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M/s. FCA Engineering India Private Limited, (Formerly known as Chrysler India Automotive Private Limited), RMZ Millennia Business Park-1, Chennai v/s Assistant Commissioner of Income Tax, Corporate Circle 1(2), Chennai & Another


Company & Directors' Information:- M & B ENGINEERING LIMITED [Active] CIN = U45200GJ1981PLC004437

Company & Directors' Information:- J J AUTOMOTIVE LTD [Active] CIN = L34103WB1981PLC033996

Company & Directors' Information:- G. R. ENGINEERING PRIVATE LIMITED [Active] CIN = U65990MH1990PTC058602

Company & Directors' Information:- G G ENGINEERING LIMITED [Active] CIN = L28900MH2006PLC159174

Company & Directors' Information:- V U B ENGINEERING PRIVATE LIMITED [Active] CIN = U29290MH2005PTC154033

Company & Directors' Information:- N S ENGINEERING COMPANY PVT LTD [Active] CIN = U29219TG1989PTC010511

Company & Directors' Information:- S S S ENGINEERING COMPANY PRIVATE LIMITED [Strike Off] CIN = U27205KA1981PTC004194

Company & Directors' Information:- J. H. BUSINESS (INDIA) LIMITED [Amalgamated] CIN = U24293DL1999PLC099782

Company & Directors' Information:- H M G ENGINEERING LIMITED [Active] CIN = U45200MH1977PLC019533

Company & Directors' Information:- K R R ENGINEERING PRIVATE LIMITED [Active] CIN = U29309TN1989PTC016852

Company & Directors' Information:- G G ENGINEERING LIMITED [Active] CIN = U28900MH2006PLC159174

Company & Directors' Information:- D B ENGINEERING PRIVATE LTD [Active] CIN = U74899DL1986PTC026541

Company & Directors' Information:- G G ENGINEERING PRIVATE LIMITED [Active] CIN = U28900MH2006PTC159174

Company & Directors' Information:- J P ENGINEERING CORPN PVT LTD [Active] CIN = U34103WB1951PTC019638

Company & Directors' Information:- S N B ENGINEERING PRIVATE LIMITED [Active] CIN = U27106DL2007PTC301213

Company & Directors' Information:- S C L AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U35900TN2009PTC072343

Company & Directors' Information:- P P AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U35999HR2009PTC039808

Company & Directors' Information:- T P W ENGINEERING LTD [Active] CIN = U27203WB1975PLC029939

Company & Directors' Information:- C L ENGINEERING PRIVATE LIMITED [Active] CIN = U34300PB1992PTC012057

Company & Directors' Information:- G B BUSINESS LIMITED [Active] CIN = U51109WB1983PLC036744

Company & Directors' Information:- R P BUSINESS PRIVATE LIMITED [Active] CIN = U74210AS2000PTC006302

Company & Directors' Information:- AUTOMOTIVE CORPN OF INDIA LTD [Strike Off] CIN = U15422MH1974PLC017377

Company & Directors' Information:- W & W ENGINEERING PRIVATE LIMITED [Active] CIN = U72900TN2003PTC051228

Company & Directors' Information:- M L R ENGINEERING PRIVATE LIMITED [Active] CIN = U74999TG2006PTC051974

Company & Directors' Information:- S N M BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1997PTC085308

Company & Directors' Information:- P R S BUSINESS PVT LTD [Active] CIN = U63090WB1992PTC056995

Company & Directors' Information:- K B ENGINEERING CO PVT LTD [Active] CIN = U74160TG1988PTC008366

Company & Directors' Information:- R P ENGINEERING PVT LTD [Active] CIN = U29299WB1992PTC055482

Company & Directors' Information:- CHENNAI BUSINESS PARK PRIVATE LIMITED [Active] CIN = U70101TN2005PTC057008

Company & Directors' Information:- G N AUTOMOTIVE PRIVATE LIMITED [Strike Off] CIN = U50102MH2010PTC201448

Company & Directors' Information:- J & K ENGINEERING LIMITED [Active] CIN = U45203JK2006PLC002684

Company & Directors' Information:- G. H. AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U34300DL2007PTC161956

Company & Directors' Information:- S P T ENGINEERING PRIVATE LIMITED [Converted to LLP] CIN = U27109UP2005PTC030940

Company & Directors' Information:- M L B BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB2000PTC091878

Company & Directors' Information:- A R F ENGINEERING LIMITED [Active] CIN = U27200TN1980PLC008347

Company & Directors' Information:- J F C BUSINESS LTD [Active] CIN = U17125WB1990PLC048495

Company & Directors' Information:- A M ENGINEERING PRIVATE LIMITED [Amalgamated] CIN = U65910MH1981PTC187856

Company & Directors' Information:- S. S. E. ENGINEERING PRIVATE LIMITED [Active] CIN = U36990MH2007PTC175320

