DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 1550/MUM/2016Status: DisposedITAT Mumbai21 November 2025AY 2009-10Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal allowed the assessee's ground regarding the disallowance of provision for expenses, directing the AO to delete the addition. It also restored the issue of depreciation on assets capitalized on March 31, 2009, to the AO for verification.

What were the facts?

The assessee, ICICI Bank Limited, filed cross-appeals against the CIT(A)'s order for AY 2009-10. The appeals dealt with issues including transfer pricing adjustments, disallowance of expenses related to exempt income, provision for expenses, and depreciation on assets capitalized on March 31, 2009.

What were the issues?

The key issues involved transfer pricing adjustments for back office support services, disallowance of expenses attributable to exempt income, and the allowability of provisions for year-end expenses and depreciation on assets capitalized at the close of the financial year.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 14A,Section 145,Section 32

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IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Physical hearing) Mumbai – 400020. Bandra (East), Mumbai – 400051. [PAN No. AAACI1195H] Appellant / Assessee Respondent / Revenue (Physical hearing) Mumbai – 400020. Bandra (East), Mumbai – 400051. [PAN No. AAACI1195H] Appellant / Assessee Respondent / Revenue

Assessee by Ms. AratiVissajnji, Sr. Advocate & Mr. Ankit Harsora & Stuti Jindal Revenue by Shri Ajay Chandra, CIT-DR Date of hearing 06.10.2025 Date of pronouncement 21.11.2025

Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER;

1.

These cross-appeals by assessee as well as by revenue are directed

against the order of ld. CIT(A)-56, Mumbai dated 21.05.2015 for A.Y.

2009-10. The assessee in its appeal has raised following grounds of appeal:

1.

Adjustment as per Transfer Pricing Order under section 92C

The order continues below.

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