Case Law Details
PCIT Vs Nirja Publishers & Printers Pvt. Ltd. (Delhi High Court)
Introduction: The recent judgment by the Delhi High Court in the case of PCIT vs. Nirja Publishers & Printers Pvt. Ltd. sheds light on the eligibility of the printing and binding of books as manufacturing activities, determining the allowance of deductions under Section 80IC of the Income Tax Act. This article delves into the court’s detailed analysis and conclusions.
Detailed Analysis: The crux of the matter revolved around the eligibility of the respondent/assessee, Nirja Publishers & Printers Pvt. Ltd., to claim deductions under Section 80IC for the Assessment Years 2011-12 and 2012-13. The Assessing Officer contested the deductions, asserting that no manufacturing activity, specifically printing and binding of books, occurred at the eligible undertaking in Rudrapur.
The court noted that the primary dispute was factual: whether printing and binding of books took place at the eligible undertaking. The Commissioner of Income Tax (Appeals) had already ruled in favor of the respondent, emphasizing that the appellant failed to disallow the deduction based on a violation of prescribed conditions. The court affirmed the findings of the CIT(A), stating that the appellant’s claim for deduction was supported by genuine evidence, and there was no refutation in the remand report.
Despite the appellant/revenue’s contentions, the court upheld the factual findings of the lower authorities, emphasizing its limited jurisdiction under Section 260A of the Income Tax Act. It clarified that it cannot reevaluate questions of fact in the absence of any grounds alleging perversity in the findings.
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