This compilation indexes twelve income-tax rulings pronounced between June and September 2026 by various benches of the Income Tax Appellate Tribunal (ITAT) and two High Courts. Each ruling touches — directly or in conjunction with allied provisions — on claims, disallowances, or procedural questions connected to the profit-linked deduction regime under Sections 80I, 80IA, 80IC, and related provisions of the Income-tax Act, 1961. The index is intended for use by in-house tax teams, law-firm researchers, and Big-4 associates who need a consolidated starting point for locating these orders before pulling the full text from official portals.

Research index only. This page is a structured case-law reference, not legal or tax advice. Nothing on this page should be relied upon as a substitute for reading the full judgment, verifying its current status (including any stay, appeal, or reversal), and obtaining qualified professional counsel.

The statutory framework in one paragraph

Section 80I of the Income-tax Act, 1961 provides a deduction in respect of profits and gains derived by an assessee from certain industrial undertakings, ships, or hotels that satisfy prescribed conditions, for a specified number of assessment years. Section 80IA extends a similar profit-linked deduction framework to infrastructure development undertakings — including power generation, transmission, and distribution enterprises — and is subject to conditions relating to commencement date, minimum years of operation, and audit-report filing requirements (including Form 10CCB in applicable cases). Section 80IC provides analogous benefits for undertakings established in specified states and union territories (including certain north-eastern and hill states). These deductions fall within Chapter VI-A of the Act and are collectively subject to the overarching condition under Section 80 that the return of income must be filed within the due date prescribed. The quantum of deduction is computed with reference to the profits and gains of the eligible undertaking, and disputes frequently arise on questions of quantum computation, eligibility of the undertaking, timely filing of audit reports, and interaction with transfer-pricing provisions.

The 12 rulings

1. Cicago Commodities Pvt. Ltd.,,Kolkata vs ACIT, Circle 1(1), , Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 1 September 2026
Sections engaged: 44A, 801A(7)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi dated 18.03.2025, for Assessment Year 2018-19, wherein the CIT(A) upheld the Assessing Officer's rejection of the assessee's deduction claim amounting to Rs.59,03,094/-. The assessee had filed its return of income for AY 2018-19 on 30.10.2018, declaring total income of Rs.46,09,370/-; the sole issue before the Tribunal was the correctness of the disallowance of the said deduction as recorded in I.T.A. No.994/KOL/2025. Note: the sections cited in this case as recorded in the source data use non-standard formatting identifiers (e.g., "801A(7)"); the text preview references the deduction provision as "80IA" — researchers should verify the precise section reference against the full order text.

2. ACIT, Rajkot vs Crystal Global Industries, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 31 August 2026
Sections engaged: 10A, 10B, 10C, 80, 801C
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involved cross-appeals between the Revenue and the assessee, with ITA Nos. 508, 537 & 538/Rjt/2025 covering Assessment Years 2011-12, 2013-14, and 2014-15. Per the source preview, the Tribunal indicated it would adjudicate the Revenue's appeals in ITA Nos. 537 and 538/RJT/2025 for AY 2013-14 first, with the proceedings relating to profit-linked deduction and allied provisions for the relevant years arising from orders passed by the lower authorities. Note: the source data also lists "80I" among the sections cited in this matter; researchers should consult the full order to confirm the complete set of provisions engaged.

3. Dy. Commissioner Of Income Tax vs Baramati Agro Limited , Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 25 August 2026
Sections engaged: 115J, 32, 40(a), 40A(3), 43B, 80, 801A, 80A
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed ITA No.395/PUN/2026 against the respondent-assessee for Assessment Year 2021-22. The source preview discloses a tabular comparison of the profit/gain of the undertakings as per books versus the amount claimed as deduction, covering two units — Shetphalgade and Kannad — with claimed deduction amounts of Rs.28,31,05,135/- and Rs.19,07,75,889/- respectively (aggregate Rs.47,38,81,024/-), and a total difference of Rs.6,43,80,455/- between book profits and claimed deduction amounts across the two units.

4. Mojika Real Estate And Developers vs Circle 1, Jpr, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 10 August 2026
Sections engaged: 115J
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed ITA No.1010/JPR/2025 for Assessment Year 2018-19 along with an application to condone a delay of 372 days in filing the appeal. The delay was attributed to the fact that the impugned order was served on an email ID belonging to a former employee (Shri Ankit Agarwal) who had resigned prior to the passing of the order and had not communicated the ex-parte order to the assessee; the Tribunal was called upon to consider whether sufficient cause had been demonstrated for condoning the delay before any substantive question could be reached.

