ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

ITA 4244/MUM/2025Status: DisposedITAT Mumbai10 March 2026AY 2019-20Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the delay in filing Form 67 for foreign tax credit is a procedural lapse and cannot deny a legitimate claim, restoring the matter to the AO for verification. The Tribunal also decided not to adjudicate the grounds challenging the validity of the assessment order as they became academic after granting relief on merits.

What were the facts?

The assessee company claimed deduction under section 80G for CSR expenditure, deduction under section 80JJAA, foreign tax credit, and incurred marketing expenditure for an e-commerce platform. The Assessing Officer made several additions and disallowances, including disallowing 80G deduction, restricting 80JJAA, disallowing under section 14A, adding written-back creditors, and treating marketing expenditure as capital. The CIT(A) granted relief on most issues but disallowed 80G deduction.

What were the issues?

Whether delay in filing Form 67 for foreign tax credit can deny the claim, and whether the assessment order was passed beyond the limitation period.

Which sections of the Income-tax Act were involved?

Section 80G,Section 80JJAA,Section 14A,Section 135,Section 37(1),Section 143(3),Section 144B,Section 153,Section 142(1),Section 92CA,Section 90,Section 139(1)

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Income Tax Appellate Tribunal, “D” BENCH MUMBAI

For Appellant: Shri Madhur Agarwal & Shri Nimesh
For Respondent: Shri Umashankar Prasad, Ld. DR
Hearing: 16.02.2026Pronounced: 10.03.2026

PER MAKARAND VASANT MAHADEOKAR, AM: These cross appeals arise out of the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] dated 12.04.2025 for Assessment Year 2019–20. The impugned order was passed under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”] in relation to the assessmen

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