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MAPAEX Remedies Pvt Ltd. vs. DCIT / ACIT

Case No: ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016-17 & 2017-18
Court: Income Tax Appellate Tribunal, Indore Bench
Date: 9/10/2024

Parties Involved

appellantMAPAEX Remedies Pvt Ltd.
respondentDCIT / ACIT

Facts Summary

The case involves appeals by both the assessee and the revenue for three assessment years: 2012-13, 2016-17, and 2017-18. The assessee, MAPAEX Remedies Pvt Ltd., is a company engaged in manufacturing pharmaceutical products for Proctor & Gamble Hygiene and Health Ltd. The assessee claims deductions under section 80-IC of the Income-tax Act, 1961, which were allowed by the Assessing Officer (AO) initially but later disallowed. The assessee and the revenue have filed cross-appeals before the Income Tax Appellate Tribunal (ITAT) for redressal of their grievances.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the re-opening of assessment by AO through notice dated 30.03.2019 u/s 148 and the assessment-order passed by AO u/s 147/143(3) was illegal, invalid and without jurisdiction?
  • 2. Whether the lower authorities have erred in not allowing expenses/deduction of Rs. 9,11,95,669/- claimed by the assessee under the heading 'cost of material consumed'?
  • 3. Whether the disallowance of deduction u/s 80-IC by the CIT(A) was justified?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

5 precedents cited in this judgement.

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MAPAEX Remedies Pvt Ltd. vs. DCIT / ACIT | ITA Nos. 486, 444, 489/Ind/2024 & 508 to 510 for AYs 2012-13, 2016… | Opakhya