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

ITA 623/KOL/2018Status: DisposedITAT Kolkata20 January 2026AY 2012-1393 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal condoned the delay in the Revenue's appeals. Regarding Section 14A, the Tribunal remanded the issue of disallowance to the Assessing Officer for re-computation, excluding investments in subsidiaries that did not pay dividends. The disallowance under Section 14A was held not applicable for computation under Section 115JB.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) heard cross-appeals by the assessee (M/s. Coal India Ltd.) and the Revenue concerning assessment years 2011-12 to 2014-15. The appeals involved issues related to disallowances under Section 14A, provisions for mark-to-market loss, mine closure, notional lease rent, and interest on rehabilitation funds.

What were the issues?

The key issues were the applicability and computation of disallowances under Section 14A, particularly concerning investments in subsidiaries and the application of Rule 8D, and whether such disallowances could be extended to book profit computation under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(21)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

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 M/s. Coal India Ltd. (Appellant) Vs. (Respondent) PAN: AABCC3929J ITA No.: 467/KOL/2018 Assessment Year: 2012-13 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata Vs. (Appellant) (Respondent) PAN: AABCC3929J ITA No.: 623/KOL/2018 Assessment Year: 2012-13 DCIT, Circle-5(1), Kolkata M/s. Coal India Ltd. (Appellant) Vs. (Respondent) PAN: AABCC3929J ITA No.: 1406/KOL/2019 Assessment Year: 2013-14 M/s. Coal India Ltd. DCIT, Circle-5(1), Kolkata Vs. (Appellant) (Respondent) PAN: AABCC3929J ITA No.: 1696/KOL/2019 Assessment Year: 2013-14 DCIT, Circle-5(1), Kolkata M/s. Coal India Ltd. (Appellant) Vs. (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, Circle-5(1),

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 14A

All 15,875 judgments and leading authorities on Section 14A →

Recent GST High Court judgments

Search GST case law →