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1 - 7 of 7 (0.56 seconds)Section 80G in The Income Tax Act, 1961 [Entire Act]
Section 115O in The Income Tax Act, 1961 [Entire Act]
Finance Act, 2019
Section 115JB in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income Tax, Delhi vs M/S Woodward Governor India P. Ltd on 8 April, 2009
Since the
decision of the special Bench binds not only the learned Assessing Officer
but also binds this Bench of the Tribunal also, we do not deem it necessary
to restore the issue to the file of the learned Assessing Officer because the
learned Assessing Officer cannot take a different view deviating from the
view taken by the special Bench in the case of Total Oil India (P) Ltd (supra).
P.R. Prabhakar vs Commissioner Of Income Tax, Coimbatore on 18 July, 2006
5. Coming to the Revenue's appeal, as stated above it is about the
deletion of the disallowance of expenditure incurred by the assessee on
ESOP & ESPP and also the disallowance of realized hedging loss on forward
contracts. Though the pleader argued vehemently to justify the additions
made by the learned Assessing Officer by making these 2 disallowances,
there is no contradiction of the fact that in assessee's own case for the
assessment years 2010-11, 2012-13 and 2014-15 the Tribunal has taken a
consistent view that the issue of expenditure on ESOP and ESPP is covered
by the decision of the Hon'ble Karnataka High Court in the case of Biocon
Ltd by order dated 11/11/2020 in ITA No.653/2013. Further, for the
assessment years 2012-13 and 2014-15, this Tribunal has taken a consistent
view that the issue relating to the activity of realized hedging loss on
forward contracts is covered by the decision of the Hon'ble Apex Court in
the cases of CIT vs. Woodward Governor India (P) Ltd (2009) 179 Taxmann
326 (SC) and also PR Prabhakar vs. CIT (2006) 284 ITR 584. This view is
consistently followed in assessee's own case for the above the assessment
years. Copies of the orders are filed in the form part of record.
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