N.R.AGARWAL INDUSTRIES LIMITED,MUMBAI vs. CIRCLE 2(3)(1), MUMBAI

ITA 6582/MUM/2025Status: DisposedITAT Mumbai14 August 2026AY 2018-1936 pages
AI SummaryAllowed

What were the facts?

The assessee claimed deduction under Section 80-IA(4) for its captive cogeneration power plant. The dispute arose over allocating costs to low-pressure steam supplied to its paper division, which the CIT(A) deemed to have nil cost.

What did the Tribunal hold?

The Tribunal held that low-pressure steam, being a useful output of the cogeneration process, cannot be assigned a nil cost. The entire common cost of the plant cannot be charged solely against electricity revenue.

What were the issues?

Whether the cost of low-pressure steam generated by a captive cogeneration plant, supplied to the assessee's paper division, can be considered as nil for the purpose of calculating deduction under Section 80-IA.

Which sections of the Income-tax Act were involved?

Section 80-IA(4),Section 250,Section 143(3),Section 144B,Section 80-IA(8)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH MUMBAI

For Appellant: Shri Biren Shah, (Virtually appeared)
For Respondent: Shri Yogesh Kamat, CIT DR
Hearing: 23.06.2026Pronounced: 14.08.2026

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal by the assessee is directed against the order dated 01.09.2025 passed by the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi

2 N. R. Agarwal Industries Limited [“CIT(A)”], under section 250 of the Income-tax Act, 1961 [“the Act”], for the assessment year 2018-19. The impugned appellate order arises from the assessment order dated 22.04.2021 passed by the National e-Assessment Centre [“the Assessing Officer”] under section 143(3) read with section 144B of the Act.

2.

The assessee has raised the

The order continues below.

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