Company & Directors' Information:- C T ENGINEERING LIMITED [Strike Off] CIN = U29259GJ1986PLC009007

Company & Directors' Information:- A TO Z BUSINESS (INDIA) PRIVATE LIMITED [Under Process of Striking Off] CIN = U51909TZ2008PTC014261

Company & Directors' Information:- S V BUSINESS PVT LTD [Active] CIN = U27310WB1984PTC038146

Company & Directors' Information:- C V AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U63011DL2009PTC189646

Company & Directors' Information:- R AND S ENGINEERING INDIA PVT LTD [Active] CIN = U29199GJ1995PTC027661

Company & Directors' Information:- R R BUSINESS PRIVATE LIMITED [Active] CIN = U74999WB2007PTC176588

Company & Directors' Information:- U AND R ENGINEERING PRIVATE LIMITED [Active] CIN = U29199TZ1999PTC009012

Company & Directors' Information:- M R BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1994PTC064165

Company & Directors' Information:- I Q ENGINEERING (INDIA) PRIVATE LIMITED [Active] CIN = U85110KA1996PTC021507

Company & Directors' Information:- G M ENGINEERING PRIVATE LIMITED [Active] CIN = U28910GJ2013PTC077091

Company & Directors' Information:- W. E. ENGINEERING PVT. LTD. [Active] CIN = U52335WB1985PTC039370

Company & Directors' Information:- CORPORATE INDIA PRIVATE LIMITED [Active] CIN = U74110DL1999PTC099505

Company & Directors' Information:- K J AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U50401PN2013PTC146058

Company & Directors' Information:- L. B. ENGINEERING PRIVATE LIMITED [Active] CIN = U74999WB2018PTC225084

Company & Directors' Information:- R I ENGINEERING (INDIA) PRIVATE LIMITED [Active] CIN = U74210KA1991PTC012420

Company & Directors' Information:- J C BUSINESS PRIVATE LIMITED [Active] CIN = U55101AS2009PTC008974

Company & Directors' Information:- U D ENGINEERING PRIVATE LIMITED [Active] CIN = U32109DL1999PTC102586

Company & Directors' Information:- RMZ BUSINESS PARK (INDIA) PRIVATE LIMITED [Active] CIN = U45202KA2007PTC043472

Company & Directors' Information:- D & B BUSINESS PRIVATE LIMITED [Active] CIN = U51909PB2010PTC033901

Company & Directors' Information:- K M T S ENGINEERING PRIVATE LIMITED [Active] CIN = U29192DL2005PTC141240

Company & Directors' Information:- C A G ENGINEERING LIMITED [Active] CIN = U00350PB2006PLC029521

Company & Directors' Information:- C A G ENGINEERING LIMITED [Active] CIN = U29110PB2006PLC029521

Company & Directors' Information:- D ENGINEERING PRIVATE LIMITED [Active] CIN = U29269TZ1932PTC000046

Company & Directors' Information:- V K B ENGINEERING PRIVATE LIMITED [Active] CIN = U74899DL2005PTC141483

Company & Directors' Information:- J D V AUTOMOTIVE ENGINEERING PVT LTD [Active] CIN = U31909MH1982PTC028905

Company & Directors' Information:- INDIA ENGINEERING PRIVATE LIMITED [Active] CIN = U72200PN1999PTC014259

Company & Directors' Information:- C N C ENGINEERING LIMITED [Strike Off] CIN = U93000KA1986PLC007922

Company & Directors' Information:- P N S BUSINESS PRIVATE LIMITED [Active] CIN = U74140WB2005PTC101643

Company & Directors' Information:- M K V ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29199TZ1997PTC007736

Company & Directors' Information:- D M AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U29253HR2012PTC045797

Company & Directors' Information:- G V T ENGINEERING (INDIA) PRIVATE LIMITED [Active] CIN = U29219DL1996PTC082427

Company & Directors' Information:- K. I. ENGINEERING PRIVATE LIMITED [Active] CIN = U74999WB2009PTC133109

Company & Directors' Information:- G M E P ENGINEERING PRIVATE LIMITED [Active] CIN = U29192DL1998PTC096737

Company & Directors' Information:- J T ENGINEERING PRIVATE LIMITED [Active] CIN = U74899DL1984PTC018756

Company & Directors' Information:- M S BUSINESS PRIVATE LIMITED [Active] CIN = U51909MH1997PTC111137

Company & Directors' Information:- T K W AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U34300DL2005PTC137031

Company & Directors' Information:- M C ENGINEERING CO PVT LTD [Active] CIN = U74899DL1972PTC006392

Company & Directors' Information:- J S B BUSINESS PVT LTD [Active] CIN = U27109WB1996PTC078319

Company & Directors' Information:- M. L. G. BUSINESS PRIVATE LIMITED [Active] CIN = U51101UP2010PTC040398

Company & Directors' Information:- L G K AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U34300AS2001PTC006713

