PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT, CIRCLE-1(1), CUTTACK

ITA 729/CTK/2025Status: DisposedITAT Cuttack22 June 2026AY 2023-2413 pages
AI SummaryAllowed

What were the facts?

The assessee challenged additions made by the AO and confirmed by the CIT(A) regarding disallowance of expenses under Section 14A, CSR expenses, and provisions for salary, wages, and provident fund. The assessee argued that its status as a statutory authority under the Major Port Trust Act exempts it from certain provisions applicable to companies.

What did the Tribunal hold?

The Tribunal held that disallowance under Section 14A should be restricted to investments yielding exempt income. It also ruled that CSR expenses are allowable for the assessee as it is not registered under the Companies Act. Finally, it allowed provisions for salary, wages, and provident fund, stating they are ascertained liabilities under an approved accrual accounting framework.

What were the issues?

Whether disallowance under Section 14A should be on all investments or only those yielding exempt income, and whether CSR expenses and provisions for salary, wages, and PF are allowable for a statutory port authority.

Which sections of the Income-tax Act were involved?

Section 14A,Section 37(1),Section 36(1)(iv)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH: CUTTACK

Before: Shri George Mathan&Shri Rajesh Kumar]

Per Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 13.10.2025 for the AY 2023-24. 2. Issue raised in ground no. 1 is against the confirmation of addition of Rs. 4,76,36,626/- by the Ld. CIT(A) as made by the AO u/s 14A of the Act on account of expenses relating to earning of exempt income.

2 Assessment Year: 2023-24 Paradip Port Authority

3.

Facts in brief are that during the course of ass

The order continues below.

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