TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

2 Tata Cummins Vs DCIT 72.5 kVA to 100 kVA range. Thus, a single engine technological input was put to numerous uses through R&D efforts. 9.4 Subsequent periods saw rapid changes in environmental / emission norms putting a serious demand on R&D. By 2005, the Assessee's R&D was involved in adapting Base six cylinder 613 5.9 litres

ACIT CIRCLE-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

gains of\nsubsequent years without any limit whatsoever.\"\n8. In the light of the judicial precedents on the issue especially that\nof the Hon'ble Gujarat High court in the case of General Motors India\nPvt. Ltd. (supra), we find that the issue is covered in favour of the\nassessee, therefore, the ground taken by the revenue is rejected

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

gains of\nsubsequent years without any limit whatsoever.\"\n8. In the light of the judicial precedents on the issue especially that\nof the Hon'ble Gujarat High court in the case of General Motors India\nPvt. Ltd. (supra), we find that the issue is covered in favour of the\nassessee, therefore, the ground taken by the revenue is rejected