Case Law Details
DCIT Vs Astral Limited (ITAT Ahmedabad)
In the case of DCIT vs. Astral Limited, heard by the Income Tax Appellate Tribunal (ITAT) in Ahmedabad, the Revenue filed an appeal against the order of the Commissioner of Income Tax-11, Ahmedabad (CIT(A)), dated 08/08/2023, pertaining to the assessment year 2018-19.
The assessee had initially declared a total income of Rs. 1,70,58,29,720/, which was later assessed by the Assessing Officer (AO) under section 143(3) r.w.s. section 144C(3)/144(B) of the Act at a total income of Rs. 1,75,87,35,950/-. During the assessment, the AO made several additions, including Transfer Pricing (TP) Adjustment, disallowance of Employee Stock Ownership Plan (ESOP) expenses, and disallowance under section 14A of the Act.
The key points of contention in the appeal were as follows:
1. TP Adjustment for Guarantee Commission:
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