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

ITA 622/KOL/2018Status: DisposedITAT Kolkata20 January 2026AY 2011-1293 pages
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What did the Tribunal hold?

The Tribunal decided that interest earned on the Shifting & Rehabilitation Fund, where the assessee acted merely as a custodian with no control or beneficial use, did not constitute taxable income. The assessee's role was to pool and utilize funds for specific rehabilitation purposes as directed by the government.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) heard cross-appeals filed by the assessee (M/s. Coal India Ltd.) and the Revenue for assessment years 2011-12 to 2014-15. The appeals involved various grounds, including disallowance of provision for mark-to-market loss, period expenditure, undisclosed income, notional lease rent, penalty charges, and issues related to Section 14A and interest earned on a shifting and rehabilitation fund.

What were the issues?

Whether interest earned on funds held by the assessee as a custodian, without beneficial use or control, is taxable as income. Whether provisions for mine closure and mark-to-market losses are allowable expenditures.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB

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Cases cited in this judgment(30)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. Vs. DCIT, Circle-5(1), Kolkata (Appellant) (Respondent) PAN: AABCC3929J ITA No.: 622/KOL/2018

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

Assessment Year: 2012-13 M/s. Coal India Ltd. Vs. DCIT, Circle-5(1), Kolkata (Appellant) (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. Vs. DCIT, Circle-5(1), Kolkata (Appellant) (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 Nos.: 466, 622, 467, 623/KOL/2018 & 1406, 1696, 1407, 1697/KOL/2019 AYs: 2011-12 to 2014-15 M/s. Coal India Ltd. ITA No.: 1407/KOL/2019

Assessment Year: 2014-15 M/s. Coal India Ltd. DCIT, Circl

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