RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

ITA 2318/MUM/2022Status: DisposedITAT Mumbai18 October 2023AY 2017-1868 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partly allowed the appeals of both the assessee and the revenue. Certain comparable companies were excluded from transfer pricing analysis, and other issues were remitted back to the TPO/Assessing Officer for fresh determination.

What were the facts?

Reliance Industries Ltd. (assessee) filed appeals against the orders of the CIT(A) concerning assessment years 2017-18 and 2018-19. The appeals involved issues related to transfer pricing, R&D expenses, depreciation, and disallowances under Section 14A.

What were the issues?

The key issues involved the validity of transfer pricing adjustments, allowability of weighted deductions for R&D, depreciation claims, and disallowances under Section 14A.

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 32,Section 14A,Section 115JB,Section 92C,Section 10AA,Section 80G,Section 42(1)(b)

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Income Tax Appellate Tribunal, “J” Bench, Mumbai

Before: Shri B.R. Baskaran (AM) & Shri Pavan Kumar Gadale (JM)

For Appellant: Shri Madhur Agrawal, Ms. Moksha Mehta &, Shri Nimesh Vora
For Respondent: Shri Krishna Kumar Mishra
Hearing: 06.10.2023Pronounced: 18.10.2023

Per B.R.Baskaran (AM) :- The cross appeals filed by the assessee and Revenue relate to AY 2017-18 and 2018-19. The assessee has filed cross objection in A.Y. 2018-19. All are directed against the orders passed by Ld CIT(A)-57, Mumbai. Since certa

The order continues below.

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