DCIT Vs Adani Logistics Ltd. (ITAT Ahmedabad)
The appeal before the Income Tax Appellate Tribunal was filed by the Revenue challenging the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), dated 4 August 2025 for Assessment Year (AY) 2020–21. The original assessment had been completed under sections 143(3) read with 144B of the Income-tax Act.
The assessee had filed its return of income for AY 2020–21 on 29 January 2021 declaring total income of ₹160,81,00,830. The case was selected for scrutiny under the Computer Assisted Scrutiny Selection (CASS). During the assessment proceedings, the Assessing Officer (AO) noticed that the assessee had claimed deduction of ₹29,10,000 under section 80G of the Act in respect of corporate social responsibility (CSR) expenditure. The AO took the view that CSR expenditure was not eligible for deduction and therefore disallowed the claim. In addition, the AO made a disallowance of ₹15,42,27,483 under section 14A read with Rule 8D of the Income-tax Rules, treating the amount as administrative expenditure related to investments capable of yielding exempt income. Consequently, the assessment was completed on 29 February 2022 determining the total income at ₹178,06,26,060.
The assessee challenged the assessment order before the Commissioner (Appeals), who allowed the appeal and granted relief on both issues. Aggrieved by this decision, the Revenue filed an appeal before the Tribunal.
