CIT v. Bokaro Steel Ltd.

236 ITR 315Supreme Court of India1999#199 most cited

What is CIT v. Bokaro Steel Ltd. authority for?

Interest earned during the pre-commencement period of a project, on advances made to contractors or on unutilized borrowed funds, if inextricably linked to the setting up of the plant, constitutes a capital receipt. Such interest is not taxable as income but can be reduced from the capital work-in-progress.

370

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. Bokaro Steel Ltd. · 236 ITR 315 · pre-commencement interest · capital receipt · income from other sources · unutilized borrowed funds · advances to contractors · capital work-in-progress · Section 56 · Section 28 · setting up of plant

Also reported as

102 Taxmann 94

Sections most often in play

Section 37(1)Section 143(3)Section 199Section 250Section 142(1)Section 143(2)Section 32Section 194A

Issues it is cited on

section 32(1)section 22section 57section 56section 32profits and gains of business or professionadvance taxsection 37(1)revenue expenditureincome from other sourcessection 28section 37

Judgments citing CIT v. Bokaro Steel Ltd.

VNG AUTOMOTIVE P. LTD. vs. ASSTT. COMMISSIONER OF INCOME

The appeals are disposed of as allowed

ITA-795/2004HC Delhi10 Apr 2026
For Appellant: Mr. Satyen Sethi & Mr. Arta Trana PandaFor Respondent: Mr Abhishek Maratha, SSC, Mr Apoorv
Section 148

…Page 3 of 30 filed the appeal before the ITAT. 5. The ITAT, vide order dated 23.06.2004, set aside the order of CIT(A) and held that the decisions of CIT v. Bokaro Steel Ltd. 236 ITR 315 (SC) and CIT v. Karnal Cooperative Sugar Mills Ltd., 243 ITR 2(SC), as relied upon by CIT(A), were not applicable and as such, interest received was wrongly adjusted against project expenses. Accordingly, the interest income was liable to be taxed separately as “income from other sources”. 6. Aggrieved by the common order of the ITAT, the…

SHREENATH REALTORS,MUMBAI vs. INCOME TAX OFFICER WARD 19(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 7295/MUM/2025[2017-2018]Status: DisposedITAT Mumbai01 Apr 2026AY 2017-2018

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarshreenath Realtors, Ito Ward - 19(3)(1), 10 Patel Mansion, Mumbai Proctor Road, Grant Vs. Piramal Chambers, Road, Mumbai-400 007 4Th Floor, Room No. 405, Dr. Ss Rao Marg, Parel, Mumbai – 400 012 Pan/Gir No. Abifs7530G (Applicant) (Respondent) Assessee By Ms. Priyanka Jain, Ld. Ar Revenue By Smt. Usha Gaikwad, Ld. Dr Date Of Hearing 16.03.2026 Date Of Pronouncement 01.04.2026

Section 143(3)Section 250Section 270ASection 56

…t the nexus between the fixed 4 Shreenath Realtors deposits and the project continued to exist and the interest income could not be treated as income from other sources. Reliance was placed on various judicial precedents including CIT vs. Bokaro Steel Ltd. (236 ITR 315), CIT vs. Karnal Cooperative Sugar Mills Ltd. (243 ITR 2), and CIT vs. Indian Oil Panipat Power Consortium Ltd. (315 ITR 255), to contend that interest earned on funds intrinsically linked to a project is required to be capitalized. The assessee also relied upon Accounting Standard AS-16 to support capitalization of such income. 6. The learned CI…

MUMBAI INTERNATIONAL AIRPORT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

…ee treated as income inextricably linked with the project funds and accordingly adjusted against the project cost. Mumbai International Airport Ltd., Mumbai 46. The assessee further relied upon various judicial precedents including CIT vs. Bokaro Steel Ltd. (236 ITR 315), CIT vs. Karnal Co-operative Sugar Mills Ltd. (243 ITR 2), CIT vs. Karnataka Power Corporation (247 ITR 268) and Bongaigaon Refinery & Petrochemicals Ltd. vs. CIT (251 ITR 329) to contend that income earned during the construction stage having direct nexus with the project should go to reduce the project cost. 47. The Assessing Officer, however…

