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

ITA 2868/CHNY/2024Status: DisposedITAT Chennai05 May 2025AY 2018-19Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal directed the AO to compute Section 14A disallowances considering only investments yielding exempt income. It allowed depreciation on capital subsidy, stating it cannot be reduced from the actual cost of the asset. For weighted deduction, the issue was remanded to await DSIR's reply.

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, depreciation on capital subsidy, and weighted deduction under Section 35(2AB). The appeals covered multiple assessment years.

What were the issues?

The key issues involved the correct computation of disallowance under Section 14A, the treatment of capital subsidy for depreciation, and the eligibility for weighted deduction under Section 35(2AB).

Which sections of the Income-tax Act were involved?

Section 14A,Section 43(1),Section 35(2AB),Section 80G

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Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI

Hearing: 27.03.2025Pronounced: 05.05.2025

आदेश आदेश

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 together an

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