DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

ITA 5142/MUM/2024Status: DisposedITAT Mumbai30 January 2026AY 2015-1624 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the CIT(A)'s decision regarding the adjustment on inter-unit transfer of power was correct, relying on previous judgments. The Tribunal also upheld the CIT(A)'s direction for re-computation of disallowance under Section 14A and its exclusion from book profit computation under Section 115JB, following the Special Bench decision in Vireet Investment (P) Ltd.

What were the facts?

The Revenue appealed against the CIT(A)'s deletion of an adjustment on inter-unit transfer of power and disallowance under Section 14A. The assessee filed cross-objections. The appeals and cross-objections were clubbed and heard together.

What were the issues?

Whether the adjustment on inter-unit transfer of power was correctly deleted by the CIT(A), and whether the disallowance under Section 14A and its addition to book profit were justified.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB,Section 41(1)

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Cases cited in this judgment(13)Show list

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Heard together (4 matters)

ITA No. 5142/MUM/2024
ITA No. 5143/MUM/2024
C.O. No. 257/Mum/2024
C.O. No. 258/Mum/2024

Read from the judgment's own cause title. This page is filed under one of them.

### IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI

## BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

ITA No. 5142/MUM/2024 (AY: 2015-16) ITA No. 5143/MUM/2024 (AY: 2016-17)

(Physical hearing)

| DCIT Circle- 5(2) (1), Mumbai,<br>Room No. 571, 5th Floor,<br>AayakarBhavan,M.K. Road, | vs | M/s JSW Steel Coated Products Limited,<br>JSW Centre, BandraKurla Complex,<br>Bandra East, Mumbai-400051. | |----------------------------------------------------------------------------------------|----|-----------------------------------------------------------------------------------------------------------| | Mumbai – 400020.<br>Appellant / Assessee | | [PAN:AACCM3988L]<br>Respondent / Revenue |

C.O. No. 257/Mum/2024 in ITA No. 5143/MUM/2024 (AY: 2016-17) C.O. No. 258/Mum/2024 in ITA No. 5142/MUM/2024 (AY: 2015-16)

| M/s JSW Steel Coated Products Limited,<br>JSW Centre, BandraKurla Complex,<br>Bandra East, Mumbai-400051. | Vs | DCIT Circle- 5(2) (1), Mumbai,<br>Room No. 571, 5th Floor,<br>AayakarBhavan, M.K. Road, | |-----------------

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