NEEL METAL PRODUCTS LTD.,NEW DELHI vs. DCIT, CIRCLE-18(1), NEW DELHI

ITA 5935/DEL/2017Status: DisposedITAT Delhi10 September 2026AY 2012-1314 pages
AI SummaryPartly Allowed

What were the facts?

The assessee challenged the disallowance of depreciation on electrical installations and UPS, and the disallowance of deduction under Section 80IC. The Revenue appealed against the deletion of disallowance of interest on capital work in progress and the admission of additional evidence.

What did the Tribunal hold?

The Tribunal allowed depreciation on electrical installations at 15% and on UPS at 60%, following High Court precedents. It also allowed the deduction under Section 80IC by directing item-wise examination of expenses. The disallowance of interest on capital work in progress was deleted, and the Revenue's appeal on additional evidence was dismissed.

What were the issues?

The key issues involved the correct rate of depreciation on electrical installations and UPS, the eligibility of deduction under Section 80IC when indirect expenses are allocated, and the capitalization of interest on borrowed funds for capital work in progress.

Which sections of the Income-tax Act were involved?

Section 14A,Section 80IC,Section 40(a)(ia),Section 194H

AI-generated summary — verify with the full judgment below

आयकर अपीलीय अधिकरण, दिल्ली पीठें, नई दिल्ली INCOME TAX APPELLATE TRIBUNAL, DELHI BENCHES, NEW DELHI BENCH: I BEFORE SHRI M BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA 3919, 386 & 5935/DEL/2017 निर्धारण वर्ा/Assessment Year: 2009-10, 2011-12, 2012-13) NEEL METAL PRODUCTS LTD. DCIT, CIRCLE-18(1) 601, HEMKUNT CHAMBERS,, 89, NEW DELHI NEHRU PLACE, NEW DELHI, NEW Vs. NEW DELHI-, DELHI DELHI-110019, DELHI अपीलधर्थी Appellant प्रत्यर्थी Respondent

Permanent Account Number of Assessee: AABCN6304Q

ITA 443, 6464/DEL/2017 निर्धारण वर्ा/Assessment Year: 2011-12 & 2012-13) DCIT, CIRCLE-18(1) NEEL METAL PRODUCTS LTD. ROOM NO. 212, C.R.BUILDING, NEW DELHI, NEW DELHI-110002, 601, HEMKUNT CHAMBERS,, DELHI Vs. 89, NEHRU PLACE, NEW DELHI NEW DELHI-110019, DELHI अपीलधर्थी Appellant प्रत्यर्थी Respondent

Permanent Account Number of Assessee: AABCN6304Q

अपीलधर्थी द्वारा/Appellant represented by: Shri M. Venkata Ramesh, Sr. DR Shri Salil Aggarwal, Sr. Adv., Shri प्रत्यर्थी द्वारा/Respondent represented by: Shailesh Gupta, CA & Shri Uma Shankar, Adv.

सुनवाई की तारीख / Date of conclusion of hearing: 13-Jul-2026 घोषणा की तारीख / Date of pronouncement: 10-Sep-2026

ITA 5935/D

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