RAMANAGARAM ENTERPRISES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD
What did the Tribunal hold?
The Tribunal ruled that once an NCLT-approved resolution plan under Section 31(1) of IBC, 2016, becomes binding, all pre-CIRP claims, including those of the Income Tax Department, are frozen and must be given effect as per Supreme Court precedents. The CIT(A) erred in dismissing the appeals as non-maintainable. The matter was remanded to the Assessing Officer to pass consequential orders under Section 156A of the Income Tax Act, 1961, consistent with the NCLT's resolution plan for both assessment years.
What were the facts?
The assessee, engaged in hydropower, faced additions under Section 14A during assessments for AY 2017-18 and 2018-19. Concurrently, a Corporate Insolvency Resolution Process (CIRP) under IBC, 2016, was initiated, and the NCLT approved a resolution plan that included the Income Tax Department's claim for AY 2017-18. The CIT(A) dismissed the assessee's appeals in limine, deeming them non-maintainable due to the IBC proceedings.
What were the issues?
Whether Income Tax appeals are maintainable after an NCLT-approved resolution plan under IBC, 2016, is in effect, and if the Assessing Officer is obligated to pass consequential orders giving effect to such a plan.
Which sections of the Income-tax Act were involved?
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Cases cited in this judgment(1)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Ghanashyam Mishra And Sons. v. Edelweiss Asset Reconstruction192 citing126 Taxmann.com 132 · 2021 · SC
Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad
आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-
1. 1. निर्धाररती/The Assessee : Ramanagaram Enterprises Private Limited, Plot No.18, iLabs Centre, Building 3, Software Units Layout, Madhapur – 500081, Hyderabad. 2. रधजस्व/ The Revenue : The Assistant Commissioner of Income Tax, Circle 16(1), Hyderabad / The Deputy Commissioner of Income Tax, Central Circle 2(1), Hyderabad.
More judgments on Section 14A
- Blacksoil Capital Private Limited (As… vs DCIT, Circle-1(1), HyderabadITA 2217/HYD/2026[2017-18]Status: Disposed9 Oct 2026AY 2017-18
- Hiral Construction, Mumbai vs ITO Ward 42(1)(2), MumbaiITA 8431/MUM/2025[2017-18]Status: Disposed8 Oct 2026AY 2017-18
- The Dy DIT (It) 1(2), Mumbai vs M/S Citi Bank N.A, MumbaiITA 4981/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S. Citi Bank N.A., Mumbai vs The Addl DIT (It) RG-1, MumbaiITA 4970/MUM/2007[2002-2003]Status: Disposed8 Oct 2026AY 2002-2003
- M/S American Express Bank Ltd., Mumbai vs The Jt DIT (It)1(1), MumbaiITA 9414/MUM/2004[2000-2001]Status: Disposed8 Oct 2026AY 2000-2001
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