SANJANA CRYOGENIC STORAGES LTD ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

ITA 1923/MUM/2026Status: DisposedITAT Mumbai10 July 2026AY 2022-235 pages
AI SummaryDismissed

What were the facts?

The assessee claimed depreciation on 'Iron Ore Rights' as intangible assets. The Assessing Officer disallowed this claim, and the CIT(A) upheld the disallowance. The assessee argued that similar claims were allowed in preceding years and that the issue was pending before the Bombay High Court.

What did the Tribunal hold?

The Tribunal dismissed the assessee's appeal, noting that a coordinate bench had previously held that depreciation on such rights was not admissible. The AO was directed to apply the decision of the Bombay High Court if it differed.

What were the issues?

Whether depreciation is allowable on 'Iron Ore Rights' as intangible assets. Whether the assessment order was passed without jurisdiction.

Which sections of the Income-tax Act were involved?

Section 32,Section 143(3),Section 144B,Section 234B,Section 270A,Section 158A

AI-generated summary — verify with the full judgment below

Before: SHRI JUSTICE (RETD.) C. V. BHADANG & SHRI PRABHASH SHANKARDr.

For Appellant: Shri M.P. Lohia,AR
For Respondent: Shri Basavaraj Hiremath, CIT-DR
Hearing: 25.06.2026Pronounced: 10.07.2026

PER PRABHASH SHANKAR [A.M.] :- The present appeal emanating from the appellate order dated 30.12.2025 is preferred by the assessee against the order passed by the Learned Commissioner of Income-tax, Appeal, CIT(A)-50, Mumbai [hereinafter referred to as “CIT(A)”] pertaining to the assessment order passed u/s. 143(3) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 30.03.2025 for the Assessment Year [A.Y.] 2022-23. P a g e | 2 A.Y. 2022-23 Sanjana Cryogenic Storages Ltd.

2.

The grounds

The order continues below.

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