DCIT 2(3)(1), MUMBAI vs. TATA STEEL LTD, MUMBAI

ITA 3555/MUM/2016Status: DisposedITAT Mumbai20 February 2026AY 2008-091 pages
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What did the Tribunal hold?

The Tribunal held that the interest expenditure incurred by the assessee for acquiring Corus was for business purposes and thus allowable under Section 36(1)(iii). The legal contentions regarding the reopening of assessment were left undecided as the appeal was decided on merits.

What were the facts?

The assessee, Tata Steel Ltd., filed appeals against the reopening of its assessment and disallowance of interest on borrowed capital used for acquiring equity in Corus Group plc. The Revenue also appealed against the deletion of an addition related to alleged excess mining.

What were the issues?

The primary issues were the validity of the assessment reopening and the allowability of interest expenditure on borrowed funds used for acquiring a foreign subsidiary.

Which sections of the Income-tax Act were involved?

Section 36(1)(iii),Section 147,Section 148,Section 151,Section 57(iii)

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Income Tax Appellate Tribunal, “H” BENCH MUMBAI

Before: SMT. BEENA PILLAI & SHRI GIRISH AGRAWAL

Hearing: 25.11.2025Pronounced: 20.02.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These are cross appeals filed by the assessee and the Revenue against the order of CIT(A)-6, Mumbai, vide order no. CIT(A)-6/IT- 182/2013-14, dated 05.03.2014, passed against the assessment order by ACIT 2(3), Mumbai, u/s. 143(3) r.w.s. 147 of the Income-tax Act AY 2008-09 (hereinafter referred to as the “Act”), dated 07.02.2014 for Assessment Year 2008-09. 2. Grounds taken by the assessee are reproduced as under: “1 The Learned Commissioner of Income-tax (Appeals) (" Ld. CIT(A)"] erre

The order continues below.

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