IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH ****

Date of Decision: 05.02.2026 COMMISSIONER OF INCOME TAX ...Appellant Vs.

M/S GLAXO SMITHKLINE CONSUMER HEALTHCARE LTD.

…Respondents CORAM:- HON'BLE MR. JUSTICE JAGMOHAN BANSAL HON'BLE MR. JUSTICE AMARINDER SINGH GREWAL Present:- Ms. Urvashi Dhugga, Sr. Standing Counsel with Mr. Vaibhav Gupta, Jr. Standing Counsel and Ms. Kavita, Advocate for Income Tax Mr. Rohit Jain, Advocate (through V.C.) and Mr. Abhishek Sharma, Advocate for the assessee ***

JAGMOHAN BANSAL, J. (ORAL)

1. The appellant through instant appeal under Section 260A of the Income Tax Act, 1961 (for short ‘1961 Act’) is seeking setting aside of order dated 21.09.2007 passed by Income Tax Appellate Tribunal, Chandigarh (for short ‘ITAT’).

2. The appellant has raised following questions for adjudication by this Court:-

i. Whether on the facts and in the circumstances of the case the ITAT was right in law in upholding the order of the CIT(A) in deleting the disallowance of claim for deduction u/s 80-IA of the 1961 Act, in as much as the machineries had been installed in the same existing factory premises, which were in the nature of routine replacements with better capa