ITAT Sets Aside AY 2023-24 Order for Fresh Assessment of Gufic Biosciences
Court / Authority
CBDT (Income Tax)
Update / Judgement Date
04 Nov 2026
Case No.
Reference No. ITA No. 7885/MUM/2025 and CO No. 30/MUM/2026
Source
WCP News Bulletin
Author
Soumya Gupta — WCP Legal Desk
Reading Time
2 min read
View Count
2
• On March 18, 2025, an assessment order under Section 143(3) read with Section 144B of the Income Tax Act, 1961 was passed for AY 2023-24, creating an initial demand of Rs. 11,88,88,580/-.
• The company filed an appeal before the CIT(A), which granted substantial relief by scaling down the demand to Rs. 11,76,198/- while sustaining certain disallowances.
• The Income Tax Department filed an appeal before the ITAT challenging the relief granted by CIT(A), whereas Gufic Biosciences filed a cross-objection against the sustained disallowances.
• The ITAT pronounced its order on October 15, 2026, which was officially received by Gufic Biosciences Limited on November 04, 2026.
What Has Changed:
Issue Finding Outcome
Department Appeal (ITA No. 7885/MUM/2025) Challenged the tax relief granted to the company by CIT(A). Allowed for statistical purposes; set aside to AO for fresh assessment.
Company Cross-Objection (CO No. 30/MUM/2026) Challenged the disallowances sustained by CIT(A). Allowed for statistical purposes; restored to AO for re-adjudication.
Who Is Affected:
• Gufic Biosciences Limited and its tax compliance, legal, and finance management teams.
• Income Tax Assessing Officer having jurisdiction over the company for Assessment Year 2023-24.
• Equity investors and market participants tracking corporate tax liabilities and contingent disclosures of the listed entity.
Compliance Action Points:
1. Monitor notice from the Assessing Officer for initiating de novo assessment proceedings for AY 2023-24.
2. Prepare structured legal submissions, underlying ledgers, and documentary evidence to substantiate original deductions and disallowances.
3. Ensure timely representation before the Assessing Officer during fresh assessment proceedings to mitigate potential tax demands.
Analysis & Impact:
• For CA / CS / Tax & Legal Professionals: The remand allows the company a full opportunity to re-present its factual and legal arguments regarding disputed additions, effectively resetting the previous CIT(A) partial disallowances.
• For Businesses & Investors: Neutral immediate cash-flow impact as the tribunal order vacates the previous CIT(A) demand of Rs. 11.76 lakh without creating any immediate liability.
• For News Readers: The ITAT has wiped the slate clean for AY 2023-24 tax disputes and instructed the tax department to re-examine the entire assessment afresh.
• Points to Watch: Issuance of fresh assessment notice by the Assessing Officer and final quantum of tax liability computed post-reassessment.
Full Judgement / Attachment
Full Judgement
Frequently asked questions about CBDT (Income Tax)
- What is the CBDT?
- The Central Board of Direct Taxes is a statutory body under the Central Boards of Revenue Act, 1963, in the Department of Revenue, Ministry of Finance. It frames direct tax policy and administers the Income Tax Department.
- What changed with the Income-tax Act, 2025?
- The Income-tax Act, 2025 replaced the Income-tax Act, 1961 with effect from 1 April 2026. It replaces the 'previous year' and 'assessment year' with a single 'tax year'. Returns for income earned up to 31 March 2026 are still filed under the 1961 Act.
- Are CBDT circulars binding?
- CBDT circulars issued under the Act are binding on income-tax authorities, but not on taxpayers or the courts. A taxpayer can rely on a beneficial circular, while the courts interpret the law independently.
- How do I appeal against an income tax order?
- A first appeal against an assessment order lies to the Commissioner of Income-tax (Appeals) or the Joint Commissioner (Appeals). A further appeal lies to the Income Tax Appellate Tribunal, then to the High Court on a substantial question of law, and finally to the Supreme Court.
- How can White Collar Professional help with a CBDT or income tax matter?
- Post your requirement on White Collar Professional to receive proposals from verified Chartered Accountants and tax Advocates, compare them, and pay securely through the platform. This page also tracks the latest CBDT or income tax CBDT circulars and income tax updates as they are reported.
