MAHASHAKTI CEMENTS,GUWAHATI vs. INCOME TAX OFFICER, WARD- 2(1), GUWAHATI, GUWAHATI

ITA 286/GTY/2025Status: DisposedITAT Guwahati23 June 2026AY 2012-138 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the assessee's appeal, noting that the assessee failed to provide evidence to establish the direct link between the fixed deposit interest income and business operations, despite multiple opportunities and clear directions from the ITAT. The Tribunal also refused to accept additional evidence at this stage.

What were the facts?

The assessee claimed deduction under Section 80IE on interest earned from fixed deposits held as security for a business loan. The Assessing Officer (AO) and Commissioner (Appeals) disallowed this deduction, stating the interest income was not business income. The ITAT had previously remanded the issue to the AO for verification of the link between the FDs and business credit facilities.

What were the issues?

Whether interest income earned on fixed deposits made as security for business loans is eligible for deduction under Section 80IE. Whether the assessee has provided sufficient evidence to prove the nexus between the fixed deposits and business credit facilities.

Which sections of the Income-tax Act were involved?

Section 80IE,Section 144,Section 254,Section 144B,Section 142(1),Section 263,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH, GUWAHATI

For Appellant: Shri Anil Kumar Agarwala, FCA
For Respondent: Shri Santosh Kumar Karnani, Addl. CIT
Hearing: 21.05.2026Pronounced: 23.06.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)] dated

2 Mahashakti Cements 29.07.2025, DIN & order No. ITBA/NFAC/S/250/2025- 26/1079043154(1) on the following grounds of appeal:

“1. For that on the facts and circumstances of the case, the Learned Commissioner of Income Tax (Appeals) erred in law as well as on facts in upholding the a

The order continues below.

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