ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

ITA 48/CHNY/2025Status: DisposedITAT Chennai20 August 2025AY 2017-18Bench: HON’BLE SHRI MANU KUMAR GIRI (Judicial Member), SHRI HON'BLE AMITABH SHUKLA (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that transfer pricing adjustments for corporate guarantee fees are permissible but should be restricted to 0.5% of the guaranteed amount. For Section 14A disallowances, the Tribunal directed specific calculations and exclusions. The revenue's appeal regarding CSR expenditure deduction under Section 80G was dismissed.

What were the facts?

The assessee company, Carborundum Universal Ltd., filed appeals against transfer pricing adjustments for corporate guarantee fees and disallowances under Section 14A. The revenue filed an appeal regarding the eligibility of CSR expenditure for deduction under Section 80G.

What were the issues?

Whether transfer pricing adjustments for corporate guarantees are valid and at what rate, and the allowability of CSR expenditure as a deduction under Section 80G.

Which sections of the Income-tax Act were involved?

Section 14A,Section 35(2AB),Section 80G

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(9)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: HON’BLE SHRI MANU KUMAR GIRI & SHRI HON’BLE AMITABH SHUKLA

Hearing: 18.07.2025Pronounced: 20.08.2025

IT(TP)A Nos.2, 3 & 4/Chny/2025 & Carbo

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 14A

All 15,875 judgments and leading authorities on Section 14A →

Recent GST High Court judgments

Search GST case law →