THE DCIT, CIRCLE-1(1)(1), VADODARA vs. GUJARAT STATE FERTILIZER & CHEMICAL LTD, VADODARA

ITA 538/AHD/2020Status: DisposedITAT Ahmedabad17 December 2024AY 2016-17Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL (Judicial Member)18 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partly allowed the assessee's appeal regarding disallowance under Section 14A, restricting it to Rs. 17,50,000. It dismissed the revenue's appeal on Section 14A and the computation of book profit under Section 115JB. The appeal related to Section 35(2AB) was dismissed.

What were the facts?

The assessee, Gujarat State Fertilizers & Chemicals Ltd., filed its return of income for AY 2016-17. The Assessing Officer made several additions, leading to disallowances. The CIT(A) granted partial relief, and both the assessee and revenue filed appeals.

What were the issues?

The key issues involved disallowances under Section 14A, capitalization of interest on CWIP, disallowance under Section 35(2AB), and treatment of CSR expenses and donations.

Which sections of the Income-tax Act were involved?

Section 14A,Section 35(2AB),Section 115JB,Section 80G,Section 37(1)

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: DR. B.R.R. KUMAR, VICE-SHRI SIDDHARTHA NAUTIYAL

For Appellant: Shri Manish J. Shah, Shri Jimi Patel and Shri Rushin Patel, ARs
For Respondent: Shri Durga Dutt, CIT (DR) &, Shri B.P. Srivastava, Sr. DR
Hearing: 27.11.2024Pronounced: 17.12.2024

Heard together (3 matters)

I.T.A. No. 348/Ahd/2020
I.T.A. No.538/Ahd/2020
CO No. 9/Ahd/2021

Read from the judgment's own cause title. This page is filed under one of them.

PER DR. B.R.R. KUMAR, VICE-PRESIDENT :

These two appeals - one filed by the assessee being ITA No.348/Ahd/2020 and other filed by the Revenue being ITA No.538/Ahd/2020, are cross appeals which are directed against the order of learned Commissioner of Income-tax (Appeals)-1, Vadodara (“CIT(A)” in short) dated 04.03

The order continues below.

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