DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

ITA 5560/DEL/2024Status: DisposedITAT Delhi18 March 2026AY 2021-22Bench: SHRI CHALLA NAGEMDRA PRASAD (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)33 pages
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What did the Tribunal hold?

The Tribunal restored the issue of additions made in the intimation u/s 143(1) to the AO for de novo adjudication. It directed the AO to verify the facts regarding the capital loss and rectify the mistake apparent from the record. The Tribunal also remitted the issue of notional interest to the AO for verification to avoid double taxation.

What were the facts?

The assessee company claimed deduction under section 80IA for power generation units and also reported a long-term capital loss. The Assessing Officer (AO) made several additions and adjustments, including transfer pricing adjustments and corporate tax issues, leading to the present appeal.

What were the issues?

Whether additions made in the intimation u/s 143(1) are valid and whether the AO correctly computed capital gains/losses and notional interest.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 143(3),Section 144C,Section 80IA,Section 92CA,Section 270A

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

Before: SHRI CHALLA NAGEMDRA PRASAD & SHRI S. RIFAUR RAHMAN

For Appellant: Shri Pradeep Dinodia, CA, Shri Ravi Kumar, CA &, Ms. Shruti Gupta, CA
For Respondent: Shri Dharm Veer Singh, CIT(DR), Ms. Anima Barnwal, CIT(DR)
Hearing: 10/02/2026Pronounced: 18/03/2026

PER S. RIFAUR RAHMAN, AM This appeal has been filed by the assessee against the final assessment order dated 24.10.2024 passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions of the Ld. Dispute Resolution Panel (DRP)/TPO for Assessment Year 2021-22. 2. Brief facts of the case are that the assessee is a public limited company engaged in the business of manufacturing and trading of chemical, PVC Resins, PVC compounds, UPVC Windows & Door Systems, Cement, Sugar, Fertilizers, seeds, textile yarn, power generation etc. The return of inc

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