DCIT -CC- 1 (4), MUMBAI vs. GRASIM INDUSTRIES LIMITED (SUCCESSOR TO ADITYA BIRLA NUVO LTD. FORMERLY INDIAN RAYON INDUSTRIES LTD.), MUMBAI

ITA 1513/MUM/2019Status: DisposedITAT Mumbai04 May 2026AY 2014-1581 pages
AI SummaryPartly Allowed

What were the facts?

The assessee and revenue filed cross-appeals against an order of the CIT(A) concerning assessment year 2014-15. The appeals involved various grounds related to disallowances, deductions, and transfer pricing adjustments.

What did the Tribunal hold?

The Tribunal dismissed the revenue's appeal on most grounds, particularly concerning the allocation of head office expenses to eligible units. The assessee's appeal was partly allowed.

What were the issues?

Key issues included the disallowance of expenses under Section 14A, the treatment of head office expenses for deduction under Section 80IA, and transfer pricing adjustments for corporate guarantees.

Which sections of the Income-tax Act were involved?

Section 14A,Section 80IA,Section 92,Section 50B,Section 115JB,Section 40(a)(ii),Section 43B,Section 40A(9),Section 32AC,Section 250

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
IN THE INCOME-TAX APPELLATE TRIBUNAL, MUMBAI “K” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER Aditya Birla Nuvo Limited (Since vs. Dy. CIT, Central Circle-1(4), Room No. 902, 9th Floor, Old CGO Building, M.K. amalgamated with Grasim Industries Limited), Aditya Birla Road, Mumbai-400 020. Centre, A Wing, 2nd Floor, S.K. Ahire Marg Worli, Mumbai-400 030. PAN/GIR No: AAACI1747H (Appellant) (Respondent) Dy. CIT, Central Circle-1(4), Room vs. Grasim Industries Limited (successor No. 902, 9th Floor, Old CGO Building, to Aditya Birla Nuvo Limited formerly M.K. Road, Mumbai-400 020. known as Indian Rayon Industries Ltd.), Aditya Birla Centre, A Wing, 2nd Floor, S.K. Ahire Marg Worli, Mumbai-400 030. PAN/GIR No: AAACI1747H (Appellant) (Respondent) Assessee by Shri Yogesh Thar, Ms. Sukanya Jayaram & Shri Riken Shah Revenue by Shri Bhagirath Ramawat Date of Hearing 04.05.2026 Date of Pronouncement 30.07.2026

PER BIJYANANDA PRUSETH, AM:

These cross appeals filed by the assessee and revenue emanate from the order passed u/s250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income Tax-55, Mumbai [in short

The order continues below.

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