Reliance Retail Limited Vs DCIT (ITAT Mumbai)
CSR Donations Eligible for Section 80G Deduction; Belated Form 67 Can’t Defeat FTC: ITAT Mumbai
Material Facts
The assessee and the Revenue filed cross-appeals against the order of the National Faceless Appeal Centre (NFAC), Delhi, dated 23.10.2025 for Assessment Year (AY) 2020–21.
In its appeal, the assessee challenged:
- The validity of the assessment order under Sections 143(3) read with 144B on the ground that it was barred by limitation under Sections 153(1) and 153(4).
- Disallowance of deduction under Section 80G amounting to ₹25,07,50,000 in respect of donations of ₹50,15,00,000 made towards Corporate Social Responsibility (CSR).
- Denial of an additional Foreign Tax Credit (FTC) claim of ₹54,63,221 on the ground that Form No. 67 had not been filed before the due date of filing the return.
- An alternative claim regarding deduction of sales promotion, advertisement expenses and professional fees.
The Revenue challenged:
- Allowance of deduction under Section 80JJAA despite delayed filing of Form No. 10DA.
- Treatment of expenditure relating to development of the existing e-commerce platform as revenue expenditure instead of capital expenditure.
Procedural History
The Tribunal first considered the assessee’s appeal. The assessee submitted that the issues relating to Section 80G deduction and Foreign Tax Credit were covered by earlier coordinate bench decisions in its own cases for AYs 2019–20 and 2018–19 respectively.
Paid content
Become a Basic or Premium Member, or log in if you are already a Basic or Premium member.
