DY CIT CC 1(4), MUMBAI vs. M/S ULTRATECH CEMENT LTD , MUMBAI
In the result, appeal filed by the Revenue is dismissed
ITA 931/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16
Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)
Section 115Section 32Section 32ASection 80I
80J, which did not have a provision similar to sub-section (12) of section 80IA.
68. In summary, prior to insertion of sub-section (12) in section 80IA, the deduction was allowed to the amalgamating and the amalgamated companies on a pro-rata basis for the year in which the amalgamation took place. Sub- section (12), although allowed the benefit