additional claim of deduction of
Rs.11,66,05,610/- under section 32AC of the Income Tax Act, 1961, made by the
assessee through ... erred in law in allowing deduction under section 32AC
in respect of capital expenditure incurred by the amalgamating company prior to
amalgamation, ignoring the specific
additional claim of deduction of
Rs.11,66,05,610/- under section 32AC of the Income Tax Act, 1961, made by the
assessee through ... erred in law in allowing deduction under section 32AC
in respect of capital expenditure incurred by the amalgamating company prior to
amalgamation, ignoring the specific
year 2015-16, raising following grounds:
1. Disallowance of deduction u/s 32AC claimed for the first time
during the appellate proceedings ... eligible for deduction u/s 32AC in AY 2015-16.
1.2. Without prejudice to the above and without admitting, on the
facts and circumstances
account of disallowance
of investment allowance claimed u/s. 32AC on dispensing units in retail outlets
ignoring the fact that the dispensing units ... plant
and hence, not eligible for claim of deduction U/s. 32AC.
2
ITA No. 3866/Mum/2025
Hindustan Petroleum Corporation
