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Trent Limited vs DCIT-2(3)(1), Mumbai

Case No: ITA No. 5166/MUM/2025 & ITA No. 5242/MUM/2025
Court: INCOME TAX APPELLATE TRIBUNAL “H” BENCH, MUMBAI
Date: 1/30/2026

Parties Involved

appellant/assesseeTrent Limited
respondent/revenueDCIT-2(3)(1), Mumbai

Facts Summary

The assessee-company, Trent Limited, is engaged in the business of retailing readymade garments. It filed its return of income for A.Y. 2014-15 declaring income of Rs. 7.14 crores under normal provisions and Rs. 65.84 crores under section 115JB. The case was selected for scrutiny. During the assessment, the assessing officer noted international and specified domestic transactions in the transfer pricing study report and made a reference under section 92CA for computation of arm’s length price. V

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Disallowance under section 14A
  • 2. Disallowance of brand equity fees paid to Tata Sons Ltd.

3 more legal issues analysed in this judgement.

Precedents Relied Upon

6 precedents cited in this judgement.

Judgment Outcome

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Version 2.0.1Last updated: October 2025
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