Company & Directors' Information:- C P ENGINEERING (INDIA) PRIVATE LIMITED [Active] CIN = U27209TN1987PTC014052

Company & Directors' Information:- L K AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U34300GJ2011PTC066118

Company & Directors' Information:- J B L ENGINEERING PRIVATE LIMITED [Active] CIN = U28112MP2008PTC021459

Company & Directors' Information:- H V S ENGINEERING PRIVATE LIMITED [Active] CIN = U28920MH2005PTC158342

Company & Directors' Information:- S C ENGINEERING CO PVT LTD [Active] CIN = U74210WB1982PTC035623

Company & Directors' Information:- A V S BUSINESS PRIVATE LIMITED [Strike Off] CIN = U31908UP2010PTC040437

Company & Directors' Information:- U M ENGINEERING PRIVATE LIMITED [Active] CIN = U29200MH1977PTC019574

Company & Directors' Information:- A V K ENGINEERING PRIVATE LIMITED [Active] CIN = U74899DL1995PTC071971

Company & Directors' Information:- S K ENGINEERING CO PRIVATE LIMITED [Strike Off] CIN = U05001UP1952PTC002408

Company & Directors' Information:- G D ENGINEERING COMPANY (INDIA) PVT LTD [Active] CIN = U74210WB1993PTC058553

Company & Directors' Information:- V M R ENGINEERING PRIVATE LIMITED [Active] CIN = U29120DL2005PTC136764

Company & Directors' Information:- K. S. I. ENGINEERING PRIVATE LIMITED [Active] CIN = U36999HR2007PTC036660

Company & Directors' Information:- N S S ENGINEERING PRIVATE LIMITED [Active] CIN = U28999KA1989PTC010312

Company & Directors' Information:- A P V ENGINEERING CO LTD [Strike Off] CIN = U29113WB1945PLC006428

Company & Directors' Information:- G B ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29212PB1996PTC017500

Company & Directors' Information:- C M S ENGINEERING INDIA PRIVATE LIMITED [Strike Off] CIN = U74210TN2010PTC075302

Company & Directors' Information:- A C BUSINESS PRIVATE LIMITED [Strike Off] CIN = U45208MH2009PTC197088

Company & Directors' Information:- J K B ENGINEERING COMPANY PRIVATE LIMITED [Strike Off] CIN = U31300TN1996PTC036482

Company & Directors' Information:- T S C ENGINEERING PRIVATE LIMITED [Active] CIN = U70109DL2011PTC217251

Company & Directors' Information:- H T S ENGINEERING PRIVATE LIMITED [Active] CIN = U74999MH2008PTC187914

Company & Directors' Information:- T P ENGINEERING PRIVATE LIMITED [Active] CIN = U45201OR2010PTC011517

Company & Directors' Information:- V K BUSINESS PVT LTD [Active] CIN = U21012WB1996PTC079121

Company & Directors' Information:- S B ENGINEERING PVT LTD [Active] CIN = U29199GJ1982PTC005292

Company & Directors' Information:- J J ENGINEERING PVT LTD [Active] CIN = U29219WB1986PTC041433

Company & Directors' Information:- D & L ENGINEERING PRIVATE LIMITED [Converted to LLP] CIN = U29113TN2004PTC052690

Company & Directors' Information:- U N D B ENGINEERING BUSINESS PVT LTD [Strike Off] CIN = U35204WB1991PTC051622

Company & Directors' Information:- H R P ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U31503MH1997PTC108621

Company & Directors' Information:- S H ENGINEERING PRIVATE LIMITED [Active] CIN = U70101WB1999PTC088930

Company & Directors' Information:- V K S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U28133TN2005PTC057283

Company & Directors' Information:- M K ENGINEERING PVT LTD [Active] CIN = U29199GJ1995PTC027278

Company & Directors' Information:- S P A BUSINESS PVT LTD [Strike Off] CIN = U29296WB1990PTC050043

Company & Directors' Information:- K J ENGINEERING PRIVATE LIMITED [Active] CIN = U29299PN2006PTC129171

Company & Directors' Information:- C S S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45302TN2003PTC051161

Company & Directors' Information:- A D BUSINESS PRIVATE LIMITED [Active] CIN = U74900MH2008PTC178245

Company & Directors' Information:- A V R BUSINESS PRIVATE LIMITED [Active] CIN = U74992UP2008PTC034629

Company & Directors' Information:- N. P. ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U31100WB2010PTC150609

Company & Directors' Information:- S R K ENGINEERING CO PVT LTD [Active] CIN = U67120WB1994PTC063442

Company & Directors' Information:- C K BUSINESS PRIVATE LIMITED [Under Process of Striking Off] CIN = U51399DL2003PTC118289

Company & Directors' Information:- C AND D BUSINESS INDIA PRIVATE LIMITED [Strike Off] CIN = U52300KA2010PTC053211

Company & Directors' Information:- M P T ENGINEERING PVT LTD [Strike Off] CIN = U29299KL1994PTC007761