5. Vedanta Limited (Successor To Cairn vs ACIT, Circle 26(1), Haryana

Bench: Income Tax Appellate Tribunal - Delhi
Date: 3 August 2026
Sections engaged: Sections not specified
Outcome: Outcome not specified in source
Procedural / substantive ground: Six Stay Applications (S.A. Nos. 295 to 300/Del/2026) were filed before the Delhi Bench, arising out of multiple ITAs spanning Assessment Years 2008-09 and 2009-10. Per the source preview, the applications were procedural in nature; no substantive finding on the merits is disclosed in the available preview.

6. Corbett Nature Reserve,Ramnagar vs Income Tax Officer, Ram Nagar

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 28 July 2026
Sections engaged: Sections not specified
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee, a partnership firm running a resort at Ramnagar, Nainital, filed this appeal against the order of the CIT(A) in Appeal No. NFAC/2020-21/10455737 dated 25.08.2025 for Assessment Year 2021-22. Per the source preview, a deduction of Rs.13,57,365/- sought by the assessee under Section 80IC of the Income-tax Act was disallowed through an intimation dated 03.09.2021 on account of belated filing of Form 10CCB, despite the assessee's Chartered Accountant having already submitted the audited form. Note: "Section 80IC" appears in the text_preview of this case; the CASE_FACTS sections_list for this case is empty, so researchers should verify the precise section reference against the full order.

7. Luminous Power Technologies Pvt vs Addl. CIT, Special Range- 05, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 22 July 2026
Sections engaged: 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal involved ITA Nos. 6996/Del/2017, 6084/Del/2018, 8768/Del/2019, and ITA No. 608/Del/2021, covering Assessment Years 2013-14 to 2016-17. The source preview discloses detailed tabular data concerning the characterisation and useful life of various advertisement and marketing expenditures — including road-show vehicles, wall campaigns, dealer boards, market-research fees, and exhibition expenses — suggesting the core issue related to the classification and allowability of such expenditure in the context of the sections engaged.

8. Dy. Commissioner Of Income Tax, Subhash vs Alf Engineering Company, Sidcul

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 3 July 2026
Sections engaged: 301C, 8(ix), 801C, 801C(4), 801C(4)(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a batch of four Revenue appeals — ITA Nos. 225, 226, 231 & 232/DDN/2026 — for Assessment Years 2009-10 to 2012-13, all arising from orders dated 28.02.2026 passed by the CIT(A)-NFAC. The Tribunal noted that the issues in all four appeals were interconnected and common, and disposed of them through a single order, taking ITA No.225/DDN/2026 (AY 2009-10) as the lead case. Note: the sections cited in the source data for this case use non-standard formatting identifiers (e.g., "301C", "801C", "8(ix)"); researchers should verify the precise section references against the full order text to confirm the corresponding standard Income-tax Act provision numbers.

9. Pr Commissioner Of Income Tax Central 1 vs Macelods Pharmaceuticals Limited Ay

Bench: Bombay High Court
Date: 3 July 2026
Sections engaged: 35
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed Income Tax Appeal No. 267 of 2024 before the Bombay High Court, challenging an ITAT Mumbai Bench order dated 31 January 2023 which had rejected the Revenue's appeal against the CIT(A) order dated 27 June 2018, for Assessment Year 2012-13. The High Court observed that there was no case made out on behalf of the Revenue and that the question of law proposed to be urged was "quite illusory," per the source preview.

10. Dcm Shriram Limited,New Delhi vs The Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 3 July 2026
Sections engaged: 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed IT(TP)A No.35/Del./2025 against the final assessment order for Assessment Year 2022-23. The source preview discloses a transfer-pricing dispute concerning the rate at which power was transferred by the assessee (at Rs.7.33 per KWh) versus the rate adopted by the Transfer Pricing Officer (Rs.5.72 per KWh), resulting in an addition of Rs.1,31,28,53,044/- on account of the difference of Rs.1.61 per KWh across 81,54,36,673 KWh of power transferred.

