M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI
In the result the appeal filed by the revenue stands\ndismissed
ITA 321/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12
Bench: Shri Sandeep Gosain&\Nshri Prabhash Shankar\N\Ni.T.A. No. 319& 321/Mum/2023\Na.Ys: 2007-08 & 2011-12\N\Npatanjali Food Ltd (Formerly Vs\Nknown As Ruchi Soya\Nindustries Ltd)\N616, Tulsiani Chambers,\Nnariman Point, Mumbai\Npan - Aaacr2892L\Ndy. Cit, Cc – 7(2)\N655, 6Th Floor, Aayakar\Nbhavan, Mk Road, Mumbai\N400020.\N(Appellant)\N(Respondent)\N\Ni.T.A. No. 1173 & 1174/Mum/2023\Na.Ys: 2007-08, 2011-12\Ndy. Cit, Cc – 7(2)\N655, 6Th Floor, Aayakar\Nbhavan, Mk Road, Mumbai\N400020.\N(Appellant)\Nvs\Npatanjali\Nfood\Nltd\N(Formerly Known As Ruchi\Nsoya Industries Ltd)\N616, Tulsiani Chambers,\Nnariman Point, Mumbai\Npan – Aaacr2892L\N(Respondent)\N\Nassessee By\Nrevenue By\Ndate Of Hearing\Ndate Of Pronouncement\N\Nshri Ss Nagar (Virtually Appeared) &\Nshri B Maheshwari\Nshri Ra Dhyani, Cit Dr\N11.08.2025\N15.09.2025\N\Norder\N\Nper: Shri. Sandeep Gosain, J.M.:\Nthe Present Appeals Have Been Filed By The Assessee\Nchallenging The Different Impugned Orders Passed Under\Nsection 250 Of The Income Tax Act, 1961 (‘The Act'), By The\Nnational Faceless Appeal Centre (Nfac) / Cit(A) For The\N Assessment Year 2007-08 & 2011-12.\N\N2. Since All The Issues Involved In These Two Appeals Are\Ncommon & Identical, Therefore, They Have Been Clubbed,\Nheard Together & Consolidated Order Is Being Passed For\Nthe Sake Of Convenience & Brevity.\N\Nita No. 319/Mum/2023, A.Y 2007-08\N\N3. At The Time Of Hearing Ld.Ar Stated At Bar That Assessee\Nwants To Withdraw The Present Appeal. Therefore, Considering\Nthe Statement Of The Ld.Ar, The Present Appeal Filed By The\Nassessee Stands Dismissed As Withdrawn.\N\N3.
Section 132Section 153ASection 250Section 37(1)
…to be determined, then, the liability is not a contingent\nliability (Woodward Governor 312 ITR 254 (SC) &Bharat Earth\nMovers 245 ITR 428 (SC) followed, Principles of law on accrual\nof income & loss summarized);\n(iv) Perfect Circle India Ltd vs DCIT (2015) 60 Taxmann.com 424\n(Mum.- Trib.) wherein, while deciding the issue of disallowance\nof foreign exchange loss on account of marked to market of\nforex derivative contracts, held by the A.O. as notional loss and\nby the CIT(A) as speculation loss, have observed as under:\nWe may further observe from the guidelines issued by the\nReserve Bank of India relating…
