SRF LTD.,NEW DELHI vs. ACIT, NEW DELHI

ITA 80/DEL/2016Status: DisposedITAT Delhi12 December 2025AY 2011-1277 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal admitted additional legal grounds, allowed certain claims for additional depreciation and other deductions on merits or by following previous orders, and remanded one issue back to the AO for fresh adjudication. Some grounds were dismissed as not pressed or consequential.

What were the facts?

The assessee filed appeals against assessment orders for AY 2011-12 and 2013-14, raising grounds related to transfer pricing adjustments, corporate tax issues like disallowance under Section 14A, and various claims for additional allowances and deductions.

What were the issues?

Key issues included the taxability of corporate guarantee as an international transaction, disallowances under Section 14A, and the admissibility of various claims for deductions and exemptions not originally claimed or claimed incorrectly.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 144C,Section 32(1)(iia),Section 80-IA,Section 14A,Section 115JB,Section 37(1),Section 139(1)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(30)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, DELHI BENCHES ‘H’: NEW DELHI.

Before: SHRIS.RIFAUR RAHMAN & SHRI SUDHIR PAREEK

For Appellant: Shri Pradeep Dinodia, CA, Shri Ravi Kumar, CAR, Shri Shubham, CA
For Respondent: Shri S.K. Jadhav, CIT DR
Hearing: 15.10.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

These appeals are filed by the assessee against the assessment order dated 30.11.2015 & 18.05.2017 passed by the ACIT, Circle 1, LTU, New Delhi u/s 143(3) r.w.s. 144C(15) of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2011-12 & 2013-14 respectively pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act.

2.

Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this common order. We take up the assessee’s appeal being ITA No.80/Del/2016 for AY 2011-12 as lead case to adjudicate the

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 92CA

All 3,978 judgments and leading authorities on Section 92CA →

Recent GST High Court judgments

Search GST case law →