Sicpa India Private Limited Vs ACIT (ITAT Delhi)
This appeal was filed by the assessee, Sicpa India Private Limited, against the order of the Ld. Commissioner of Income Tax (Appeals) [CIT(A)] dated November 28, 2024, for the Assessment Year (A.Y.) 2020-21. This order arose from an assessment order passed under Section 143(3) of the Income Tax Act, 1961, dated September 30, 2022.
Case Background and Disallowances
Sicpa India Private Limited is a company engaged in the manufacturing and distribution of security inks. The company e-filed its return of income on February 15, 2021, declaring a total income of Rs. 6,74,74,000/-.
During the scrutiny assessment proceedings, the Assessing Officer (AO) passed an order under Section 143(3) making two disallowances:
- Disallowance of Rs. 23,09,391/- on account of Dividend Distribution Tax and Educational Cess claimed as expenses.
- Disallowance under Section 14A of Rs. 25,56,078/-.
- The total income was assessed at Rs. 7,71,05,940/-.
The assessee appealed the order, particularly the disallowance under Section 14A, before the CIT(A). The assessee contended that the issue regarding the disallowance under Section 14A was covered in its favor by decisions of Co-ordinate Benches in the company’s own case for preceding assessment years. However, the CIT(A) did not accept these contentions and confirmed the addition made by the AO under Section 14A.
