Appeal partly allowed with significant relief on depreciation, ESOP, MAT credit, TDS credit, and interest.

The appeal was partly allowed, with significant relief granted on the issues of depreciation on goodwill, ESOP expenses, MAT credit, TDS credit, and interest under section 234A. The Tribunal's directions provided a comprehensive resolution to the various grounds raised by the assessee.

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Issues Involved:
1. Limitation of the order under section 153 r.w.s 144C.
2. Disallowance of depreciation on goodwill.
3. Disallowance of ESOP expenses.
4. Non-grant of foreign tax credit.
5. Non-grant of MAT credit.
6. Short credit of tax deducted at source.
7. Short credit of self-assessment tax.
8. Charging of interest under section 234A.
9. Charging of interest under sections 234B and 234C.

Detailed Analysis:

1. Limitation of the Order:
The first ground raised by the assessee was that the order passed by the Assessing Officer (AO) was barred by limitation under section 153 r.w.s 144C of the Income-tax Act. However, this ground was not pressed by the assessee and was dismissed as not pressed.

2. Disallowance of Depreciation on Goodwill:
The assessee contested the disallowance of depreciation on goodwill amounting to Rs. 89,28,64,060. The Tribunal noted that this issue was already adjudicated in the assessee's favor in earlier years, specifically in ITA No.1308/Del/2015 for Assessment Year 2010-11 and ITA No.7637/Del/2018 for Assessment Year 2014-15. Following the same reasoning, the Tribunal allowed the claim of depreciation on goodwill for the current assessment year.

3. Disallowance of ESOP Expenses:
The assessee challenged the disallowance of ESOP expenses amounting to Rs. 14,99,05,312. The Tribunal observed that this issue was similarly adjudicated in the assessee's favor in previous years. The Tribunal held that the ESOP expenses were deductible as business expenditure under section 37(1) of the Act. The Tribunal also clarified that tax deduction at source (TDS) on ESOPs would arise only when the options are exercised by employees, not at the time of reimbursement to the parent company. Consequently, the Tribunal allowed the ESOP expenses for the current year.

4. Non-Grant of Foreign Tax Credit:
The assessee claimed foreign tax credit of Rs. 4,51,62,275, out of which Rs. 3,58,00,000 was allowed by the AO. The balance of Rs. 88,67,811 was not allowed due to the absence of necessary certificates. The Tribunal found no merit in the assessee's plea as the required certificates were not produced, and thus, this ground was dismissed.

5. Non-Grant of MAT Credit:
The assessee claimed MAT credit of Rs. 21,22,53,782, out of which Rs. 18,71,00,000 was allowed by the AO. The Tribunal directed the AO to allow the balance MAT credit after giving appeal effects for earlier years, thereby allowing this ground.

6. Short Credit of Tax Deducted at Source:
The assessee claimed TDS credit of Rs. 18,79,68,945, but the AO allowed only Rs. 16,57,18,029, resulting in a shortfall of Rs. 2,22,50,916. The Tribunal directed the AO to verify the details and allow the TDS credit as per the revised Form No.26AS, thereby allowing this ground.

7. Short Credit of Self-Assessment Tax:
The issue of short credit of self-assessment tax amounting to Rs. 1,54,01,450 was not specifically addressed in the order, implying it was not pressed or was considered along with TDS credit issues.

8. Charging of Interest under Section 234A:
The assessee argued that the interest under section 234A was wrongly charged as the return was filed on the due date. The Tribunal found merit in this plea and directed the AO to delete the interest charged under section 234A.

9. Charging of Interest under Sections 234B and 234C:
The interest under section 234B was deemed consequential and thus dismissed. However, the Tribunal directed the AO to recompute the interest under section 234C based on the returned income, allowing this ground partially.

Conclusion:
The appeal was partly allowed, with significant relief granted on the issues of depreciation on goodwill, ESOP expenses, MAT credit, TDS credit, and interest under section 234A. The Tribunal's directions provided a comprehensive resolution to the various grounds raised by the assessee.

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