TATA STEEL LIMITED (SUCCESSOR OF ANGUL ENERGY LIMITED),DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, NEW DELHI

ITA 4171/DEL/2024Status: DisposedITAT Delhi12 December 2025AY 2020-21Bench: Ms. MADHUMITA ROY, JUDICIAL MEMBER\nAND\nSMT. RENU JAUHRI, ACCOUNTANT MEMBER\nITA No. 4171/DEL/2024\nAssessment Year: 2020-21\nM/s Tata Steel Limited\n[Successor of Angul Energy Limited]\nBombay House-24,\nHomi Mody Street Fort,\nMumbai-400001.\nPAN: AACCB 7445 Η\nAPPELLANT\nAssessee represented by\nDepartment represented by\nDate of hearing\nDate of pronouncement\nVs\nACIT, Circle-1(1),\nNew Delhi.\nRESPONDENT\nMs. Kavita Jha, Sr. Adv. &\nSh. Akash Shukla, Adv.\nSh. S.K. Jadhav, CIT(DR)\n111 pages
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What did the Tribunal hold?

The Tribunal held that the reference to the TPO and the subsequent transfer pricing adjustment were invalid. This was because clause (i) of Section 92BA of the Income Tax Act, which defined specified domestic transactions to include interest payments, was omitted by the Finance Act, 2017, effective from April 1, 2017.

What were the facts?

The assessee, formerly Angul Energy Limited, received Inter Corporate Deposits (ICD) from its parent company, Tata Steel BSL Ltd., at a 10% interest rate. The Transfer Pricing Officer (TPO) made an adjustment of Rs. 12,19,11,871/- on this interest, considering it a specified domestic transaction.

What were the issues?

Whether the reference to the TPO under Section 92CA and the subsequent transfer pricing adjustment were valid for the Assessment Year 2020-21, given the omission of clause (i) of Section 92BA of the Act.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 92BA,Section 143(3)

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, DELHI BENCH “H”: NEW DELHI

Before: Ms. MADHUMITA ROY & SMT. RENU JAUHRI

For Appellant: Ms. Kavita Jha, Sr. Adv. &
Hearing: 10.12.2025

PER Ms. MADHUMITA ROY, JM:

The instant appeal, filed by the assessee, is directed against the Assessment

Order dated 31.07.2024 (DIN & Order No. ITBA/AST/S/143(3)/2024-

25/1067198746(1) passed by the Assistant Commissioner of Income Tax, Circle

1(1), Delhi, under Section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961

(hereinafter referred to as “the Act”), pursuant to the directions of the Learned

2 Dispute Resolution Panel (“DRP”) under Section 144C(5) of the Act for the Assessment Year 2022-23. 2. Grounds of appeal raised by the assessee are as under:

“1. General Ground

1.1.

That on the facts and in the circumstances of th

The order continues below.

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