11. The Principal Commissioner Of Income vs Montecarlo Construction Ltd

Bench: Gujarat High Court
Date: 1 July 2026
Sections engaged: 260A
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed R/Tax Appeal No. 269 of 2025 before the Gujarat High Court, challenging the ITAT order dated 27.09.2024. The source preview indicates the dispute concerned road construction and infrastructure development work, with reference to packages involving rehabilitation, road widening, upgradation, and strengthening of state highways; the Revenue sought to frame substantial questions of law arising from the ITAT's findings.

12. Imperial Jewels,Mumbai vs DCIT-24(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 June 2026
Sections engaged: 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed ITA No.5941/MUM/2025 against the order dated 29.08.2025 passed by NFAC, Delhi for Assessment Year 2022-23. The assessee is a unit located at Unit No.72, SDF III, SEEPZ SEZ, Andheri (East), Mumbai; the substantive grounds are not further disclosed in the available source preview beyond the procedural filing details.

Patterns across these 12 rulings

Quantum vs. book-profit disputes in infrastructure deductions. In at least two matters (Baramati Agro Limited and Cicago Commodities), the central contest visible from the source data concerns the quantum of deduction claimed versus what the Assessing Officer or CIT(A) permitted, with the gap between profit as per books and the claimed deduction amount forming the axis of the dispute. This is a recurring structural tension in profit-linked deduction litigation.
Procedural disallowance due to belated filing of statutory forms. The Corbett Nature Reserve matter illustrates a pattern where substantively eligible deductions are disallowed at the intimation or assessment stage solely because the required audit form was uploaded after the prescribed date, even where the audited form had in fact been filed. This procedural trigger for disallowance appears across the broader profit-linked deduction landscape and is well-represented in recent filings.
Condonation of delay as a threshold issue. The Mojika Real Estate matter demonstrates that procedural gating — specifically, whether a 372-day delay in filing the appeal should be condoned — can consume the first layer of adjudication entirely, before any substantive deduction question is reached. Service of orders to outdated or former-employee email IDs in the faceless regime is an emerging procedural concern visible in this data set.
Revenue-initiated High Court appeals on infrastructure and project deductions. Both Montecarlo Construction (Gujarat HC) and Macelods Pharmaceuticals (Bombay HC) involve Revenue appeals to the High Court, suggesting a pattern of the Revenue escalating infrastructure and profit-linked deduction matters to the High Court tier after adverse ITAT orders. In the Macelods matter, the High Court found the proposed question of law to be "quite illusory" per the source preview.
Batch disposal of interconnected assessment years. The ALF Engineering Company batch (four appeals, AY 2009-10 to 2012-13) and the Vedanta Limited stay applications (six applications across multiple AYs) illustrate a consistent practice of the Tribunal consolidating factually linked or legally common matters across multiple assessment years into a single order, which has implications for how researchers should locate and read the operative findings.

How to use this compilation

This index is a navigational aid. Each entry provides the identity fields needed to locate the full order — bench, ITA or appeal number (where visible in the source preview), assessment year, and date of pronouncement. Researchers should use these identifiers to retrieve the complete order from the ITAT's official e-filing portal (ITAT.gov.in), the relevant High Court's portal, or indiankanoon.org before drawing any conclusions about the legal position. The source previews reproduced here are necessarily excerpts; operative findings, detailed reasoning, and the specific grounds disposed of will only be visible in the full text.

Before relying on any ruling in this compilation, researchers should verify: (a) whether the order has been appealed to a higher forum and whether any stay has been granted; (b) whether a subsequent CBDT circular or instruction addresses the same issue; and (c) the assessment year and factual matrix of the ruling against the facts of the matter under research, since profit-linked deduction outcomes are highly fact-specific. A ruling favourable to the assessee on audit-form timing in one assessment year does not bind the outcome for a different assessee in a different year without examining whether the underlying facts and procedural history are comparable.

For transfer-pricing matters appearing in this compilation (such as DCM Shriram and Luminous Power Technologies), researchers should additionally check for any Advance Pricing Agreement (APA) or Safe Harbour Rule development that may affect the comparable analysis, and for any ITAT Special Bench or High Court pronouncement that may have modified the applicable arm's-length standard in the intervening period. Several cases in this compilation also feature non-standard section identifiers in the source data; in all such instances, researchers should treat the section references in this index as a starting point only and verify precise provision numbers against the full order text.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 80I/80IA/80IC Income Tax Deduction: 12 Recent ITAT and HC Rulings (2026)