TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

ITA 1518/MUM/2025Status: DisposedITAT Mumbai30 December 2025AY 2018-19Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)89 pages
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What did the Tribunal hold?

The Tribunal held that the dispute was only regarding the method of calculation of tax sparing credit, not its eligibility. It found the assessee's FIFO method to be appropriate and directed that the tax sparing credit be allowed based on the assessee's working.

What were the facts?

The assessee, Tata Consultancy Services Ltd., claimed tax credit for Singapore tax paid on dividends received from its subsidiary. The Assessing Officer disallowed this claim, arguing that the assessee did not provide sufficient details on the utilization of reserves by the subsidiary. The CIT(A) upheld this disallowance.

What were the issues?

The primary issue was the allowability of tax credit for Singapore tax paid on dividends received from a subsidiary, specifically concerning the method of calculation and the utilization of reserves.

Which sections of the Income-tax Act were involved?

Section 90

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Income Tax Appellate Tribunal, “H” BENCH MUMBAI

Before: SHRI PAWAN SINGH & SHRI GIRISH AGRAWAL

Hearing: 14.10.2025Pronounced: 30.12.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

All these six appeals filed by both, assessee (TCS) and revenue are against the orders of Ld. CIT(A)-58, Mumbai passed against the Tata Consultancy Services Ltd. AY 2016-17, 2017-18 and 2018-19 assessment orders by ACIT, Mumbai/NFAC, Delhi. Consolidated details of these appeal

The order continues below.

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