Company & Directors' Information:- T S R C ENGINEERING PRIVATE LIMITED [Active] CIN = U29100UP2020PTC133920

Company & Directors' Information:- C S ENGINEERING INDIA PRIVATE LIMITED [Active] CIN = U28110MH2021PTC361962

Company & Directors' Information:- A K ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U50300UP1981PTC005354

Company & Directors' Information:- K B BUSINESS PARK PRIVATE LIMITED [Strike Off] CIN = U55101MH1998PTC114489

Company & Directors' Information:- H M T D ENGINEERING PVT LTD [Active] CIN = U99999MH1981PTC035175

Company & Directors' Information:- J P ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U28129MH1972PTC015813

Company & Directors' Information:- V M ENGINEERING COMPANY PRIVATE LIMITED [Active] CIN = U28920MH1969PTC014224

Company & Directors' Information:- H M A ENGINEERING LIMITED [Strike Off] CIN = U45209PB2008PLC031777

Company & Directors' Information:- P T S ENGINEERING INDIA PRIVATE LIMITED [Active] CIN = U74210TZ2011PTC016944

Company & Directors' Information:- K S M ENGINEERING PRIVATE LIMITED [Active] CIN = U74210TG1997PTC028612

Company & Directors' Information:- M M ENGINEERING COMPANY PRIVATE LIMITED [Converted to LLP] CIN = U28932MH1979PTC021819

Company & Directors' Information:- N G T ENGINEERING PVT LTD [Active] CIN = U27109WB1968PTC027292

Company & Directors' Information:- M A S ENGINEERING PRIVATE LIMITED [Active] CIN = U99999MH1976PTC019233

Company & Directors' Information:- J N AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U50102AS2014PTC011838

Company & Directors' Information:- G R K ENGINEERING (INDIA) PRIVATE LIMITED [Active] CIN = U74200AP2011PTC076356

Company & Directors' Information:- P N S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29120TN2006PTC060120

Company & Directors' Information:- A S A AUTOMOTIVE PVT LTD [Strike Off] CIN = U51109WB1991PTC052174

Company & Directors' Information:- K P ENGINEERING CORPORATION PVT LTD [Strike Off] CIN = U74200WB1961PTC025258

Company & Directors' Information:- M A N INDIA ENGINEERING LTD [Strike Off] CIN = U74200WB1979PLC020893

Company & Directors' Information:- BUSINESS CORPN PRIVATE LIMITED [Strike Off] CIN = U15429UP1945PTC001335

Company & Directors' Information:- R V K ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29253TN2010PTC074505

Company & Directors' Information:- R K ENGINEERING COMPANY PVT LTD [Active] CIN = U74899DL1975PTC007743

Company & Directors' Information:- G S A ENGINEERING CORPN PVT LTD [Strike Off] CIN = U74210WB1957PTC023382

Company & Directors' Information:- A R M ENGINEERING PRIVATE LIMITED. [Strike Off] CIN = U00500JH1988PTC003057

Company & Directors' Information:- L & V ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45202MZ2005PTC007690

Company & Directors' Information:- S G A ENGINEERING COMPANY PRIVATE LIMITED [Strike Off] CIN = U29200MH2005PTC154349

Company & Directors' Information:- C P C ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29120TZ1986PTC001880

Company & Directors' Information:- P K R ENGINEERING INDIA PRIVATE LIMITED [Strike Off] CIN = U29130TZ2004PTC011094

Company & Directors' Information:- M N B ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U70101TN2005PTC057442

Company & Directors' Information:- FCA ENGINEERING INDIA PRIVATE LIMITED [Active] CIN = U29253TN2007PTC064974

Company & Directors' Information:- M M BUSINESS PVT LTD [Strike Off] CIN = U51909WB2005PTC106884

Company & Directors' Information:- L K BUSINESS PVT LTD [Active] CIN = U45202WB1985PTC038604

Company & Directors' Information:- R R K ENGINEERING PRIVATE LIMITED [Active] CIN = U74999WB2011PTC161080

Company & Directors' Information:- M S V ENGINEERING PRIVATE LIMITED [Active] CIN = U52399TG2020PTC147098

Company & Directors' Information:- D M S ENGINEERING CO PVT LTD [Strike Off] CIN = U28920WB1964PTC026168

Company & Directors' Information:- C R T ENGINEERING LIMITED [Strike Off] CIN = U32109DL1990PLC038842

Company & Directors' Information:- S D S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U28999PN2000PTC014838

Company & Directors' Information:- G B L ENGINEERING COMPANY PRIVATE LIMITED [Strike Off] CIN = U29130RJ1998PTC015182

Company & Directors' Information:- N T ENGINEERING COMPANY PVT LTD [Strike Off] CIN = U99999PY1986PTC000445

Company & Directors' Information:- R K ENGINEERING PRIVATE LIMITED [Active] CIN = U31100MH2005PTC152838

