Mukka Proteins secures partial relief in AY 2018-19 tax appeal
Mukka Proteins received a partial relief in its tax appeal for Assessment Year 2018-19, with the CIT (Appeals)-2, Panaji deleting additions totaling ₹8.08 crore, including prior period income of ₹4.48 crore and part of an alleged excess stock addition. However, an addition of ₹7.55 crore related to alleged excess stock was sustained under Section 115BBE, attracting a special tax rate of 78%. The company, having already paid tax at the normal rate, is evaluating the order and considering further legal remedies.

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Mukka Proteins has secured partial relief in its tax appeal for Assessment Year 2018-19, with the Commissioner of Income Tax (Appeals)-2, Panaji, deleting additions totaling ₹8.08 crore while sustaining a demand of ₹7.55 crore. The appellate order, dated June 30, 2026, addressed disputes arising from an assessment completed under Section 143(3) read with Section 263 of the Income-tax Act, 1961. The order reduces the company's disputed tax liability, though a significant addition remains subject to a higher effective tax rate.
The litigation involved the Assistant Commissioner of Income Tax, Central Circle-1, Mangalore, who had originally made additions totaling ₹15.63 crore. This comprised an alleged excess stock of ₹11.14 crore and prior period income of ₹4.48 crore. The company filed an appeal against these additions, leading to the recent order which provides relief on specific components of the demand.
Breakdown of the Appellate Order
The Commissioner of Income Tax (Appeals) partly allowed the appeal, providing relief on two key counts. The addition of prior period income amounting to ₹4.48 crore was deleted after the authority held that the income had already been offered to tax in earlier assessment years. Additionally, out of the total alleged excess stock of ₹11.14 crore, an addition of ₹3.60 crore was deleted.
| Particulars | Original Addition | Outcome | Amount Deleted/Sustained |
|---|---|---|---|
| Prior Period Income | ₹4,48,21,141 | Deleted | ₹4,48,21,141 |
| Alleged Excess Stock | ₹11,14,72,010 | Partly Deleted | ₹3,60,16,402 (Deleted), ₹7,54,55,608 (Sustained) |
However, the addition relating to alleged excess stock amounting to ₹7.55 crore has been sustained. This amount is assessed under the special tax rate prescribed under Section 115BBE of the Income-tax Act, which carries an effective rate of 78%. The company stated that it has already discharged the tax liability on this amount at the normal tax rate, which has an effective rate of 34.944%.
Financial Implications and Next Steps
Pursuant to the appellate order, the company has secured a reduction in the taxable demand by ₹8.08 crore. The consequential tax impact will be determined in accordance with the provisions of the Income-tax Act, 1961. The sustained addition of ₹7.55 crore under Section 115BBE remains a point of contention, given the higher effective tax rate applicable to such income.
Mukka Proteins is currently evaluating the appellate order to understand its full financial implications. The company indicated that it is considering appropriate legal remedies available under the law to address the sustained addition. The intimation was submitted to the exchanges in compliance with Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
Historical Stock Returns for Mukka Proteins
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -1.07% | -3.31% | +6.16% | +1.54% | -22.86% | -45.37% |
What specific legal remedies is Mukka Proteins considering to challenge the sustained ₹7.55 crore addition under Section 115BBE?
How will the differential between the normal tax rate paid and the 78% effective rate under Section 115BBE impact the company's cash flow and liquidity?
What is the estimated timeline for a final resolution on the remaining disputed amount, and could this lead to further provisions in the upcoming financial statements?































