PATTON INTERNATIONAL LIMITED,KOLKATA vs. ACIT, CIRCLE 7(1), , KOLKATA

ITA 1044/KOL/2025Status: DisposedITAT Kolkata10 February 2026AY 2018-201911 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

For AY 2018-19, the Tribunal noted that the assessee did not provide complete details for calculating the disallowance under Section 14A and Rule 8D, leading to the matter being set aside and remitted to the AO for de novo assessment. For AY 2020-21, the Tribunal set aside the CIT(A)'s order and remanded the issue of Section 80G deduction to the AO for verification due to discrepancies in donation details and fund approval.

What were the facts?

The assessee company appealed against the CIT(A)'s orders for Assessment Years 2018-19 and 2020-21. The appeal for AY 2018-19 involves the disallowance of expenses under Section 14A read with Rule 8D. The appeal for AY 2020-21 concerns the denial of deduction for donations under Section 80G.

What were the issues?

The core issues are the correct computation of disallowance under Section 14A for exempt income and the eligibility for deduction under Section 80G for donations made to a relief fund.

Which sections of the Income-tax Act were involved?

Section 14A,Section 8D,Section 80G,Section 250,Section 143(3),Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, KOLKATA ‘D BENCH, KOLKATA

Before: SHRI SONJOY SARMA & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

Both these appeals filed by the assessee are against the separate orders of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act') for AYs 2018-19 & 2020- 21 dated 05.05.2025 and 23.04.2025, respectively. Since the issues relate to the common assessee, therefore, they are being decided vide this common order for the sake of convenience and brevity.

2.

The assessee is in appeal before the Tribunal raising the following grounds of appeal: I. ITA No. 1044/KOL/2025; AY 2019-20: “

The order continues below.

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