DCIT-4(1), INDORE, INDORE vs. MARAL OVERSEAS LTD, KHARGONE

In the result, the “Impugned

ITA 569/IND/2025[1992-93]Status: DisposedITAT Indore27 Feb 2026AY 1992-93

Bench: Shri B.M. Biyani & Shri Paresh M Joshideputy Commissioner Of Maral Overseas Ltd. बनाम/ Income Tax- 4(1) Maral Srovar, V & Po, Vs. Indore Khalbujurg, Kasrawad, Khargone, Bhopal (Pan: Aaccm0230B) (Appellant) (Respondent) Assessee By Shri Satyajeet Goyal, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 27.02.2026

Section 143(3)Section 250Section 253

…आयकरअपीलीयअिधकरण,इंदौर"ायपीठ,इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER Deputy Commissioner of Maral Overseas Ltd. बनाम/ Income Tax- 4(1) Maral Srovar, V & PO, Vs. Indore Khalbujurg, Kasrawad, Khargone, Bhopal (PAN: AACCM0230B) (Appellant) (Respondent) Assessee by Shri Satyajeet Goyal, CA Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 03.02.2026 Date of Pronouncement 27.02.2026 आदेश/ O R D E R Per Paresh M Joshi, J.M.: This is an Appeal filed by the Revenue under section 253 of the income tax Act 1…

MAX SQUARE LTD,NOIDA vs. ITO WARD-5(1)(5), NOIDA

In the result, the appeal of the assessee is dismissed

ITA 4100/DEL/2025[2021-22]Status: DisposedITAT Delhi13 Feb 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2021-22] Max Square Ltd. Vs Ito L-12, Max Tower, Sector-16-B Ward-5(1)(5) Gautam Budha Nagar Noida Noida, Uttar Pradesh-201301 Pan-Aagcn5808G Appellant Respondent Appellant By Shri Anil Bhalla, Ca & Shri Nitin Kumar Sharma, Ca Respondent By Shri Gouranga Chandra Das, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 30.05.2025 Of Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2020-21/10308419 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 07.12.2023 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2021-22. 2. Brief Acts Of The Case Are That The Assessee Is A Company, Engaged In The Business Of Real Estates Development & Started Construction Of Commercial Complex Project “Max Square” At Sector 129, Noida. The Assessee Borrowed Funds From Indusind Bank Amounting To Inr 29.45 Crores For The Construction & Further Raised Funds Through Issue Of Equity/Ccd’S. The Funds Which Remained Un-Utilized, Were Invested Temporary In Fdrs From Which Interest Was Received Of Inr 63,77,502/- & Was Credited To The Cost Of Construction. However, The Ao Has Held The Same As Taxable Under The Head “Income From Other Sources”.

Section 143(3)Section 250

…been adjusted against the cost of the asset, in accordance with judicial precedents. 1.1. The Learned CIT(A) has erred both on and in law in disregarding the binding judicial pronouncements of the Hon'ble Supreme Court in the case of Bokaro Steel Ltd. [1999] 236 ITR 315 (SC), and the Hon'ble Delhi High Court in the cases of NTPC Sail Power Company (P) Ltd. [2012] 25 taxmann.com 401 (Del) and Indian Oil Panipat Power Consortium Ltd. [2009] 315 ITR 255 (Del), which have clearly held that interest earned from temporary parking of borrowed funds intended for project development is inextricably linked to the setting…

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 104/ASR/2024[2017-18]Status: DisposedITAT Amritsar15 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

Section 143(3)Section 148Section 250Section 35A

…are taxable as business income and not as income from other sources. a. Tuticorin Alkali Chemicals & Fertilisers Ltd. v. CIT [1997] 227 ITR 172 (SC) b. CIT v. Karnal Co-operative Sugar Mills Ltd. [2001] 118Taxman489 (SC) c. CIT v. Bokaro Steel Ltd. [1999] 236 ITR 315 (SC) d. CIT v. Shahi Export House [2010] 195 taxman 163 (Delhi HC) e. DCIT vs. G. G. Continental Traders (P.) Ltd. [2023] 151 taxmann.com 384 (Amritsar - Trib.) I.T.A. No. 103 & 104/Asr/202 1 Assessment Years: 2014-15 and 2017-18 5 7.2. Hence, going by the above judgements, I hold that the income earned on such fixed deposits were rightly ad…

