DCIT,CIRCLE-1, RANCHI vs. TENUGHAT VIDYUT NIGAM LTD, RANCHI

ITA 360/RAN/2024Status: DisposedITAT Ranchi28 July 2026AY 2016-1718 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee is an instrumentality of the State, owned and controlled by the Government of Jharkhand. Therefore, it is considered a 'STATE' under Article 12 and entitled to immunity from Union taxation as per Article 289 of the Constitution.

What were the facts?

The assessee, Tenughat Vidyut Nigam Limited, a 100% government undertaking, claimed to be a 'STATE' under Article 12 of the Constitution, exempt from income tax under Article 289. The assessee is wholly owned by the Government of Jharkhand, with its operations and pricing controlled by the Jharkhand State Electricity Regulatory Commission.

What were the issues?

Whether a government-owned electricity generation company, whose operations and pricing are controlled by a state regulatory commission, qualifies as a 'STATE' for the purpose of income tax exemption under the Constitution.

Which sections of the Income-tax Act were involved?

Article 12, Article 289

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY

For Appellant: Shri Devesh Poddar, Adv
For Respondent: Shri Robindro Singh, CIT DR
Hearing: 28/07/2026Pronounced: 28/07/2026

Per Bench These are the appeals filed by the revenue and assessee, respectively against the order of the ld CIT(A), NFAC, Delhi dated 10.07.2024 in Appeal No. CIT(A), Ranchi/10282/2018-19 for the assessment year 2016-17. P a g e 1 | 18

ITA No. 360/RAN/2024 & ITA/162/RAN/2025 Assessment Year: 2016-17

2.

Shri Robindro Singh, Ld CIT DR appeared for the revenue and Shri Devesh Poddar, ld AR appeared for the assessee.

3.

At

The order continues below.

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