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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

Aspee Sons, Solan vs. Income Tax Officer, Parwanoo

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1167/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh29 Jul 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 271(1)(c)Section 80Section 80I

आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING

Sylvan Greens Private Limited, Jaipur vs. Deputy Commissioner of Income Tax Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

assessee is a eligible to claim deduction under section 80 IC(ii)(b) of the Income Tax Act. The assessee also claimed deduction under section 80IC(ii)(b) since A Y 2010-11 and also claimed for this year also. Copy of Audit Report under section 80 IC in form ... object for which subsidy was given, without following the proper procedure with respect with respect to reassessment and without giving the deduction under section 80IC, are not according to the law and facts of the case. The assessee would like to submit as under: a) The assessee's plant

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 473/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh21 Jul 2025AY 2018-19
For Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute 'manufacturing' or 'production'. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the application of industrial processes and technology, and not to extend benefits to mere packers ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 472/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh21 Jul 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Aman Bansal, AdvocateFor Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute ‘manufacturing’ or ‘production’. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the 10 application of industrial processes and technology, and not to extend benefits to mere ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 471/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh21 Jul 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Aman Bansal, AdvocateFor Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute ‘manufacturing’ or ‘production’. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the 10 application of industrial processes and technology, and not to extend benefits to mere ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 470/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh21 Jul 2025AY 2015-16
For Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute 'manufacturing' or 'production'. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the application of industrial processes and technology, and not to extend benefits to mere packers ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 469/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh21 Jul 2025AY 2014-15
For Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute 'manufacturing' or 'production'. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the application of industrial processes and technology, and not to extend benefits to mere packers ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 468/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh21 Jul 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Aman Bansal, AdvocateFor Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute ‘manufacturing’ or ‘production’. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the 10 application of industrial processes and technology, and not to extend benefits to mere ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Daxen Agritech India Pvt. Ltd., Baddi vs. ACIT, Circle, Parwanoo

In the result, all the above appeals of the Assessee are dismissed

ITA 467/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh21 Jul 2025AY 2011-12
For Appellant: Shri Aman Bansal, AdvocateFor Respondent: Smt. Geetinder Mann, CIT, DR
Section 143(1)Section 143(3)Section 148Section 80

composition, or intended use of the product, cannot be said to constitute 'manufacturing' or 'production'. It is pertinent to reiterate that the incentive under Section 80IC has been introduced to promote genuine manufacturing activities involving the application of industrial processes and technology, and not to extend benefits to mere packers ... necessity and relevance of such an exercise. The core issue in this appeal pertains to the eligibility of the assessee for deduction under Section 80IC of the Income Tax Act. The primary onus to establish that the assessee was engaged in the manufacture or production of an article or thing

Aspee Sons, Solan vs. Income Tax Officer, Parwanoo

In the result, Assessee’s appeal is allowed for Statistical Purposes

ITA 1168/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh21 Jul 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1168/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 Aspee Sons, The Ito, बनाम Village Kuranwala, Parwanoo Barotiwala, Vs. S.O.Barotiwala (196), Solan 174103 "थायी लेखा सं./ Pan No: Aaqfa1827R अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, C.A. राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 16.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 21.07.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 19.09.2024 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. Grounds Of Appeal Are As U

For Appellant: Sh. Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 115JSection 143(3)Section 250bSection 80Section 80I

आयकर अपील"य अ"धकरण, च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH

Deputy Commissioner of Income Tax, CC-2(3), Kolkata, Aayakar Bhawan Poorva vs. Kamlang Saw & Veneer Mills Pvt. Ltd., Assam

In the result, the appeal filed by the revenue is dismissed

ITA 225/KOL/2025[2018-19]Status: DisposedITAT Kolkata17 Jul 2025AY 2018-19

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

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

आयकर अपील"य अ"धकरण, कोलकाता पीठ “बी’’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA "ी राजेश कुमार

Amico Textiles, Solan vs. DCIT CC-1, Chandigarth

The appeal stand partly allowed

ITA 431/CHANDI/2022[2014-15]Status: DisposedITAT Chandigarh16 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.431/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2014-15) M/S Amico Textiles Dcit Village Bir Plassi, Ropar Road, Central Circle-1 बनाम/ Vs. Nalagarh, Solan Chandigarh Himachal Pradesh 176077 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfa-9823-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 23-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 30-12-2016. The Substantial Grievance Of The Assessee Is Confirmation Of Addition Of Rs.63.27 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed Off As Under.

For Appellant: Sh. Neeraj Jain (CA) – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) – Ld. DR
Section 132Section 143(3)Section 69

1 IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHANDIGARH PHYSICAL HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

Deputy Commissioner of Income Tax Circle 3(1)(1), Ahmedabad vs. Reckitt Benckiser Healthcare India Private Limited, Haryana

ITA 1248/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad16 Jul 2025AY 2022-23

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Rignesh Das, CIT-DR
Section 250Section 40Section 80Section 80I

expenditure made by AO. c) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction claimed under section 80IC of the Act of Rs.50,91,52,050/- by restricting the deduction under section 80IC of the Act to Rs.44 ... income, made by AO. d) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction under section 80IC on scrap income of Rs.60,77,133/-, made by AO. e) The Ld. CIT(A) has erred in law and on facts in deleting

Deputy Commissioner of Income Tax Circle 3(1)(1), Ahmedabad vs. Reckitt Benckiser Healthcare India Private Limited, Haryana

