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1 - 7 of 7 (0.17 seconds)Section 260A in The Income Tax Act, 1961 [Entire Act]
Section 10B in The Income Tax Act, 1961 [Entire Act]
Section 154 in The Income Tax Act, 1961 [Entire Act]
The Jt Cit (Osd) (Exemption) Circle-1, ... vs Gujarat Energy Development Agency, ... on 2 August, 2023
2. Whether the Tribunal was justified in holding that filing of
Form 56F was directory in nature by placing reliance in the case
of CIT (E) v. Gujarat Energy Development Agency1 , which is
contrary to the direction of the Apex Court while dealing with
10B(8) in the case of Principal Commissioner of Income Tax v.
The Principal Commissioner Of Income ... vs M/S Wipro Limited on 11 July, 2022
6. We agree with the ITAT that the facts in the case of Principal
Commissioner of Income Tax v. Wipro Ltd (supra) were different. In that
case, assessee initially made the claim and did not seek to carry forward
losses, but during the assessment proceedings, the assessee had taken an
altogether different stand and sought withdrawal of the initial deduction
claimed in the return of income and sought to carry forward losses. In the
case at hand, the deduction under Section 10AA of the Act has been claimed
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https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/06/2025 04:06:21 pm )
TCA No.87 of 2025
in the original return of income which was filed within the prescribed time,
but Form 56F was filed about 50 days later.
M/S Wipro Limited vs The Principal Commissioner Of Income ... on 27 September, 2022
Wipro Limited2 and also in the case of Review Petition filed in
1 TCA No.35 of 2024, dated 15.1.2024
2 (2022) 446 ITR 1
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Page 2 of 7
https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/06/2025 04:06:21 pm )
TCA No.87 of 2025
Wipro Limited v. Principal Commissioner of Income Tax3,
wherein it was held that the twin conditions of furnishing the
declaration to the Assessing Officer in writing and that the same
must be furnished before the due date for filing of the return of
income under Section 139(1) of the IT Act must be satisfied,
whereas assessee failed to do while claiming deduction under
Section 10B?”
1