2024 (12) TMI 1619

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....al, CIT-DR ORDER PER OMKARESHWAR CHIDARA, AM The Revenue has filed an appeal in this above cited case following three grounds: "1. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in allowing the deduction u/s 80IC(2) of the I.T. Act for Uttaranchal Unit-I of Rs. 15,97,87,975/ - without appreciation of the facts that preparation of Ujala Supreme....

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..... "On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in allowing the credit of TDS of Rs. 3,22,008/-without appreciation of the facts that the assessee has not offered the earned income of amalgamating company i.e. Jyothy Consumer Products Ltd." 2. The essence of the issue in the first two grounds is whether the appellant company is entitled to deduction ....

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....he same are pending. The Ld. AR and Ld. DR have agreed that the first two grounds are covered in favour of assessee. In view of the same, the first two grounds are adjudicated in favour of the appellant, i.e. the appellant is entitled to deduction u/s 80IC(2) and the activites of appellant company amount to "manufacturing activity. " 4. As far as the 3rd ground of appeal is concerned, the....

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....it of Rs. 3,22,008/-, JCPL which was then merged with Pursuant to the amalgamation, all the assets and liabilities of the amalgamating company (JCPL) were transferred to the assessee.Accordingly, the TDS credit of Rs. 3,22,008/ which is on account of JCPL which was then merged with the assessee, has been claimed as credit by the assessee, being the amalgamated company. As a result, the assessee be....