ACIT -3(4), MUMBAI vs. RELIANCE INDUSTRIES LTD, MUMBAI

ITA 1438/MUM/2021Status: DisposedITAT Mumbai14 October 2022AY 2016-1758 pages
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What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A should be recomputed as directed by the CIT(A). It also upheld the CIT(A)'s decision regarding the addition of interest on income tax refund for book profit calculation. However, the Tribunal deleted the ALP adjustment related to interest on share application money, following its own prior decisions.

What were the facts?

The assessee, Reliance Industries Ltd., and the Revenue filed cross-appeals against the CIT(A)'s order concerning assessment year 2016-17. The primary issues involved disallowance under Section 14A, depreciation, addition of interest on income tax refund, and transfer pricing adjustments.

What were the issues?

The key issues were the computation of disallowance under Section 14A, the allowability of depreciation, the treatment of interest on income tax refunds for book profits, and the validity of transfer pricing adjustments for international and specified domestic transactions.

Which sections of the Income-tax Act were involved?

Section 14A,Section 32,Section 115JB,Section 92CA,Section 92C(3)

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Cases cited in this judgment(11)Show list

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Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SHRI PRAMOD KUMAR, VICE PRESIDE & SHRI SANDEEP SINGH KARHAIL

For Appellant: Shri Nimesh Vora a/w, Ms. Moksha Mehta
For Respondent: Shri Chetan M. Kacha, Sr. AR

PER SANDEEP SINGH KARHAIL, J.M.

The present cross appeals have been filed by the assessee and the Revenue challenging the impugned order dated 17/02/2021, passed under Reliance Industries Ltd. ITA No.579/Mum./2021 ITA No.1438/Mum./2021 section 250 of the Income Tax Act, 1961 (‘the Act‘) by the learned Commissioner of Income Tax (Appeals)-57, Mumbai [‘learned CIT(A)’], which in tu

The order continues below.

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