DR.REDDY'S LABORATORIES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD
In the result, we hold that the Tax Authorities were not justified in apportioning R & D expenditure and ESOP cost to the units which claimed exemption u/s 10B, 80IB and 80IC of the Act
ITA 1844/HYD/2017[2008-09]Status: DisposedITAT Hyderabad08 Jun 2018AY 2008-09
Bench: Shri D. Manmohan & Shri S. Rifaur Rahman
For Appellant: Shri S.P. ChidambaramFor Respondent: Shri J. Siri Kumar, CIT-DR
Section 10ASection 10BSection 143(3)Section 147Section 148
reassessment beyond 4
years is barred by limitation and the allocation of R&D expenses to special units is a mere change of opinion. Hence, the proceedings u/s 148 of the Act are void ab initio and deserves to be quashed.
1.4
In this regard, we rely on various case laws as referred to in the case law compendium. Without