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Facts
The assessee, Bihar State Road Development Corporation Limited, filed six appeals against the orders of the Commissioner of Income Tax (Appeals). The appeals relate to assessment years 2012-13 to 2018-19. The core issues involve the disallowance of Corporate Social Responsibility (CSR) expenses and deductions claimed under Section 80-IA for interest income.
Held
The Tribunal found that some documents and an additional ground of appeal were filed for the first time and had not been considered by the lower authorities. In the interest of justice, the Tribunal set aside the orders of the CIT(A) and remitted the matters back to the CIT(A) for fresh adjudication, considering these new submissions.
Key Issues
Whether the disallowance of CSR expenses and deductions under Section 80-IA for interest income was justified, considering the timing of legislative amendments and the nature of the income.
Sections Cited
Sec 250, Sec 143(3), Sec 147, Sec 144, Sec 263, Sec 148, Sec 143(2), Sec 142(1), Sec 37(1), Sec 80-IA, Sec 115JB
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Income Tax Appellate Tribunal, PATNA BENCH AT KOLKATA
Before: SHRI SONJOY SARMA & SHRI RAKESH MISHRA
Bihar State Road Development ACIT, Circle-2, Patna Corporation Limited (BSRDCL) Vs. Income Tax Department, NFAC, Delhi (Appellant) (Respondent) PAN: AADCB7567M Appearances: Assessee represented by : Abhi Sarkar, AR. Department represented by : Rajat Datta, CIT. Date of concluding the hearing : 15-July-2025 Date of pronouncing the order : 24-July-2025 ORDER PER BENCH: These six appeals filed by the assessee are against the separate orders of the Commissioner of Income Tax (Appeals)-NFAC, Delhi