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

ITA 103/ASR/2024[2014-15]Status: DisposedITAT Amritsar15 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

Section 143(3)Section 148Section 250Section 35A

…are taxable as business income and not as income from other sources. a. Tuticorin Alkali Chemicals & Fertilisers Ltd. v. CIT [1997] 227 ITR 172 (SC) b. CIT v. Karnal Co-operative Sugar Mills Ltd. [2001] 118Taxman489 (SC) c. CIT v. Bokaro Steel Ltd. [1999] 236 ITR 315 (SC) d. CIT v. Shahi Export House [2010] 195 taxman 163 (Delhi HC) e. DCIT vs. G. G. Continental Traders (P.) Ltd. [2023] 151 taxmann.com 384 (Amritsar - Trib.) I.T.A. No. 103 & 104/Asr/202 1 Assessment Years: 2014-15 and 2017-18 5 7.2. Hence, going by the above judgements, I hold that the income earned on such fixed deposits were rightly ad…

POWERGRID RAMPUR SAMBHAL TRANSMISSION LIMITED,DELHI vs. ITO WARD 20(1), DELHI

The appeal stands dismissed

ITA 5236/DEL/2025[2022-23]Status: DisposedITAT Delhi07 Jan 2026AY 2022-23

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

For Appellant: Department byFor Respondent: Shri Ved Jain, Adv., Shri Pawan Garg
Section 143(1)Section 143(1)(a)Section 154Section 199Section 244ASection 250

…from the cost of project due to it being a Capital Receipt and inextricably linked to the construction activity (PB Page 134 & 138). 5.4 Reliance was placed on judgement of Hon'ble Supreme Court in the case of Commissioner of Income-tax v. Bokaro Steel Ltd. - 236 ITR 315 (SC)-dated 18.12.1998. ITAT Delhi judgement in the assessee's group case entity, namely, Power Grid Mithilanchal Transmission Limited, ITA No:- 68/Del/2023, Dated-30.11.2023. 6. Learned Authorised Representative for Department of Revenue relied on order of Ld. CIT(A). 7. From examination of record in the light of aforesaid rival contentions, it i…

VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1315/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Sandeep Bagmar R, AdvocateFor Respondent: MS. U. Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 32

…0/Ahd/2010. 2. M/s Avnet India Pvt. Ltd vs Deputy Commissioner of Income-tax (IT(TP)A No.757(Bang)/2011). 3. GSS Infotech Ltd. vs., ACIT (ITA No 497/Hyd./2015) 4. Ingersoll Rand (India) Ltd vs., DCIT (IT.(TP).A No.228/Bang/2015). 5. CIT vs., Bokaro Steel Ltd. 236 ITR 315. 6. Nimbus Communications Ltd. (ITA No. 6579/Mum/09). 9. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Final 25 ITA.No.1315 /Hyd./2024 Assessment Order of the Assessing Officer passed in pursuance to the Directions of the DRP submitted that, the A.O. has rightly disallowed depreciation claimed on the bu…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. CHENANI NASHRI TUNNELWAY LIMITED, MUMBAI

ITA 4686/MUM/2025[2012-13]Status: HeardITAT Mumbai29 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Mr. Bhupal RapelliFor Respondent: Mr. Virabhadra S. Mahajan, Sr.DR

…ted as capital work-in-progress. Further reliance was placed on the decision of the Hon'ble Delhi High Court in the case of Indian Oil Panipat Power Consortium Ltd., 181 Taxman 249 and the decision of the Hon'ble Supreme Court in the case of Bokaro Steel Ltd. 236 ITR 315 and it was submitted that the interest earned be treated as business receipt having the character of capital in nature and the same can be reduced from the capital work-in-progress and the same need not be offered to tax separately in the hands of the assessee. 4. The submissions of the assessee were considered but not found acceptable to the AO…