Company & Directors' Information:- V J S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29130TN1996PTC036636

Company & Directors' Information:- D R P AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U51101DL2014PTC267341

Company & Directors' Information:- R. K. V. ENGINEERING PRIVATE LIMITED [Active] CIN = U29253MH2010PTC205237

Company & Directors' Information:- U S ENGINEERING PVT LTD [Active] CIN = U34300CH1986PTC006887

Company & Directors' Information:- A D ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U74210OR1989PTC002348

Company & Directors' Information:- R J ENGINEERING COMPANY PRIVATE LIMITED [Active] CIN = U27107RJ1972PTC001441

Company & Directors' Information:- H F ENGINEERING PRIVATE LIMITED [Active] CIN = U29244KL2013PTC033909

Company & Directors' Information:- O N ENGINEERING PRIVATE LIMITED [Active] CIN = U74899DL1988PTC031987

Company & Directors' Information:- I D M ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29199KA1981PTC004517

Company & Directors' Information:- P S R ENGINEERING PVT LTD [Strike Off] CIN = U40200WB1987PTC042244

Company & Directors' Information:- P N ENGINEERING CO PVT LTD [Strike Off] CIN = U74210WB1980PTC032750

Company & Directors' Information:- C L BUSINESS PRIVATE LIMITED [Active] CIN = U93000WB2014PTC202032

Company & Directors' Information:- A M A R ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29219DL1997PTC084187

Company & Directors' Information:- S G D ENGINEERING PRIVATE LIMITED [Active] CIN = U29210KA2009PTC050452

Company & Directors' Information:- A. P. V. BUSINESS PRIVATE LIMITED [Strike Off] CIN = U14299RJ2017PTC058759

Company & Directors' Information:- G A S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29191MH2004PTC149606

Company & Directors' Information:- G T ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29219PN2012PTC145781

Company & Directors' Information:- M. M. K. ENGINEERING COMPANY PRIVATE LIMITED [Active] CIN = U29305MH2014PTC252830

Company & Directors' Information:- K-4 ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U31400MH2010PTC204004

Company & Directors' Information:- D S AUTOMOTIVE PRIVATE LIMITED [Strike Off] CIN = U50102MH2011PTC215763

Company & Directors' Information:- J V B BUSINESS PRIVATE LIMITED [Active] CIN = U74999MH2016PTC282145

Company & Directors' Information:- N J ENGINEERING PRIVATE LIMITED [Active] CIN = U45209MH2015PTC262607

Company & Directors' Information:- U & C BUSINESS CORPORATION PRIVATE LIMITED [Strike Off] CIN = U51909TG2014PTC095129

Company & Directors' Information:- P R S ENGINEERING PRIVATE LIMITED [Active] CIN = U29253TN2009PTC073915

Company & Directors' Information:- U P S ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U40300TN2013PTC090167

Company & Directors' Information:- A R M G BUSINESS PRIVATE LIMITED [Strike Off] CIN = U51909UP2013PTC055405

Company & Directors' Information:- V. E AUTOMOTIVE INDIA PRIVATE LIMITED [Active] CIN = U34200UP2012PTC054101

Company & Directors' Information:- U K BUSINESS PRIVATE LIMITED [Active] CIN = U74999UP2016PTC086597

Company & Directors' Information:- K G D ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45400WB2014PTC200732

Company & Directors' Information:- T A ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U28992CH2003PTC025800

Company & Directors' Information:- M N A ENGINEERING PVT LTD [Strike Off] CIN = U45202CH2006PTC030215

Company & Directors' Information:- A A P ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U27106DL2005PTC138318

Company & Directors' Information:- A C ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29253DL2011PTC222515

Company & Directors' Information:- S. Z. ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U29253DL2014PTC274095

Company & Directors' Information:- IN ENGINEERING PRIVATE LIMITED [Active] CIN = U74210DL2011PTC212284

Company & Directors' Information:- J N ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45400DL2015PTC278906

Company & Directors' Information:- N I ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45400DL2015PTC280734

Company & Directors' Information:- K. S. AUTOMOTIVE PRIVATE LIMITED [Active] CIN = U51502DL2007PTC163634

Company & Directors' Information:- A N D ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U51502DL2012PTC242516

Company & Directors' Information:- R R V ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U51909DL1997PTC089342

Company & Directors' Information:- Z. M. ENGINEERING PRIVATE LIMITED [Active] CIN = U51909DL2007PTC168270

Company & Directors' Information:- A 2 J BUSINESS PRIVATE LIMITED [Active] CIN = U51909DL2014PTC269045

Company & Directors' Information:- K Y ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U74999DL2013PTC248278

Company & Directors' Information:- R AND T ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U34300DL2005PTC136846

Company & Directors' Information:- J K AUTOMOTIVE PRIVATE LIMITED [Converted to LLP] CIN = U34300DL2011PTC218392

