DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ADANI LOGISTICS LTD, AHMEDABAD

ITA 1837/AHD/2025Status: DisposedITAT Ahmedabad12 February 2026AY 2020-21Bench: SHRI TR SENTHIL KUMAR (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)7 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the disallowance under Section 14A, reasoning that no exempt income was earned by the assessee during the year, and the Explanation to Section 14A (w.e.f. 01.04.2022) is prospective. Regarding CSR expenses, the Tribunal affirmed that deductions under Section 80G are permissible for contributions to eligible trusts, even if such expenses are disallowed under Section 37, provided they are not made to specific restricted funds like Swachh Bharat Kosh or Clean Ganga Fund. The Tribunal relied on several precedents supporting both positions.

What were the facts?

The assessee, Adani Logistics Ltd., filed its income tax return for A.Y. 2020-21, claiming a deduction of Rs. 29.10 lakhs under Section 80G for CSR expenses. The Assessing Officer (AO) disallowed this deduction and made an addition of Rs. 15.42 crores under Section 14A read with Rule 8D. The CIT(A) allowed the assessee's appeal, deleting both the disallowance under Section 14A and the deduction under Section 80G. The Revenue subsequently appealed to the ITAT.

What were the issues?

Whether disallowance under Section 14A for administrative expenses is justified when no exempt income is earned by the assessee. Whether deduction under Section 80G is permissible for amounts spent on mandatory Corporate Social Responsibility (CSR) obligations.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 80G,Section 14A,Section 37(1)

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Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: SHRI TR SENTHIL KUMAR & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Dhrunal Bhatt, AR
For Respondent: Shri R P Rastogi, CIT-D.R
Hearing: 05.02.2026Pronounced: 12.02.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the Revenue against the order of National Faceless Appeal Centre(NFAC), Delhi [hereinafter referred to as ‘CIT(A)’], dated 04.08.2025 for the Assessment Year (A.Y.) 2020-21 in the proceeding u/s 143(3) r.w.s. 144B of the Income Tax Act.

2.

The brief facts of the case are that the assessee had filed its return of income for the Assessment Year (A.Y.) 2020-21 on 29.01.2021 declaring total income of Rs.160,81,00,830/-. The case was selected for scrutiny under CASS. In the course of assessment, the AO noticed that the assessee had claimed deduction of Rs.29,

The order continues below.

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