ACIT, NEW DELHI vs. GUJARAT GUARDIAN LIMITED, SOUTH EAST DELHI

ITA 4784/DEL/2025Status: DisposedITAT Delhi13 May 2026AY 2016-1717 pages
AI SummaryPartly Allowed

What were the facts?

The assessee's appeal concerned excess depreciation, while the Revenue's appeals challenged disallowances under Section 14A and Section 80IA. The issue of excess depreciation arose from retrospective capitalization of engineering fees for cold tank repairs.

What did the Tribunal hold?

The Tribunal restored the issue of excess depreciation to the Assessing Officer for fresh verification, allowing the assessee's appeal partly for statistical purposes. The Revenue's appeals concerning Section 14A and Section 80IA disallowances were upheld in favor of the assessee.

What were the issues?

Whether retrospective capitalization of engineering fees warrants revision of depreciation claims and if disallowances under Section 14A and Section 80IA were correctly made by the lower authorities.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(3),Section 14A,Section 80IA,Section 80A,Section 32

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘C’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: Adv. Sh. Kunal Pandey, Adv
Hearing: 09.04.2026Pronounced: 13.05.2026

Heard together (2 matters)

ITA No. 3103/Del/2025
ITA No. 4812/Del/2025

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

PER SATBEER SINGH GODARA, JM: The instant batch of five cases involves the single assessee herein M/s Gujarat Guardian Limited. This taxpayer’s solitary

appeal 3103/Del/2025 for assessment year A.Y. 2014-15 and the Revenue’s four cases ITA N

The order continues below.

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