ITAT allows additional ground regarding treatment of subsidy – HC confirms

PCIT Vs Crystal Crop Protection Pvt. Ltd. (Delhi High Court)

The department has reiterated its objection to the ITAT admitting additional ground raised by the assessee regarding the treatment of subsidy. However, in the impugned order, the ITAT has given detailed reasoning for permitting the additional ground after relying upon the judgments of the Supreme Court, the CBDT Circular and the history of the legislative provision of Section 143 (3) of the Act. Pertinently, no submission has been advanced by the department on the merits of the claim of subsid

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