Company & Directors' Information:- THE ENGINEERING CORPORATION PRIVATE LIMITED [Strike Off] CIN = U99999KA1951PTC000699

Company & Directors' Information:- S J P ENGINEERING CO. PRIVATE LIMITED [Strike Off] CIN = U51505KA2002PTC030808

Company & Directors' Information:- D Y R ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U45205KA2014PTC075105

Company & Directors' Information:- T J ENGINEERING PRIVATE LIMITED [Active] CIN = U28999MH2021PTC353062

Company & Directors' Information:- S I ENGINEERING COMPANY PRIVATE LIMITED [Strike Off] CIN = U27109UP1967PTC003182

Company & Directors' Information:- W D ENGINEERING PRIVATE LIMITED [Active] CIN = U29308MH2020PTC345065

Company & Directors' Information:- S D ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U18101DL1999PTC102948

Company & Directors' Information:- M B D ENGINEERING PRIVATE LIMITED [Strike Off] CIN = U74210DL2008PTC181446

Company & Directors' Information:- A. B. C. ENGINEERING CORPORATION LIMITED [Not available for efiling] CIN = U99999MH1950PLC008192

Company & Directors' Information:-  ENGINEERING COMPANY ( [Not Available for eFiling] CIN = U99999MH1951PLC010002

Company & Directors' Information:- F M P ENGINEERING PVT LTD [Strike Off] CIN = U29259GJ1965PTC001337

    WP No. 27102 of 2016 & WMP No. 23283 of 2016

    Decided On, 02 August 2021

    At, High Court of Judicature at Madras

    By, THE HONOURABLE MR. JUSTICE S.M. SUBRAMANIAM

    For the Petitioner: N.V. Balaji, Advocate. For the Respondents: D. Prabhu Mukunth Arunkumar, Junior Standing Counsel for Income Tax.



Judgment Text


(Prayer: Writ Petition is filed under Article 226 of the Constitution of India, praying for the issuance of a Writ of Certiorari, calling for the records on the file of the first respondent and quash the impugned proceedings in AAGCA6907M/09-10 dated 18.07.2016 along with notice issued by the first respondent under Section 148 of the Income Tax Act, dated 03.03.2016.)

1. The order dated 18.07.2016, disposing of the objection filed by the Assessee for reopening of the assessment under Section 147 of the Income Tax Act, 1961, is under challenge in the present writ petition.

2. The petitioner is a Private Limited Company incorporated under the Companies Act, 1956 and is a wholly owned subsidiary of Chrysler Netherlands Distribution BV, a Company incorporated in Netherlands. The name of the petitioner-Company was changed to FCA Engineering India Private Limited from Chrysler India Automotive Private Limited with effect from 23.02.2015.

3. The petitioner, being set up as a 100% Export Oriented Unit (EOU) under the Software Technology Park Scheme of India (STPI), is engaged in the business of providing engineering and design services to its group companies and is eligible for deduction under Section 10A of the Income Tax Act.

4. The petitioner filed its return of income for the assessment year 2009-2010 on 30.09.2009. Notice under Section 143(2) of the Income Tax Act, was initiated for scrutiny procedures on 30.09.2010. A reference was made under Section 92CA of the Income Tax Act, to the Transfer Pricing Officer (TPO) for determining arm’s length price on 19.05.2011. The Transfer Pricing Officer passed an order on 09.01.2013. Considering all the materials available on record, the Assessing Officer passed final assessment order on 28.02.2013.

5. A notice under Section 148 of the Income Tax Act, was issued for reopening of the assessment year 2009-2010. The petitioner confirmed the return of income already filed in response to the notice. Thereafter, the reasons for reopening was furnished to the Assessee in proceedings dated 21.04.2016. The petitioner submitted its detailed objections vide letter dated 17.05.2016 and the said objections were rejected by the first respondent in order dated 18.07.2016.

6. The learned counsel for the petitioner mainly contended that the very initiation of reopening proceedings is beyond the scope of jurisdiction and in respect of other assessment years, the benefit of Section 10A of the Income Tax Act, was extended in favour of the petitioner.

7. This apart, the reasons furnished are not in consonance with the mandatory requirements as contemplated under Section 147 of the Income Tax Act, 1961. The reasons stated for reopening of assessment is nothing but change of opinion, as the issues raised were adjudicated in the original assessment proceedings and considered by the Assessing Authority. The reopening is made beyond the period of four years and within six years and therefore, the requirements as contemplated under the proviso clause to Section 147 of the Income Tax Act, are to be complied with. Thus, the initiation itself is without jurisdiction.

8. The learned counsel for the petitioner to substantiate the said contention, drawn the attention of this Court with reference to the spirit of Section 10A of the Income Tax Act. It is contended that as per Section 10A sub-section (2), the petitioner is entitled for the benefit of the said provision and it was rightly considered by the Assessing Authority and therefore, the very same ground cannot be a reason for reopening of assessment under Section 147 of the Income Tax Act.

