CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

ITA 2866/CHNY/2024Status: DisposedITAT Chennai05 May 2025AY 2014-1518 pages
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What did the Tribunal hold?

The Tribunal held that for Section 14A disallowances, only investments yielding exempt income should be considered. Regarding depreciation on capital subsidy, the Tribunal ruled that the subsidy amount cannot be reduced from the actual cost of the capital asset for depreciation calculation.

What were the facts?

The assessee company appealed against disallowances made by the Assessing Officer (AO) and confirmed by the CIT(A) concerning Section 14A disallowances and depreciation on capital subsidy. The appeals covered multiple assessment years.

What were the issues?

Whether disallowance under Section 14A should be based on all investments or only those yielding exempt income, and whether capital subsidy reduces the actual cost for depreciation.

Which sections of the Income-tax Act were involved?

Section 14A,Section 43(1),Section 35(2AB)

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, ‘A BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI

Hearing: 27.03.2025Pronounced: 05.05.2025

PER MANU KUMAR GIRI, JM: The captioned appeals filed by the assessee are directed against separate orders of the Ld. Commissioner of Income Tax (Appeals)(NFAC), Delhi [CIT(A)]all dated10.09.2024 for Assessment Years 2010-11, 2014-15, 2016-17 and 2018-19.Since the facts and issues are common in these appeals, they are heard t

The order continues below.

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