Tribunal upheld deletion of disallowance u/s 80-IA on amalgamated units and capped sec. 14A disallowance at actual exempt income

DCIT Vs Chiripal Industries Ltd. (ITAT Ahmedabad) Conclusion: Tribunal upheld the deletion of a disallowance of over ₹4.82 crore under Section 80-IA as the power plant was transferred as part of a court-approved amalgamation, assessee was entitled to “step into the shoes” of the amalgamating company and claim the deduction and also confirmed that disallowance under Section 14A could not exceed the actual exempt income earned during the year. Held: Assessee was a company engaged in the manufacture and processing of textile products, filed its return of income declaring a loss of ₹12.24 ...