DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(1), AHMEDABAD, AHMEDABAD vs. TORRENT POWER LIMITED, AHMEDABAD

ITA 1117/AHD/2024Status: DisposedITAT Ahmedabad06 August 2026AY 2011-1210 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s order, finding that the issue regarding the apportionment of contributions under Section 35(1)(ii) for Section 80IA deduction had already been decided in favor of the assessee by a coordinate bench. The AO's disallowances were found to be covered by this earlier decision.

What were the facts?

The Assessing Officer (AO) reopened the assessment for AY 2010-11 and 2011-12, making disallowances under Section 80IA concerning donations made by the assessee. The CIT(A) had allowed the assessee's appeal, quashing the reassessment and deleting the disallowances.

What were the issues?

Whether the reassessment was validly initiated and whether the disallowance under Section 80IA on account of donations was justified, considering prior tribunal rulings.

Which sections of the Income-tax Act were involved?

Section 80IA,Section 35(1)(ii),Section 143(3),Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Dhrunal Bhatt, AR
For Respondent: Shri Rameshwar P Meena, SR-DR
Hearing: 18.06.2026Pronounced: 06.08.2026

Heard together (2 matters)

ITA No. 1076/Ahd/2024
CO No. 19/Ahd/2024

Read from the judgment's own cause title. This page is filed under one of them.

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

These two appeals are filed by the Revenue against the orders of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 21.03.2024 and 26.03.2024 for the Assessment Years

ITA No. 1076 & CO No. 19/Ahd/2024 & 1117/Ahd/2024 Torrent Power Ltd Vs DCIT, AY- 2010-11 & 2011-12 2

(A.Ys.) 2010-

The order continues below.

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