9. In view of the fact that the issue was considered elaborately and the reopening is made beyond four years and the very same reason is furnished for the purpose of reopening, it is to be construed that the proceedings are nothing but change of opinion and not based on any tangible materials available on record.

10. The learned counsel for the petitioner relied on the instruction No.1 of 2006 dated 31.03.2006 issued by the Central Board of Direct Taxes (CBDT), wherein the deduction under Section 10A of the Income Tax Act was clarified. As per the said clarification, the petitioner-Company is entitled for the benefit and it was rightly granted by the Assessing Authority originally. While-so, the very reason for reopening is untenable based on the instructions issued by the Central Board of Direct Taxes. Therefore, the present writ petition is to be allowed.

11. The learned Standing Counsel, appearing on behalf of the respondents, disputed the contentions raised on behalf of the petitioner by stating that the petitioner has not fully and truly disclosed the informations as required under the provisions of the Income Tax Act. Under Section 10A of the Income Tax Act, the Company must be in any one of the declared Special Economic Zone.

12. However, even in the details relating to the claim by the exporter for deduction Section 10A of the Income Tax Act, i.e., Form No.56-F, the Assessee has not stated about their location of functioning and the said Form categorically indicates that the Assessee must mention the location and address of undertaking in the Form enclosed by the petitioner itself. In page No.33 of the typed set of papers filed along with the present writ petition, the petitioner-Company has mentioned the address alone and the location has not been stated and this apart, the respondents have stated that the petitioner-Company is not functioning in any one of the Special Economic Zone and therefore, they are not entitled for the benefit of Section 10A of the Income Tax Act.

13. The learned Standing Counsel, appearing on behalf of the respondents, contended that even in such cases, it is for the Assessee to submit all materials and evidences to establish his case and such an adjudication need not be done in the present writ proceedings by the High Court. It is only initiation of proceedings, which is under challenge and therefore, the merits are to be adjudicated by the Assessing Authority and the petitioner-Company is at liberty to avail the opportunities to be provided for the purpose of establishing their case. Thus, the writ petitioner-Company has not established any prima facie grounds for the purpose of assailing the institution of proceedings under Section 147/148 of the Income Tax Act and therefore, the present writ petition is to be rejected.

14. Considering the arguments as advanced by the respective learned counsel appearing on behalf of the parties to the lis, the issue mainly raised in this writ petition is, whether the petitioner-Assessee is eligible to claim the benefit under Section 10A of the Income Tax Act. The point of jurisdiction raised is relating to Section 10A of the Income Tax Act. The reasons for reopening is also connected with the said provision. Thus, the interpretation of the said provision is required for the purpose of deciding the issue raised in this writ petition.

15. Let us consider Section 10A of the Income Tax Act. Sub-section (1) enumerates that “subject to the provisions of this section, a deduction of such profits and gains as are derived by an undertaking from the export of articles or things or computer software for a period of ten consecutive assessment years beginning with the assessment year relevant to the previous year in which the undertaking begins to manufacture or produce such articles or things or computer software, as the case may be, shall be allowed from the total income of the Assessee.

16. Sub-section (2) is relatable to the facts and circumstances of the case on hand. Sub-section (2) of Section 10A of the Income Tax Act, reads as under:-

'This section applies to any undertaking which fulfils all the following conditions, namely:

(i) it has begun or begins to manufacture or produce articles or things or computer software during the previous year relevant to the assessment year

(a) commencing on or after the 1st day of April, 1981, in any free trade zone; or

(b) commencing on or after the 1st day of April, 1994, in any electronic hardware technology park, or, as the case may be, software technology park;

(c) commencing on or after the 1st day of April, 2001 in any special economic zone;

(ii) it is not formed by the splitting up, or the reconstruction, of a business already in existence :

Provided that this condition shall not apply in respect of any undertaking which is formed as a result of the re-establishment, reconstruction or revival by the assessee of the business of any such undertakings as is referred to in section 33B, in the circumstances and within the period specified in that section;

(iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose.

Explanation.—The provisions of Explanation 1 and Explanation 2 to sub-section (2) of section 80-I shall apply for the purposes of clause (iii) of this sub-section as they apply for the purposes of clause (ii) of that sub-section'.

17. Sub-section (2) begins by contemplating that the said Section would apply to any undertaking which fulfils all the conditions stipulated in sub-section (2) to sub-clause (i). Sub-clause (i)(a) to (c). Sub-clause (i) (a) to sub-section (2) unambiguously enumerates that it has begun or begins to manufacture or produce articles or things or computer software during the previous year relevant to the assessment year, commencing on or after the first day of April, 1981, in any free trade zone. Therefore, if the commencement of manufacture or produce articles or things or computer software, on or after the 1st day of April, 1981 in any free trade zone. Sub-clause (i) (a) contemplates that the manufacture must be in any free trade zone. Secondly sub-clause (i)(b) to sub-section (2) stipulates that commencing on or after the first day of April, 1994, in any electronic hardware technology park, or, as the case may be, software technology park. Thus, if the commencement of manufacture or produce articles or things or computer software, on or after the first day of April, 1981, in any electronic hardware technology park or as the case may be, software technology park.

