DCIT-CC-4(2),MUMBAI, MUMBAI vs. SHOPPERS STOP LIMITED, MUMBAI

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ITA 1004/MUM/2026Status: DisposedITAT Mumbai27 May 2026AY 2023-248 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the order of the CIT(A) who had deleted the addition. The Tribunal noted that the issue with identical facts had been consistently decided in favour of the assessee by appellate authorities in previous years, and that the Revenue's appeals were pending before the High Court.

What were the facts?

The Assessing Officer (AO) made an addition on account of notional interest on interest-free loans and advances given by the assessee to its subsidiary. The assessee argued that similar additions were deleted in previous years by the CIT(A) and the ITAT, and that the issue was covered by precedent.

What were the issues?

Whether notional interest on interest-free loans to a subsidiary can be taxed when similar additions have been deleted in previous years based on the principle of real income and judicial discipline.

Which sections of the Income-tax Act were involved?

Section 5,Section 143(3)

AI-generated summary — verify with the full judgment below

Before: SMT.BEENA PILLAI & SHRI PRABHASH SHANKAR

For Appellant: Shri Fenil Bhatt, AR
For Respondent: Shri Swapnil Choudhari, Sr. DR
Hearing: 16.04.2026Pronounced: 27.05.2026

आदेश की प्रयियलयि अग्रेयिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent.

P a g e | 8 ITA No. 1004/Mum/2026 A.Y. 2023-24 Shoppers Stop Ltd., Mumbai 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीय अयधकरण/ ITAT, Bench, Mumbai.

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