APOLLO TYRES LTD,COCHIN vs. THE DEPUTY COMMISSIONER OF INCOME TAX, COCHIN

ITA 1000/COCH/2024Status: DisposedITAT Cochin10 September 2025AY 2021-22Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal addressed several grounds, including transfer pricing adjustments for corporate IT services, salary expenses, and corporate guarantee fees. Regarding the Section 14A disallowance, the Tribunal held that it does not arise as the assessee did not receive exempt income and directed its deletion.

What were the facts?

The assessee, Apollo Tyres Ltd., filed its return of income for AY 2021-22 declaring Nil income. The Assessing Officer (AO) made additions based on the Transfer Pricing Officer's (TPO) report and a disallowance under Section 14A. The Dispute Resolution Panel (DRP) dismissed the assessee's objections.

What were the issues?

The main issues involved transfer pricing adjustments for various international transactions and the disallowance of expenses under Section 14A. The grounds also raised disputes over the comparability analysis and the application of filters used by the TPO/AO/DRP.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA(1),Section 92CA(3),Section 14A,Section 10B(2),Section 10B(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM & SHRI RAHUL CHAUDHARY, JM

For Appellant: Shri Abraham Joseph Markos, Adv
For Respondent: Shri Sanjit Kumar Das, CIT-DR
Hearing: 20.08.2025Pronounced: 10.09.2025

Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the final assessment order dated 24.10.2024passed u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of Income Tax Act, 1961 (hereinafter "the Act") for Assessment Year (AY) 2021-22. 2. Brief facts of the case are that the appellant is a company incorporated under the provisions of Companies Act, 1956. It is engaged in the business of manufacture and sale of tyres, tubes and dealing in flaps. The return of income for AY 2021-22 was filed on 2 Apollo Tyres Ltd. 03.03.2022 declaring Nil income and also reported book profit under MAT of Rs. 1088,40,84,655/-. The assessee company also reportedthe certaininternational transactions from AE in from 3CEB.

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The order continues below.

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