18. Therefore, the case of the petitioner falls under sub-clause (i)(b) of Section 10A of the Income Tax Act. They are manufacturing in the software technology. The said factum is not disputed by the Revenue also. Therefore, they claim commencing on or after the 1st day of April 1994. If commencement of manufacture is in software technology park, then the benefit under Section 10A of the Act is to be extended is also the arguments advanced.

19. Sub-clause (i)(c) denotes commencement of manufacture on or after the first day of April, 2001 in any special economic zone. Therefore, if any manufacture begins on or after the first day of April, 2001, it must be in any Special Economic Zone.

20. To make the interpretation more clear, commencement of manufacturing after 01.04.1981 in any free trade zone or commencement of manufacture on or after 01.04.1994 in any electronic hardware technology park or in between sub-clauses (i)(b) and (i)(c), the word ‘or’ is not contemplated. Therefore, clause(c) is independent and clauses (a) and (b) are connected to each other. Clauses (a) and (b) are to be read together for the purpose of determining the eligibility and clause (c) is to be interpreted independently for the purpose of considering eligibility to grant the benefit of Section 10A of the Income Tax Act. Because clause (a) ends with the option or in between clauses (b) and (c), there is no such option is provided. Thus, the commencement of manufacturing on or after 01.04.2001 must be in any Special Economic Zone. Moreover, the same is also not contemplated. Therefore, sub-clause (i)(c) must be interpreted that commencement of manufacture on or after the first day of April, 2001 must be in any Special Economic Zone.

21. Beyond the scope of interpretation, yet another aspect is to be considered with reference to these three clauses. Sub-section (2) of Section 10A of the Income Tax Act, unambiguously stipulates that this section applies to any undertaking which fulfils all the following conditions. Therefore, all the three conditions stipulated in sub-section (2) of Section 10A of the Act, is to be fulfilled.

22. As far as sub-clauses (i)(a), (i)(b) and (i)(c) to sub-section (2) are concerned, it is to be understood that different spells are contemplated in order to determine the eligibility. The three spells indicate that commencement of manufacture from 01.04.1981, which would impliedly end on 31.03.1994 and commencement of manufacture on or after 01.04.1994 and impliedly ends on 31.03.2001. Thereafter, sub-clause (i)(c) states that the manufacture commencing on or after 01.04.2001.

23. This apart, all three sub-clauses (a), (b) and (c) contemplate different Zones. If a case is falling under sub-clause (a), it must be in any free trade zone. If it is falling under clause (b), it must be in any electronic hardware technology park, or, as the case may be, software technology Park. If any Company falls under sub-clause (c), then it must be in any Special Economic Zone.

24. The case of the petitioner, admittedly, that the manufacture was commenced in the year 2008. When the manufacture or produce articles or things or computer software commences in the year 2008, then the case of the petitioner squarely falls under sub-clause (i)(c) to sub-section (2) of Section 10A of the Income Tax Act. Therefore, the petitioner must manufacture in any Special Economic Zone as the manufacture, admittedly, commenced in the year 2008. The petitioner is not entitled to claim the benefit under sub-clause (i)(b) software not manufacturing prior to 2001, so as to claim the benefit of Section 10A of the Income Tax Act on the ground that they are manufacturing any software technology park.

25. The scope of above provisions would unambiguously portrays that the case of the petitioner is falling under Section 10A of sub-section (2) to sub-clause (i)(c) of the Income

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Tax Act, and therefore, if the petitioner is manufacturing or producing articles or things of computer software, it must be in any Special Economic Zone. The Form 56-F submitted by the petitioner would reveal that they are not mentioned about their location of functioning. However, they have furnished their address and the respondents have filed counter stating that the Unit is not located in Special Economic Zone. 26. This being the factum established, the petitioner-Company is not entitled to avail the benefit of Section 10A of the Income Tax Act and if at all any contra materials are available with the petitioner, it is for them to place it before the Assessing Authority for the purpose of availing the benefit for which they are entitled under the provisions of the Income Tax Act. However, the adjudication in this writ petition is done with reference to the interpretations to be considered for the purpose of availing the benefit of Section 10A of the Income Tax Act and regarding all other factual disputes, it is for the Assessee to pursue the same before the Assessing Authority for the purpose of completion of reassessment proceedings. If at all the writ petitioner-Company has already claimed the benefit and in order to establish the said claim, the writ petitioner is at liberty to submit the documents and materials at the time of participating in the reassessment proceedings. 27. With the above observations, the writ petition stands dismissed. However, there shall be no order as to costs. Consequently, connected miscellaneous petition is also dismissed.
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