M/S COAL INDIA LTD.,KOLKATA vs. DCIT, CIR-5(1), , KOLKATA

ITA 1407/KOL/2019Status: DisposedITAT Kolkata20 January 2026AY 2014-1593 pages
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What did the Tribunal hold?

The Tribunal held that interest earned on the Shifting & Rehabilitation Fund, where Coal India Ltd. acted merely as a custodian with no control or beneficial interest, could not be treated as the company's income. The interest was considered part of the fund itself and not 'real income' of the assessee.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) heard cross-appeals by M/s. Coal India Ltd. and the Revenue for assessment years 2011-12 to 2014-15. The appeals involved several grounds, including disallowances for provision for mark-to-market loss, period expenditure, undisclosed income, notional lease rent, penalty charges, and issues related to Section 14A and provisions for mine closure.

What were the issues?

Whether interest earned on a fund managed by the assessee as a custodian, without beneficial ownership or control, constitutes taxable income. Whether provisions for mine closure and mark-to-market losses are allowable.

Which sections of the Income-tax Act were involved?

Section 115JB,Section 14A

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Cases cited in this judgment(25)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 (Appellant) Vs. (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 (Appellant) Vs. (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 (Appellant) Vs. (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, Circl

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