SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

ITA 5618/DEL/2024Status: DisposedITAT Delhi12 December 2025AY 2021-2289 pages
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What did the Tribunal hold?

The Tribunal restored the matter to the Assessing Officer (AO) for fresh examination on several issues, including disallowance of deduction under Section 80-IA, incorrect demand due to MAT credit and refund adjustments, and interest charged under Section 234A. The AO was directed to verify claims in line with previous orders and circulars.

What were the facts?

The assessee, SRF Limited, filed an appeal against the assessment order which included transfer pricing adjustments and other additions. The assessee also raised grounds related to incorrect computation of total income, disallowance of deduction under Section 80-IA, MAT credit, and interest charges.

What were the issues?

The key issues involved transfer pricing adjustments, disallowance of deductions, incorrect computation of total income, and consequential interest and penalty charges. The validity of the assessment order itself was also challenged on procedural grounds.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 260,Section 144C(5),Section 92CA(3),Section 80-IA,Section 156,Section 115JAA,Section 234A,Section 234B,Section 234C,Section 270

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

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

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

This appeal is filed by the assessee against the assessment order dated 29.04.2022, passed by the ACIT, Circle 10 (1), Delhi under section 143(3) r.w.s. 260 of the Income-tax Act, 1961 (for short ‘the Act”) for Asses

The order continues below.

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