Section 80-IE of the Income Tax Act

Income-tax Act, 2025: s.143

Section 80-IE of the Income-tax Act, 1961 corresponds to section 143 (Special provisions in respect of certain undertakings in North-Eastern States) of the Income-tax Act, 2025.

Read section 143 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 80-IE is Apex Laboratories Pvt. Ltd. v. CIT (135 Taxmann.com 286), cited in 148 of the 45 judgments on BharatTax that turn on this section.

Leading authorities on Section 80-IE

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.

A.V. Fernandez v. State of Kerala
8 STC 561 · 1957 · Supreme Court
21
citing judgments

Taxing statutes must be strictly construed, and their clear language does not allow for inference or equity. Exemptions and exclusions must also be strictly construed and cannot be extended by interpretation.

Similarly, in B. Premanand v. Mohan Koikal
4 SCC 266 · 2011 · Reported
19
citing judgments

Where the statutory language is plain and unambiguous, external aids like precedents cannot be used to obscure or rewrite the legislative command.

Apex Laboratories (P.) Ltd. v. Dy. CIT
286 Taxmann 200 · 2022 · Supreme Court
16
citing judgments
10B. In Navbharat Charitable Trust v. Income
150 Taxmann.com 311 · 2023 · ITAT
15
citing judgments

Exemption for a charitable trust under sections 11/12 cannot be denied solely due to the delayed filing of the audit report in Form No. 10B, provided all other conditions for exemption have been substantially met.

Karnataka State Industrial Infrastructure Development Corporation Ltd. v. DCIT
76 Taxmann.com 360 · 2016 · ITAT
13
citing judgments

The expression 'any income' in Section 10(38) refers to long-term capital gains computed under Section 48, which includes the indexed cost of acquisition. This principle applies when computing book profits under Section 115JB.

Judgments on Section 80-IE

Heavy Vehicles Factory Employees Coop Thrift and Credit Society Ltd., Thiruvallur vs. ITO, Ncw-7(3), Chennai

In the result, both the appeals filed by the assessee are dismissed

ITA 3577/CHNY/2025[2019-20]Status: DisposedITAT Chennai27 Jan 2026AY 2019-20

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3576 & 3577/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & 2019-20 Heavy Vehicle Factory Employees Vs. The Income Tax Officer, Cooperative Thrift & Credit Society Non Corporate Ward 7(3), Ltd., M B 26-A, Hvf Estate, Avadi, Chennai. Tiruvallur 600 054. [Pan:Aaaah3020N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri Sbr Kumar Laghimsetti, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 27.01.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Order Dated 09.09.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2018-19 & 2019-20. 2. When The Appeal Was Taken Up For Hearing, None Appeared On Behalf Of The Assessee Nor Filed Any Adjournment Petition. Thus, The 2

For Appellant: NoneFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 139(1)Section 148Section 80ASection 80P

Heavy Vehicles Factory Employees Coop Thrift and Credit Society Ltd., Tiruvallur vs. ITO, Ncw-7(3), Chennai

In the result, both the appeals filed by the assessee are dismissed

ITA 3576/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Jan 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3576 & 3577/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & 2019-20 Heavy Vehicle Factory Employees Vs. The Income Tax Officer, Cooperative Thrift & Credit Society Non Corporate Ward 7(3), Ltd., M B 26-A, Hvf Estate, Avadi, Chennai. Tiruvallur 600 054. [Pan:Aaaah3020N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri Sbr Kumar Laghimsetti, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 27.01.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Order Dated 09.09.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2018-19 & 2019-20. 2. When The Appeal Was Taken Up For Hearing, None Appeared On Behalf Of The Assessee Nor Filed Any Adjournment Petition. Thus, The 2

For Appellant: NoneFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 139(1)Section 148Section 80ASection 80P