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Siemens Limited vs. Asst. DIT

Case No: ITA No. 6678/Mum/2025
Court: Income Tax Appellate Tribunal 'G' Bench, Mumbai
Date: 1/5/2026

Parties Involved

appellantSiemens Limited
respondentAsst. DIT, CPC

Facts Summary

The assessee, Siemens Limited, a resident corporate entity, filed a return of income for the assessment year 2020-21. The Centralized Processing Centre (CPC) made an upward adjustment of Rs. 6,62,28,591/- on account of reversal of interest charged under section 23 of the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act). The assessee contested this addition by appealing to the first appellate authority, which sustained the addition. The assessee then appealed to the Income Tax Appellate Tribunal, arguing that the interest provision was not claimed as a deduction and hence, the reversal should not result in an addition.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the addition of Rs. 6,62,28,591/- on account of reversal of interest charged under section 23 of the MSMED Act is valid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

2 precedents cited in this judgement.

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Version 2.0.1Last updated: October 2025
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