Shrihari S/ Anant Shidore And Ors vs The Commissioner/Administrator on 27 March, 2026

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Bombay High Court

Shrihari S/ Anant Shidore And Ors vs The Commissioner/Administrator on 27 March, 2026

Bench: G. S. Kulkarni

                                                                                                  15-ITXA-150-24.DOC


JYOTI
RAJESH                              IN THE HIGH COURT OF JUDICATURE AT BOMBAY
MANE                                  ORDINARY ORIGINAL CIVIL JURISDICTION
Digitally signed
by JYOTI
RAJESH MANE
Date: 2026.04.01
10:39:13 +0530                              INCOME TAX APPEAL NO. 150 OF 2024


                   Hindustan Unilever Limited                                    ...Appellant
                         Versus
                    Deputy Commissioner Of
                   Income Tax, Range 1 And Anr.                                  ...Respondents

                                                    _______
                   Mr. Nishant Thakkar a/w. Ms. Jasmin Amalsadwala a/w. Mr. Rajesh Poojary i/b.
                   Mulla & Mulla and CBC, for Appellant.
                   Mr. Suresh Kumar, for Respondent.
                                                                 _______

                                                         CORAM:       G. S. KULKARNI &
                                                                      AARTI SATHE, JJ.

                                                         DATE:        27th MARCH 2026

                   P.C.

1. Heard learned counsel for the parties. Admit, on the following reframed questions of law:

A) Whether the Tribunal was justified in holding head office expenditure not relatable to or having no direct nexus with the undertaking, the profits whereof qualified for deduction under section 80HH and 801, were required to be taken into consideration for the purposes of computing deduction under Section 80HH and 801/IA of the Act?

B) Whether on the facts and in the circumstances of the case the Tribunal ought to have held that no adjudication in terms of Section 145(2) of the Act can be made in respect of that part of the purchase price that represented the cenvat credit available on the goods purchased by the appellant as the same was not a duty that was paid or incurred by the appellant?"

C) Whether the Tribunal ought to have held that the legal expenditure incurred on amalgamation of Ponds (India) Ltd. with the Appellant was allowable under section 37(1) or alternatively under section 35DD of the Act?

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3. It is also observed that Question No. (A) has arisen in the case of the assessee for Assessment Year 1997-98 in ITXA No. 1499 of 2018. Question No. (B) has arisen for consideration in ITXA No. 1225 of 2013 pertaining to Assessment Year 2006-07. Accordingly, let the present appeal be tagged along with ITXA No. 1499 of 2018 and ITXA No. 1225 of 2013. The Respondent waives service.

4. Liberty to the Appellant/assessee to apply for early hearing as a short issue is involved.

          (AARTI SATHE, J.)                         (G. S. KULKARNI, J.)




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