ITA 1247/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Jul 2025AY 2020-21

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Rignesh Das, CIT-DR
Section 250Section 40Section 80Section 80I

expenditure made by AO. c) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction claimed under section 80IC of the Act of Rs.50,91,52,050/- by restricting the deduction under section 80IC of the Act to Rs.44 ... income, made by AO. d) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction under section 80IC on scrap income of Rs.60,77,133/-, made by AO. e) The Ld. CIT(A) has erred in law and on facts in deleting

Deputy Commissioner of Income Tax Circle 3(1)(1), Ahmedabad vs. Reckitt Benckiser Healthcare India Private Limited, Haryana

ITA 1246/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad16 Jul 2025AY 2013-14

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Rignesh Das, CIT-DR
Section 250Section 40Section 80Section 80I

expenditure made by AO. c) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction claimed under section 80IC of the Act of Rs.50,91,52,050/- by restricting the deduction under section 80IC of the Act to Rs.44 ... income, made by AO. d) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction under section 80IC on scrap income of Rs.60,77,133/-, made by AO. e) The Ld. CIT(A) has erred in law and on facts in deleting

Deputy Commissioner of Income Tax Circle 3(1)(1) Ahmedabad, Ahmedabad vs. Reckitt Benckiser Healthcare India Private Limited, Gurgaon

ITA 1245/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jul 2025AY 2012-13

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Rignesh Das, CIT-DR
Section 250Section 40Section 80Section 80I

expenditure made by AO. c) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction claimed under section 80IC of the Act of Rs.50,91,52,050/- by restricting the deduction under section 80IC of the Act to Rs.44 ... income, made by AO. d) The Ld. CIT(A) has erred in law and on facts in deleting the disallowance of deduction under section 80IC on scrap income of Rs.60,77,133/-, made by AO. e) The Ld. CIT(A) has erred in law and on facts in deleting

Surya Laxmi Industries, Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5103/DEL/2024[2020-21]Status: DisposedITAT Delhi16 Jul 2025AY 2020-21

Bench: Shri Vikas Awasthy & Shri M. Balaganeshsurya Laxmi Industries, Vs. Dcit, 7-B, Bigjos Tower, Netaji New Delhi Subhash Place, Pitampura, New Delhi (Appellant) (Respondent) Pan: Abwfs8662D Assessee By : Shri Lalit Mohan, Adv Shri Ankit Kumar, Adv Revenue By: Shri Manish Gupta, Sr. Dr Date Of Hearing 22/05/2025 Date Of Pronouncement 16/07/2025

For Appellant: Shri Lalit Mohan, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 139(1)Section 143(1)Section 154Section 80I

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Rtv International, Solan vs. Pr.CIT, Shimla

The appeal stands allowed in terms of our above order

ITA 131/CHANDI/2021[2014-15]Status: DisposedITAT Chandigarh15 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No. 131/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2014-15) M/S Rtv Vision Technologies Pvt. Ltd. Pr. Cit बनाम/ (Successor Of M/S Rtv International) Shimla. Plot No.G-97, Site-5, Upsidc Vs. Kasna Industrial Area, Greater Noida "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-4395-J / Aalfr-8106-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sameer Kapoor- Ld. Ar ""थ"कीओरसे/Respondent By : Shri Rajat Kumar Kureel (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 02-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Assailing Proposed Revision Of The Order U/S 263 As Passed By Ld. Pr. Commissioner Of Income Tax, Shimla (Pr. Cit) On 22-03-2019 Has Come Up For Hearing Pursuant To The Order Of Hon’Ble High Court Of Himachal Pradesh, Shimla In Ita No.01 Of 2025 Dated 28-05-2025. The Directions Of Hon’Ble Court Are As Under: - 3. In The Given Facts & Circumstances, We Deem It Appropriate To Condone The Delay In Filing The Appeal & Set Aside Orders Dated

For Appellant: Shri Sameer Kapoor- Ld. ARFor Respondent: Shri Rajat Kumar Kureel (CIT) – Ld. DR
Section 143(3)Section 263Section 80I

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH BEFORE HON’BLE SHRI LALIET KUMAR, JM AND HON’BLE

Deputy Commissioner of Income Tax, Chennai vs. Ashok Leyland Limited, Chennai

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

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

आयकर अपीलीय अिधकरण, ’डी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Ashok Leyland Limited, Chennai vs. DCIT Non Corp Circle 8(1) Ltu - II, Chennai

ITA 1402/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1402/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (अपीलार्थी/Appellant) V. The Dcit, Ncc-8(1), Ltu-Ii, Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1663/Chny/2024 निर्धारण वर्ष/Assessment Year: 2019-20 The Dcit, Ncc-8, Chennai. (अपीलार्थी/Appellant) V. M/S. Ashok Leyland Ltd., No.1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaса 4651 L] (प्रत्यर्थी/Respondent) Assessee By : Mr.R. Vijayaraghavan, Advocate Department By : Ms.Ann Marry Baby, Cit सुनवाईकीतारीख/Date Of Hearing : 04.06.2025 घोषणाकीतारीख /Date Of Pronouncement : 07.07.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Cross-Appeals Preferred By The Assessee As Well As The Revenue Against The Order Of The Learned Commissioner Of Income Tax

For Appellant: Mr.R. Vijayaraghavan, AdvocateFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

आयकर अपीलीय अधिकरण, 'डी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक