STEEL AUTHORITY OF INDIA LTD.,DELHI vs. ACIT, CIRCLE-22(2), NEW DELHI

ITA 4201/DEL/2025Status: DisposedITAT Delhi15 May 2026AY 2021-227 pages
AI SummaryRemanded

What were the facts?

The assessee claimed a deduction under Section 80M on inter-corporate dividends received, which was not entertained by the CIT(A) as it was a fresh claim made before the appellate authority. The assessee argued that appellate authorities have the power to admit such claims.

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in not admitting the additional claim for deduction under Section 80M, as appellate authorities are empowered to entertain fresh claims. The matter was remanded to the AO for verification of the eligible deduction amount.

What were the issues?

Whether an appellate authority can entertain a fresh claim for deduction not made before the Assessing Officer, and if so, the extent of such power and the procedure to be followed.

Which sections of the Income-tax Act were involved?

Section 80M,Section 115BAA,Section 250,Section 143(1),Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHIBENCH ‘A’, NEW DELHI

Before: Sh. Anubhav Sharma & Sh. Manish Agarwal

For Appellant: Adv. &
Hearing: 17.02.2026Pronounced: 15.05.2026

Per Manish Agarwal, Accountant Member:

The present appeal has been filed by the assessee against the order dated 05.05.2025passed by CIT(A)/Addl./JCIT(A), Panchkula in DIN & order No. ITBA/APL/S/250/2025- 26/1076033636(1) passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising from the intimation order dated 14.12.2022 passed u/s 143(1) of the Act pertaining to Assessment Year 2021-22. 2. The assessee has raised additional grounds of appeal before the ld. CIT(A) claiming deduction u/s 80M of the Act on inter-corporate dividend received and placed reliance on the judgment of Hon’ble Supreme Court in the case of G

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80M

All 84 judgments and leading authorities on Section 80M →

Recent GST High Court judgments

Search GST case law →