VidhiSangh

Supreme Court of India · 20/05/2025

SHITAL FIBERS LIMITED versus COMMISSIONER OF INCOME TAX

[2025] 5 S.C.R. 1248 · 2025 INSC 743

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Summary

Three-Judge Bench reference arising from the split in ACIT v. Micro Labs Ltd on the meaning of Section 80-IA(9) of the Income Tax Act, 1961. The Court held that sub-section (9) does not require the deduction allowed under Section 80-IA to be reduced from gross total income when computing a deduction under another provision of heading 'C' of Chapter VI-A (such as Section 80-HHC); it operates only at the stage of allowing the deduction, capping the aggregate of heading 'C' deductions at the profits and gains of the eligible business, approving the Bombay High Court in Associated Capsules and the view of Dipak Misra, J. in Micro Labs.

Issues

  1. Whether, once a deduction is claimed and allowed under Section 80-IA, Section 80-IA(9) requires the gross total income to be reduced by that deduction before computing the deduction under Section 80-HHC or any other provision under heading 'C' of Chapter VI-A.
  2. Whether Section 80-IA(9) affects the computation of deductions under heading 'C' or only their allowability, so that the aggregate does not exceed the profits and gains of the eligible business.
  3. Which of the two views expressed in ACIT v. Micro Labs Ltd (Anil R. Dave, J. or Dipak Misra, J.) is correct.

Provisions considered

Held

Result

Reference answered in favour of the interpretation adopted by the Bombay High Court in Associated Capsules and by Dipak Misra, J. in Micro Labs; Registry directed to place the appeals and petitions before the appropriate Bench for disposal.

Judgment PDF: Supreme Court of India, [2025] 5 S.C.R. 1248.