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“section 80JJAA”

DeductionsSection 80JJAASection 80JJAA247 judgments

The decision most relied on for section 80JJAA is CIT v. G.M. Knitting Industries (P.) Ltd. (376 ITR 456), cited in 221 judgments on BharatTax.

Leading authorities on section 80JJAA

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

Apex Laboratories Pvt. Ltd. v. CIT
135 Taxmann.com 286 · 2022 · Supreme Court
148
citing judgments

Expenditure incurred by pharmaceutical companies on freebies provided to medical practitioners is not deductible under Explanation 1 to Section 37(1) of the Income-tax Act, as such gifting is prohibited by the Medical Council Regulations, 2002. The court also held that what is directly prohibited by law cannot be indirectly evaded through contrivance.

Orissa State Warehousing Corpn v. CIT
237 ITR 589 · 1999 · Supreme Court
114
citing judgments

A fiscal statute must be interpreted strictly based on its plain language, without substituting judicial impressions for legislative intent. Exemptions and exclusions within such statutes must also be construed strictly and cannot be extended through interpretation.

CIT v. Tara Agencies
292 ITR 444 · 2007 · Supreme Court
80
citing judgments

When interpreting fiscal legislation, courts must adhere strictly to the plain and unambiguous language of the statute, without introducing intendment, equity, or words not present in the text, irrespective of perceived hardship. The legislative intent must be gathered solely from what has been said and not said in the statutory language.

Best Trading and Agencies Limited v. DCIT
119 Taxmann.com 129 · 2020 · High Court
45
citing judgments

The computation provisions for long-term capital gains, including the benefit of indexation under sections 45, 48, and 112, are applicable when determining book profits under section 115JB(5) for Minimum Alternate Tax, unless explicitly overridden, ensuring the 'real income' is taxed.

Form No. 10B. In Trust For Reaching The Unreached Through Trustee v. Commissioner of Income Tax (Exemptions), Ahmedabad
126 Taxmann.com 77 · 2021 · High Court
34
citing judgments

A trust substantially satisfying the conditions for exemption under Section 11 cannot be denied that exemption solely due to a procedural delay in furnishing the audit report in Form No. 10, as the submission of the form is considered a procedural rather than a mandatory condition.

Digital Equipment India Ltd. v. DCIT
103 TTJ 329 · 2006 · ITAT
27
citing judgments

A mere substantial profit does not inherently indicate an arrangement to earn profits beyond ordinary levels to abuse tax concessions under Section 80-IA(9) or (10). The Assessing Officer must provide specific evidence of such an arrangement.

Addl. CIT v. Delhi Press Patra Prakashan
10 SOT 74 · 2006 · ITAT
19
citing judgments

An Assessing Officer cannot arbitrarily adjust the profit margin of a specific unit by comparing it to the overall profit margin of the assessee, especially when the units have different business natures and separate books of accounts are maintained.

Judgments citing section 80JJAA

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

have held that: a. the Appellant claimed the deduction u/s 80JJAA towards additional employee cost after fulfilling the conditions and requirements provided in section 80JJAA, b. the documents and evidence submitted by the Appellant along with Form 10DA clearly establish that the Appellant is eligible to claim deduction u/s 80JJAA

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

80JJAA of Act. The total no. of employees during the previous year was 2531 out of which eligible employees for the purpose of section 80JJAA was 627. The copy of excel sheet file for deductions claimed u/s 80JJAA of the Act and Form 10DA has been submitted by the assessee ... dated 19.09.2022 and in the said scrutiny assessment proceedings, the assessing officer has allowed the deduction claimed by the assessee, under section 80JJAA of the Act to the tune of Rs.3,01,93,275/-, therefore, while making the order under section 143(3) of the Act dated 19.09.2022, assessing officer

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

80JJAA of Act. The total no. of employees during the previous year was 2531 out of which eligible employees for the purpose of section 80JJAA was 627. The copy of excel sheet file for deductions claimed u/s 80JJAA of the Act and Form 10DA has been submitted by the assessee ... dated 19.09.2022 and in the said scrutiny assessment proceedings, the assessing officer has allowed the deduction claimed by the assessee, under section 80JJAA of the Act to the tune of Rs.3,01,93,275/-,. therefore, while making the order under section 143(3) of the Act dated 19.09.2022, assessing officer