ACIT, Circle-1, Noida vs. Jaiprakash Associates Limited

Income Tax Appellate Tribunal Decision: ACIT, Circle-1, Noida vs. Jaiprakash Associates Limited

Case Number: ITA 946/DEL/2022

Appellant: ACIT, Circle-1, Noida

Respondent: Jaiprakash Associates Limited

Assessment Year: 2011-12

Result: Dismissed

Summary

This document presents the judgment passed by The Income Tax Appellate Tribunal, Delhi Bench ‘C’, concerning multiple appeals filed by the Revenue against the separate orders of the Ld. CIT(A)-I, Noida. The appeals for the assessment years 2010-11 to 2012-13 involve identical issues and hence were clubbed together for a consolidated judgment.

Background

The appeals arise from the orders passed by Ld. CIT(A)-I, Noida concerning the respective assessment years, which provided substantial relief to the assessee, Jaiprakash Associates Limited. The Revenue, not satisfied with the outcomes, pursued further appeal.

Key Points of Judgment

• The tribunal observed that since the appeals by the Revenue for the three different assessment years involve identical issues, they were heard together and disposed of by a single consolidated order for brevity.
• Several specific issues were addressed, including the claim of depreciation on Iraqi assets, disallowance of depreciation on purely temporary erections, disallowance of interest claims, and more.
• The CIT(A)’s decision to allow depreciation claims and deductions under various sections was contested. However, for each ground raised by the Revenue, detailed deliberations led to the conclusions largely favoring the assessee.
• Particularly, the tribunal recounted past judgments, the principles of consistency, and various assessments from previous years to arrive at their decisions.
• The core principle guiding the tribunal’s judgment was based on precedents and the factual matrix presented for each assessment year.

Conclusion

After thorough examination, the Tribunal dismissed the Revenue’s appeals for all the assessment years in question, thus upholding the orders of the Ld. CIT(A), which granted relief to Jaiprakash Associates Limited. Significant emphasis was placed on consistency and adherence to previous judgments.

ACIT, Circle-1, Noida vs. Jaiprakash Associates Limited