IN THE HIGH COURT OF DELHI AT NEW DELHI
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ITA 739/2010
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PEPSICO INDIA HOLDINGS PVT LTD ..... Appellant
Through Mr. C.S. Aggarwal, Sr. Adv. with
Mr. Prakash Kumar, Adv.
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versus
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COMMISSIONER OF INCOME TAX ..... Respondent
Through Mrs. Prem Lata Bansal, Adv.
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CORAM:
HON'BLE THE CHIEF JUSTICE
HON'BLE MR. JUSTICE MANMOHAN
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O R D E R
02.07.2010
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CM No.11165/2010 (Exemption)
Allowed, subject to all just exceptions.
ITA No.739/2010
The present appeal preferred under Section 260A of the Income Tax Act is
admitted on the following substantial questions of law:-
1. Whether the Income-Tax Appellate Tribunal was justified in law in holding
that an amount of Rs.68,23,350/- representing the liability towards gratuity and
payable to employees and duly debited in the Profit and Loss Account represented
an unascertained liability so as to enhance the book profit in terms of
provisions of Clause (c) of Explanation to Section 115JA(1) of the Income Tax
Act, 1961?
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ITA No.739/2010 page 1 of
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2. Whether the Income-Tax Appellate Tribunal was justified in law in not
directing, that the amount of Rs.29,60,828/- being the liability towards leave
encashment due to the employees could not be deducted from the income computed
under the provisions of the Income Tax Act, 1961, inspite of judgment of Apex
Court in the case of Bharat Earthmovers v. CIT, reported in 245-ITR-428-SC?
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3. Whether in the circumstances of the case was not the Income Tax Appellate
Tribunal right in not deducting an addition made of Rs.2,83,70,822/- despite the
fact that no such deduction was either claimed in the computation of income or
was debited in the Profit and Loss Account?
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Mrs. Prem Lata Bansal, learned counsel for the revenue accepts notice.
In view of the aforesaid, no further notice need to be issued.
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CHIEF JUSTICE
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MANMOHAN, J
JULY 02, 2010
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