ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD
In the result, the appeal of Revenue is allowed
ITA 1199/HYD/2024[2016-17]Status: DisposedITAT Hyderabad11 Feb 2025AY 2016-17
Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025
For Appellant: Shri RV. Chalam, C.AFor Respondent: Shri B. Balakrishna, CIT-DR
Section 11Section 11(1)(a)Section 12(1)Section 12ASection 143(2)Section 143(3)Section 144
forward by the learned
Standing Counsel for the Revenue was that the expenditure, even if it is considered as application of the income, was outside India and the mandate of the Section is that the income should be applied in India to charitable purposes and this condition not having been satisfied, the Tribunal was clearly wrong in holding that