M/S RPJ MINERALS PVT. LTD ,MAIHAR vs. INCOME TAX OFFICER, WARD -1,SATNA, SATNA

ITA 86/JAB/2022[2017-18]Status: DisposedITAT Jabalpur19 Sept 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

…bly linked with the setting up of the project of the assessee company. In view of this factual position, the assessee, after considering the ratio laid down by the Hon'ble Supreme Court in the case of Commissioner of Income tax vs. Bokaro Steel Limited (1999) 236 ITR 315 (SC) had reduced interest received from the capital work in progress, which also included the capitalization of interest paid on the amount borrowed, at Rs.748.09 Lacs. It was submitted that the facts of the assessee's case were distinguishable from the facts of the case in the case of Tuticorin Alkali Chemicals and Fertilizers Limited vs. CIT (1…

INCOME TAX OFFICER WARD-1 vs. M/S RPJ MINERALS PRIVATE LTD., SATNA

ITA 154/JAB/2016[2012-13]Status: DisposedITAT Jabalpur19 Sept 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: NoneFor Respondent: Sh. Shrawan Kumar Meena, CIT DR
Section 143(3)Section 234ASection 43B

…bly linked with the setting up of the project of the assessee company. In view of this factual position, the assessee, after considering the ratio laid down by the Hon'ble Supreme Court in the case of Commissioner of Income tax vs. Bokaro Steel Limited (1999) 236 ITR 315 (SC) had reduced interest received from the capital work in progress, which also included the capitalization of interest paid on the amount borrowed, at Rs.748.09 Lacs. It was submitted that the facts of the assessee's case were distinguishable from the facts of the case in the case of Tuticorin Alkali Chemicals and Fertilizers Limited vs. CIT (1…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 343/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 342/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 341/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 340/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 339/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

DCIT, CIRCLE-1(1), VIJAYAWADA vs. TRANSMISSION CORPORATION OF ANDHRA PRADESH LIMITED, VIJAYAWADA

In the results, appeals filed by the revenue in ITA Nos

ITA 335/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

…me Tax (International Taxation)-l, Hyderabad reported in- (2014) 45 Taxmann.com 339. 6. CIT v Punjab State E-Governance Society in ITA No. 75 of 2011. The assessee also relied on the ratio laid down by the Hon'ble Supreme Court in the case of M/s Bokaro Steel 236 ITR 315 (SC) to contend that interest which is inextricably connected to the Capital Grant is to be treated as Capital Receipt only which will go to reduce the cost of the Capital Asset that is corning into existence by the utilisation of the Capital Grant along with the interest thereon. Further, it was pointed out that the interest earned was reduced w…

M/S BROOKS LABORATORIES LTD. ,BADDI vs. ACIT, CIRCLE , PANCHKULA

The appeal stands dismissed

ITA 596/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh20 May 2025AY 2016-17

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) & Ms. DeepaliFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld.Sr. DR
Section 143(3)

…cted with the setting up of a new plant. In the case of Tuticorin Alkali Chemical and Fertilizers Ltd. (227 ITR 172), it was held that interest received on surplus funds would have to be treated as income from other sources, In the case of Bokaro Steel Ltd. (236 ITR 315), the assessee earned interest on advances paid to the contractors during pre-commencement period and the same was found to be inextricably linked to the setting up of the plant of the assessee and accordingly, held as capital receipt. However, the same was not the case here. Finally, the action of Ld. AO was upheld against which the assessee is…

M/S BROOKS LABORATORIES LIMITED,SOLAN vs. DCIT, PANCHKULA

The appeal stands dismissed

ITA 530/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh20 May 2025AY 2014-15

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar (CA) & Ms. DeepaliFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld.Sr. DR
Section 143(3)

…cted with the setting up of a new plant. In the case of Tuticorin Alkali Chemical and Fertilizers Ltd. (227 ITR 172), it was held that interest received on surplus funds would have to be treated as income from other sources, In the case of Bokaro Steel Ltd. (236 ITR 315), the assessee earned interest on advances paid to the contractors during pre-commencement period and the same was found to be inextricably linked to the setting up of the plant of the assessee and accordingly, held as capital receipt. However, the same was not the case here. Finally, the action of Ld. AO was upheld against which the assessee is…

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