assessee with regard to the
disallowance under section 14A and confirmed the disallowance made under
section 35DD of the Act. Aggrieved, the assessee ... expenditure mentioned in sub-
section (1) under any other provision of this Act."
(emphasis supplied)
Section 35DD is unambiguous wherein it is provided that
Additional depreciation u/s 32(1)(iia) of the Act on Plant
& Machinery.
III. Non-granting of deduction u/s. 35DD ... Further,
the PCIT observing that the assessee had claimed deduction under Section
35DD of the Act amounting to Rs. 5.39 crores, but the PCIT observed
Assessee cannot claim twin deduction by claiming the
same under Section 35DD of the Act
3. The Appellant prays that deduction ... allow the claim of
deduction as per provisions of Sec. 35DD of the Act. Therefore, this
ground of appeal is allowed.
Ground No.7: Disallowance
Assessee cannot claim twin deduction by claiming the
same under Section 35DD of the Act
3. The Appellant prays that deduction ... allow the claim of
deduction as per provisions of Sec. 35DD of the Act. Therefore, this
ground of appeal is allowed.
Ground No.7: Disallowance
claim made by the assessee towards deduction of expenditure under
section 35DD of the Act based on the assessment order for Assessment
Year ... filed for an
additional claim for deduction under section 35DD of the Act of Rs
62,39,102/- being the 1/5th share
percent
2. Non-grant of claim of deduction under section 35DD of the
Income-tax Act, 1961 ('the Act') amounting ... deduction, under the provisions of section
35DD of the Act. The Assessing Officer has not considered the
fresh claim of the assessee in his Assessment
percent
2. Non-grant of claim of deduction under section 35DD of the
Income-tax Act, 1961 ('the Act') amounting ... deduction, under the provisions of section
35DD of the Act. The Assessing Officer has not considered the
fresh claim of the assessee in his Assessment
lakhs viz., Rs. 15.37 lakhs u/s 35DD. The ld. PCIT noted that the
method adopted by the assessee to claim deduction u/s 35DD ... exclusively' for the purpose of demerger. Therefore, provisions of
section 35DD of the Act are not applicable;
ii. The Company has only carried forward
5651/2021 JUDGMENT DATED: 05/07/2024
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issued under section 148 of the Income Tax
Act,1961 [for short ... report of the petitioner contained various
disclosures relating to deduction under
section 35DD of the Act [i.e. amortization
of expenditure in case of amalgamation
capital receipt as a benefit taxable
u/s 28(iv) of the Act:
3. Ground No. III: Disallowance ... deduction of taxes u/s. 194-1 of the Act:
7. Ground No. VII: Deduction u/s 35DD of the Act:
3. Whereas the Revenue
