COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 467/KOL/2018Status: DisposedITAT Kolkata20 January 2026AY 2012-1393 pages
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What did the Tribunal hold?

The Tribunal held that the disallowance computed as per Rule 8D cannot be applied under Section 115JB, as Section 14A is restricted to normal computation of income. The matter regarding computation under Rule 8D(iii) was remanded back to the Assessing Officer. Certain grounds of the assessee were dismissed, while others were partly allowed.

What were the facts?

The appeals by both the assessee (M/s. Coal India Ltd.) and the Revenue concerned assessment years 2011-12 to 2014-15. Key issues involved disallowances on account of provision for mark to market loss, period expenditure, undisclosed income, notional lease rent, penalty charges, and provisions for mine closure, among others. The Revenue also contested the deletion of disallowances under Section 14A and additions related to interest earned on shifting and rehabilitation funds.

What were the issues?

Whether disallowances under Section 14A, computed as per Rule 8D, can be applied for computing book profits under Section 115JB. Whether the Assessing Officer recorded the necessary objective satisfaction before invoking Rule 8D.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB

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Cases cited in this judgment(20)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH, KOLKATA Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.: 466/KOL/2018

Assessment Year: 2011-12 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata Vs. (Appellant) (Respondent) PAN: AABCC3929J ITA No.: 622/KOL/2018

Assessment Year: 2011-12 DCIT, Circle-5(1), Kolkata (Appellant) Vs. M/s. Coal India Ltd. (Respondent) PAN: AABCC3929J ITA No.: 467/KOL/2018

Assessment Year: 2012-13 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata (Appellant) Vs. (Respondent) PAN: AABCC3929J ITA No.: 623/KOL/2018

Assessment Year: 2012-13 DCIT, Circle-5(1), Kolkata (Appellant) Vs. M/s. Coal India Ltd. (Respondent) PAN: AABCC3929J ITA No.: 1406/KOL/2019

Assessment Year: 2013-14 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata (Appellant) Vs. (Respondent) PAN: AABCC3929J ITA No.: 1696/KOL/2019

Assessment Year: 2013-14 DCIT, Circle-5(1), Kolkata (Appellant) Vs. M/s. Coal India Ltd. (Respondent) PAN: AABCC3929J ITA No.: 1407/KOL/2019

Assessment Year: 2014-15 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata (Appellant) Vs. (Respondent) PAN: AABCC3929J ITA No.: 1697/KOL/2019

Assessment Year: 2014-15 DCIT, C

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