DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI V. SHRIRAM PISTONS AND RINGS LTD, DELHI

ITA 4418/DEL/2024

AI Insights

The case involves an appeal by the Deputy Commissioner of Income-tax against Shriram Pistons and Rings Ltd. concerning the assessment year 2018-19. The primary issues in the appeal were related to the deletion of additions made by the Assessing Officer, which were challenged by the Revenue. These additions pertained to expenditures claimed by the assessee on Dies for New Model Development and Productivity Maintenance. The CIT (A) had allowed the appeal of the assessee, which the Revenue contested. However, the ITAT dismissed the Revenue's appeal, referencing decisions from earlier years where similar issues were resolved in favor of the assessee.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 314403 (ITAT-DELHI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-05-2025
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: G
• Assessment Year: 2018-2019
• Other Referred Cases: ITA Nos.4123 & 4150/Del/2024, ITA No.7249/Del/2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SAHIL KUMAR BANSAL
• Assessee Lawyers: RAVI KUMAR

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No.4418/DEL/2024 (Assessment Year: 2018-19) Deputy Commissioner of Income-tax, vs. Shriram Pistons and Rings Ltd., New Delhi. Himalaya House, 23, 3rd Floor, Kasturba Gandhi Marg, New Delhi – 110 001. (PAN : AAACS0229G) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Ravi Kumar, CA Ms. Shruti Gupta, CA REVENUE BY : Shri Sahil Kumar Bansal, Sr. DR Date of Hearing : 19.02.2025 Date of Order : 07.05.2025 O R D E R PER S. RIFAUR RAHMAN,ACCOUNTANT MEMBER : 1. This appeal filed by the assessee is against the order of ld. Commissioner of Income-tax Appeals/National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to ‘ld. CIT (A)’) dated 25.07.2024 for Assessment Year 2018-19 raising following grounds of appeal :- “1. Whether in facts and circumstances of the case Ld. CIT (A) was right in allowing appeal of the assessee. 2 ITA No.4418/DEL/2024 2. Whether in facts and circumstances of the case Ld. CIT (A) has erred in deleting the addition in this respect of Rs.12606417 being expenditure on account of Dies for New Model Development. 3. Whether in facts and circumstances of the case Ld. CIT (A) has erred in deleting the addition in this respect of Rs.7682135/- being expenditure on account of Productivity Maintenance.” 2. At the outset, ld. AR of the assessee submitted that the issues involved in respect of additions made on account of Dies for New Model Development and Productivity Maintenance are covered in favour of the assessee by the coordinate Bench of the ITAT in ITA Nos.4123 & 4150/Del/2024 dated 12.02.2025 for AYs 2015-16 & 2020-21 and the ITAT following the decision of the coordinate Bench in ITA No.7249/Del/2017 dated 16.07.2021 for Assessment Year 2014-15 upheld the action of the ld. CIT (A) and dismissed the appeal of the Revenue. Accordingly, he prayed that the identical issues are decided by the ITAT in favour of the assessee, hence the appeal filed by the Revenue may be dismissed. 3. On the other hand, ld. DR of the Revenue did not controvert the aforesaid submissions made by the assessee. 4. Considered the rival submissions and material placed on record. We find that the identical issues were involved in the appeals decided by the coordinate Bench of the ITAT in assessee’s own case in AYs 2014-15, 3 ITA No.4418/DEL/2024 2015-16 & 2020-21 (supra) and the ITAT decided the issues against the Revenue and dismissed the appeals of the Revenue. Accordingly, respectfully following the orders of the coordinate Bench, we uphold the action of the ld. CIT (A) and dismiss the appeal of the Revenue. 5. In the result, the appeal filed by the Revenue is dismissed. Order pronounced in the open court on this 7th day of May, 2025. Sd/- sd/- (YOGESH KUMAR U.S.) (S.RIFAUR RAHMAN) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 07.05.2025 TS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals). 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI "