M/s. Rallis India Ltd. vs. The Dy. Commissioner of Income Tax

Parties Involved

Facts Summary

M/s. Rallis India Ltd. filed two appeals against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi, dated 27-09-2025, pertaining to Assessment Years 2021-22 & 2023-24. The appeals raised several grounds including non-grant of TDS credit, wrong computation of interest under section 234C, and issues related to double taxation of dividend income and deduction under section 80M. The appellant argued that the Assessing Officer (AO) and the Commissioner of Income Tax (Appeals) (CIT(A)) had erred in their decisions. The respondent defended the orders passed by the lower authorities.…

Legal Issues

• 1. Non-grant of TDS credit of Rs. 71,407/- deducted by Yes Bank Ltd.
• 2. Wrong computation of interest under section 234C of the Act.
• 3. Double taxation of dividend income of Rs. 6,76,000/-.
• 4. Claim for deduction under section 80M of Rs. 6,76,000/-.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Tata Consumer Products Limited vs. Assistant Commissioner of Income Tax

  Kolkata Bench benchAY 2021-22Partly Allowed

• RATNASHRI BUILDTECH PVT. LTD. VS. CENTRAL PROCESSING

  Delhi Bench benchAY 2019-20Allowed

• Hasbro SA vs. Dy. Commissioner of Income Tax (International Tax), Circle-1(1)(1), Delhi

• Shree Capital Services Ltd. Vs. A.C.I.T., Circle-5(1), Kolkata

  Kolkata ‘D’ Bench, Kolkata benchAY 2023-24Allowed

• Intertek India Private Limited Vs. Asst. Commissioner of Income Tax

  Delhi Bench ‘B’ benchAY 2016-17Partly Allowed

• Kad Steel Rolling Mills vs. Income Tax Officer

  Ahmedabad bench