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Case Law Details

Case Name : PCIT Vs Alembic Ltd (Gujarat High Court)
Appeal Number : R/Tax Appeal No. 83 of 2023
Date of Judgement/Order : 06/05/2024
Related Assessment Year : 2013-14
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PCIT Vs Alembic Ltd (Gujarat High Court)

The case of PCIT vs Alembic Ltd, decided by the Gujarat High Court, delves into significant tax issues concerning disallowance under Section 14A of the Income Tax Act, 1961 (the Act), and the deduction under Section 80IA(4). This judgment provides clarity on the interpretation and application of these provisions, pivotal for understanding tax liability in specific contexts.

Background and Facts

Alembic Ltd, the respondent in this case, filed its income tax return for the Assessment Year 2013-14, declaring a total income of NIL after adjusting brought forward losses and business losses. The Assessing Officer, however, made additions under Section 14A read with Rule 8D, amounting to Rs. 43,70,550, and disallowed deductions claimed under Section 80IA(4) to the tune of Rs. 4,07,76,334.

Section 14A Disallowance

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