1), Saket, Delhi. Delhi. Pan No.Aaacu0325P अपीलाथ" Appellant ""यथ"/Respondent

Section 250oSection 271(1)Section 271(1)(c)Section 274Section 80ISection 94(7)

ITA No.4439/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”NEW DELHI BEFORE SHRIMAHAVIR SINGH, HON’BLE VICE PRESIDENT

ACIT, CC-13, Jhandewalan vs. Sbl Pvt Ltd, Haridwar

In the result, the appeal of the Revenue is dismissed

ITA 4391/DEL/2025[2014-15]Status: DisposedITAT Delhi03 Dec 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2014-15] Vs Acit Sbl Pvt. Ltd. Central Circle-13 Plot No.3, Sector-12, Iie, New Delhi. Sideul, Haridwar, Uttarakhand-249403. Pan-Aaccd0037H Appellant Respondent Revenue By Shri Jitender Singh, Cit Dr Assessee By Shri Shaurya Jain, Adv. Date Of Hearing 03.12.2025 Date Of Pronouncement 03.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Revenue Against The Order Dated 15.04.2025 Passed By Ld. Commissioner Of Income Tax (A)-26, New Delhi [“Ld.Cit(A)”] In Appeal No. 26/10525/17-18 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 30.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That Assessee Company Engaged In Manufacturing Of Homoeopathy Medicines In India & Has Two Manufacturing Units Situated At Haridwar Which Are Eligible For Deduction U/S 80-Ic Of The Act & Also Has Units At Jaipur & Sahibabad, Which Are Non-Eligible Units. The Assessee Company Filed Its Return Of Income On 29.09.2014, Declaring Total Income Of Inr 18,85,40,940/-. The Case Was Selected For Scrutiny Through Cass & Notice U/S 143(2) Was Issued On 31.08.2015, Followed By Notices U/S 142(1) Alongwith Questionnaire. In Response, Requisite Details & Replies Were From Time To Time. After Considering The Submissions & Replies Filed By The Assessee In Support Of Its Claim, Ao Assessed The Income Of The Assessee Company At Inr 52,74,33,562/- Vide Assessment Order Dated 30.12.2016 Passed U/S 143(3) Of The Act By Making Estimation Of Income At Sahibabad Plant & Further By Making Disallowance Out Of Various Expenses & By Not Allowing The Deduction U/S 80Ic Of The Act.

Section 142(1)Section 143(2)Section 143(3)Section 250Section 80Section 80I

ITA No.4391/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “A” BENCH: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI