CIT v. Bokaro Steel Ltd.

236 ITR 315Supreme Court of India1999#200 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 367,518 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.

M/S Iifcl Asset Management Company Ltd., New Delhi vs. DCIT, New Delhi

In the result we answer the question as framed in favour of the assessee and against the revenue

ITA 2333/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri Saurav Rohtagi, CAFor Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 143(3)Section 3Section 71

…Alkali Chemicals 248 ITR 110 is factually distinguishable as in that case the funds were ‘surplus’ whereas in the in the instant case the funds were inextricably linked with the business of management of AMC. The decision in the case of Bokaro Steels Ltd. 236 ITR 315 applies to the factual matrix of the instant case as also the decision in the case of CIT vs Karnal Co-Operative Sugar Mills Ltd. [2000] 243 ITR 2(SC) on 23 April, 1999, wherein the hon’ble Supreme Court held as follows: “2. In the present case, the assessee had deposited money to open a letter of credit for the purchase of the machinery requi…

Assistant Commissioner of Income Tax, Chennai vs. Suryanarayana Iyer, Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 1491/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Oct 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1491/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 V. The Acit, Ncc-19(1), Mr. Suryanarayana Iyer, Chennai. Old No.3, New No.5, Third Street, Nehru Colony, Nanganallur, Chennai-600 061. [Pan: Aztps 0939 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Ms. G. Vardini KarthikFor Respondent: Dr. Samuel Pitta, JCIT
Section 194J

…e assessee- company had not been able to realize the enhanced charges. Since no real income having accrued, it was held that the amount due on enhancement was not assessable to Income Tax. In a subsequent decision rendered in CIT v. Bokaro Steel Ltd. [1999] 236 ITR 315, the Hon’ble Supreme Court, following its earlier decision in Godhra Electricity Co. Ltd.’s case (supra) affirmed the decision of the Patna High Court wherein it was held that the entry in the books of account shown as income from Hindustan Steel Ltd. for the 8 locomotives supplied by the assessee-company to them could not be brought to tax as…

Income Tax Officer Ward-1, Gondia vs. Shri Satishkumar Madanlal Gupta, Gondia

In the result, appeal filed by the assessee for the ay 2009–10 stands dismissed

ITA 29/NAG/2020[2011-12]Status: DisposedITAT Nagpur01 Aug 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri M.K.M. AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 69A

…dences in the interest of equity and natural justice. This is all the more important as it is only the real income of the assessee that can be taxed, under the Income Tax Act. As held by the Hon'ble Supreme Court in the case of CIT v. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), "any strait-jacket formula (to determine the income) is bound to create problems in its application to every situation, it must depend upon the facts and circumstances of each case. When and how does an income accrue and what are the consequences that follow from accrual of income are well settled. The accrual must be real taking into accou…

Income Tax Officer Ward-1, Gondia vs. Shri Satishkumar Madanlal Gupta, Gondia

In the result, appeal filed by the assessee for the ay 2009–10 stands dismissed

ITA 28/NAG/2020[2009-10]Status: DisposedITAT Nagpur01 Aug 2024AY 2009-10

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri M.K.M. AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 69A

…dences in the interest of equity and natural justice. This is all the more important as it is only the real income of the assessee that can be taxed, under the Income Tax Act. As held by the Hon'ble Supreme Court in the case of CIT v. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), "any strait-jacket formula (to determine the income) is bound to create problems in its application to every situation, it must depend upon the facts and circumstances of each case. When and how does an income accrue and what are the consequences that follow from accrual of income are well settled. The accrual must be real taking into accou…

Satish Kumar Madanlal Gupta, Gondia vs. Income Tax Officer Ward -1, Gondia

In the result, appeal filed by the assessee for the ay 2009–10 stands dismissed

ITA 24/NAG/2020[2011-12]Status: DisposedITAT Nagpur01 Aug 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri M.K.M. AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 69A

…dences in the interest of equity and natural justice. This is all the more important as it is only the real income of the assessee that can be taxed, under the Income Tax Act. As held by the Hon'ble Supreme Court in the case of CIT v. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), "any strait-jacket formula (to determine the income) is bound to create problems in its application to every situation, it must depend upon the facts and circumstances of each case. When and how does an income accrue and what are the consequences that follow from accrual of income are well settled. The accrual must be real taking into accou…

Satish Kumar Madanlal Gupta, Gondia vs. Income Tax Officer Ward -1, Gondia

In the result, appeal filed by the assessee for the ay 2009–10 stands dismissed

ITA 23/NAG/2020[2010-11]Status: DisposedITAT Nagpur01 Aug 2024AY 2010-11

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri M.K.M. AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 69A

…dences in the interest of equity and natural justice. This is all the more important as it is only the real income of the assessee that can be taxed, under the Income Tax Act. As held by the Hon'ble Supreme Court in the case of CIT v. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), "any strait-jacket formula (to determine the income) is bound to create problems in its application to every situation, it must depend upon the facts and circumstances of each case. When and how does an income accrue and what are the consequences that follow from accrual of income are well settled. The accrual must be real taking into accou…

Satish Kumar Madanlal Gupta, Gondia vs. Income Tax Officer Ward -1, Gondia

In the result, appeal filed by the assessee for the ay 2009–10 stands dismissed

ITA 22/NAG/2020[2009-10]Status: DisposedITAT Nagpur01 Aug 2024AY 2009-10

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri M.K.M. AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 69A

…dences in the interest of equity and natural justice. This is all the more important as it is only the real income of the assessee that can be taxed, under the Income Tax Act. As held by the Hon'ble Supreme Court in the case of CIT v. Bokaro Steel Ltd. (1999) 236 ITR 315 (SC), "any strait-jacket formula (to determine the income) is bound to create problems in its application to every situation, it must depend upon the facts and circumstances of each case. When and how does an income accrue and what are the consequences that follow from accrual of income are well settled. The accrual must be real taking into accou…

Ndtv Worldwide Ltd, New Delhi vs. DCIT 18(1), New Delhi

ITA 1180/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Jul 2024AY 2014-15

Bench: Shri G.S. Pannu & Shri Anubhav Sharmandtv Worldwide Ltd, Vs. Dcit, Okhla Industrial Estate, Circle-18(1), Phase-Ii, New Delhi New Delhi (Appellant) (Respondent) Pan: Aaccn9121G

For Appellant: Shri Rohit Tiwari, Ms Tanya &For Respondent: Shri Sandeep K Mishra &
Section 1Section 142Section 143Section 143(3)Section 2Section 3

…ubsequent date. Further judgments in this regards can be noted as CIT vs. Shoorji Vallabhdas & Co. 46 ITR 144 (SC), CIT vs. Chamanlal NDTV Worldwide Ltd Mangaldas & Co. 39 ITR 8 (SC), CIT vs. Virtual Soft Systems Ltd 404 ITR 409 (SC), CIT vs. Bokaro Steel Ltd 236 ITR 315 (SC). 20. In case in hand, taking from 30.09.2013, when agreement was executed, if the purchaser was required to make the payment of Total Consideration, in 60 days then only the advance amount was received and remaining may be considered to be accrued subject to contingency of receipt of total purchase consideration, which did not happen and tra…

Asst. Commissioner of Income Tax, Circle 6(1)(1), Mumbai vs. Essar Power Gujarat Ltd., Mumbai

In the result, the appeal of the revenue is dismissed

ITA 137/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 May 2024AY 2014-15

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2014-15 Mr. Arun Bende M/S. Essar Power Asst. Commissioner Of Gujarat Ltd. 11Th Floor, Essar House, Income Tax, Circle-6(1)(1), Mumbai. 11 K.K. Marg, Vs. Room No.504, 5Th Floor, Mahalaxmi, Aayakar Bhavan, Mumbai- 400034. M.K.Road, Pan:Aabce7510K Mumbai- 400020. (Appellant) (Respondent) Present For: Assessee By : Shri Vijay Mehta, A.R. Revenue By : Shri P. D. Chougule (Addl. Cit), D.R. Date Of Hearing : 21 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per: Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed By The Revenue Against The Order Of The Ld. Cit Appeal Passed U/S 250 Of The Income Tax Act (“Act” In Short) Vide Order No. Itba/Nfac/S/250/2023-24/1058193153(1) Dated 23.11.2023 For Assessment Year 2014-15. 2. Following Grounds Of Appeal Have Been Raised:

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri P. D. Chougule (Addl. CIT), D.R
Section 250Section 801ASection 92C

…hat amounts had been advanced in the course of assessee's business; hence the interest income is assessable as Income 6 M/s. Essar Power Gujarat Ltd. from Other Sources. This has further been affirmed by the Apex Court in the case of CIT v. Bokaro Steel Ltd. 236 ITR 315. In the case of Murli Investment Co. CIT 167 ITR 368 [Raj.], the Rajasthan High Court has held that the activity indulged in by the assessee did constitute not money-lending business since the assessee merely invested its funds when they were not required for the time being and, therefore, the interest earned by the assessee was assessable as „In…

DCIT, New Delhi vs. Candor Gurgaon One Reality Project Pvt. Ltd., New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1647/DEL/2021[2014-15]Status: DisposedITAT Delhi01 May 2024AY 2014-15

Bench: Shri Amit Shukla & Shri M. Balaganeshassessment Year: 2014-15

Section 234BSection 271(1)(c)Section 80Section 80I

…1 ITA nos. 1635/Del/2020 & ITA no. 1647/Del/2021 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER Assessment Year: 2014-15 Candor Gurgaon One Realty Vs ACIT, Circle-5(2), New Delhi. Projects Pvt. Ltd., (Formerly known as Unitech Realty Projects Pvt. Ltd. and earlier known as Unitech Realty Projects Ltd.) PAN- AAACU8046K APPELLANT RESPONDENT Assessment Year: 2014-15 ACIT, Circle-5(2), Vs Candor Gurgaon One New Delhi. Realty Projects Pvt. Ltd., (Formerly known as Unitech Realty Projects Pvt. Ltd. and earlier known…

Candor Gurgaon One Reality Projects Private Limited, Mumbai vs. ACIT Circle-5(2), New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1635/DEL/2020[2014-15]Status: DisposedITAT Delhi01 May 2024AY 2014-15

Bench: Shri Amit Shukla & Shri M. Balaganeshassessment Year: 2014-15

Section 234BSection 271(1)(c)Section 80Section 80I

…1 ITA nos. 1635/Del/2020 & ITA no. 1647/Del/2021 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER Assessment Year: 2014-15 Candor Gurgaon One Realty Vs ACIT, Circle-5(2), New Delhi. Projects Pvt. Ltd., (Formerly known as Unitech Realty Projects Pvt. Ltd. and earlier known as Unitech Realty Projects Ltd.) PAN- AAACU8046K APPELLANT RESPONDENT Assessment Year: 2014-15 ACIT, Circle-5(2), Vs Candor Gurgaon One New Delhi. Realty Projects Pvt. Ltd., (Formerly known as Unitech Realty Projects Pvt. Ltd. and earlier known…

Kolaparthy Suvarna Lakshmi, Nellore vs. The Deputy Commissioner of Income Tax, Circle-1, Nellore

In the result, the appeal of the assessee is dismissed

ITA 595/HYD/2023[A.Y.2018-19]Status: DisposedITAT Hyderabad22 Mar 2024

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2018-19 Kolaparthy Suvarna Lakshmi, Vs. The Deputy Commissioner Of Income Tax, Nellore. Central Circle – 1, Nellore. Pan : Agupk4977A. (Appellant) (Respondent) Assessee By: Shri M.V. Prasad, C.A. Revenue By: Ms. Sheetal Sarin, Sr. Ar. Date Of Hearing: 19.03.2024 Date Of Pronouncement: 22.03.2024

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. Sheetal Sarin, Sr. AR
Section 115BSection 143(1)Section 143(3)Section 153CSection 69A

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B” , HYDERABAD BEFORE SHRI R.K. PANDA, VICE PRESIDENT AND SHRI LALIET KUMAR, JUDICIAL MEMBER Assessment Year: 2018-19 Kolaparthy Suvarna Lakshmi, Vs. The Deputy Commissioner of Income Tax, Nellore. Central Circle – 1, Nellore. PAN : AGUPK4977A. (Appellant) (Respondent) Assessee by: Shri M.V. Prasad, C.A. Revenue by: Ms. Sheetal Sarin, Sr. AR. Date of hearing: 19.03.2024 Date of pronouncement: 22.03.2024 O R D E R PER LALIET KUMAR, J.M. This appeal is filed by the assessee, feeling aggrieved by the order passed by the Co…

Viaton Energy Private Limited, Mumbai vs. ITO, Ward-17(4), Hyd, Hyderabad

In the result, appeal of the assessee is dismissed

ITA 1280/HYD/2016[2012-13]Status: DisposedITAT Hyderabad21 Mar 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Dharmesh Shah &For Respondent: Shri Shakeer Ahamed, DR
Section 143(3)

…f the Tribunal in the case of Adani Power Ltd., 61 taxmann.com 355, Prayagraj Power Generation Company Ltd., 158 ITR 909, Indian Oil Panipat Power Consortium Ltd. 315 ITR 225 and also on the decision of the Hon’ble Apex Court in the case of Bokaro Steel Ltd., 236 ITR 315. Page 2 of 14 5. In respect of the disallowance of the interest and financial charges, the argument of the assessee was that the assessee borrowed the money and earned the interest from the fund not immediately required and, therefore, the interest cannot be brought to tax as income from other sources, without giving set-off of the interest amoun…

Alaknanda Hydro Power Company Limited, Secunderabad vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

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

ITA 745/HYD/2019[2014-15]Status: DisposedITAT Hyderabad31 Jan 2024AY 2014-15

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarआ.अपी.सं /Ita No.745/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2014-15) Alakananda Hydro Power Vs. Dy. C. I. T. Company, Circle 1(1) Secunderabad Hyderabad Pan:Aafac2081B (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H. Srinivasulu राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 18/01/2024 घोषणा की तारीख/Pronouncement: 31/01/2024 Order Per R.K. Panda, Vice-

For Appellant: Advocate H. SrinivasuluFor Respondent: : Smt. Sheetal Sarin, DR
Section 143(2)

…hargeable to tax during the previous year when such receipts are inextricably linked with the construction of the Hydro Power Project and go to reduce the cost of the project and such interest income is in the nature of capital receipts: (1) Bokaro steel Ltd- 236 ITR 315 (SC) (2) Karnal Cooperative Sugar Mill Ltd - 243 ITR 2 (SC) (3) Karnataka Power Corporate -247 ITR 268 (SC) (4) Shree Rama Multi Tech Ltd 403 ITR 426 (SC) (5) Indian oil Panipat Power consortium Ltd -315 ITR 255 (Del) (6) Adani Power Ltd -ITAT, (Ahm) -61 Taxmann.com 355 (7) VGR Foundations - 298 ITR 132 (Mad) Page 7 of 10 ITA No 745 of 2019 Ala…

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

In the result, the appeals of the Revenue for assessment year

ITA 2154/MUM/2023[2013-2014]Status: DisposedITAT Mumbai18 Jan 2024AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Ita Nos. 1688, 1687, 1686, 1685, 1683, 1684/Mum/2023 Assessment Years: 2014-15 To 2019-2020

For Appellant: Mr. Ajay R. Singh, &

…) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is e present case is completely different than the judicia! pronouncement relied upon by the completely diff…

Assistant Commissioner of Income Tax-CC-5(4), Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

ITA 2153/MUM/2023[2019-20]Status: DisposedITAT Mumbai18 Jan 2024AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

Section 37(1)Section 56

…money which are under lien with Bank in respect of guarantees and letter of credit for the purpose of setting up its plant*"? 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is completely different than the judicia! pronouncement relied upon by the Ld.CIT(A).*"? 5. "Whether the Ld.CIT (A) is justified in deleting disallowance u/s 37(1) of the Act. of Rs. 129.32.54.291/- thereby reducing the CWIP. ignoring the findings of the DRI giving detail…

Assistant Commissioner of Income Tax-CC-5(4), Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

In the result, the appeals of the Revenue for assessment year

ITA 2152/MUM/2023[2015-16]Status: DisposedITAT Mumbai18 Jan 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Ita Nos. 1688, 1687, 1686, 1685, 1683, 1684/Mum/2023 Assessment Years: 2014-15 To 2019-2020

For Appellant: Mr. Ajay R. Singh, &

…) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is e present case is completely different than the judicia! pronouncement relied upon by the completely diff…

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

ITA 2151/MUM/2023[2018-2019]Status: DisposedITAT Mumbai18 Jan 2024AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Ajay R. Singh, &For Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 37(1)Section 56

…money which are under lien with Bank in respect of guarantees and letter of credit for the purpose of setting up its plant*"? 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is completely different than the judicia! pronouncement relied upon by the Ld.CIT(A).*"? 5. "Whether the Ld.CIT (A) is justified in deleting disallowance u/s 37(1) of the Act. of Rs. 129.32.54.291/- thereby reducing the CWIP. ignoring the findings of the DRI giving detail…

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

ITA 2150/MUM/2023[2014-2015]Status: DisposedITAT Mumbai18 Jan 2024AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

Section 37(1)Section 56

…money which are under lien with Bank in respect of guarantees and letter of credit for the purpose of setting up its plant*"? 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is completely different than the judicia! pronouncement relied upon by the Ld.CIT(A).*"? Matix Fertilizers and Chemicals Ltd. ITA Nos. 1688, 1687, 1686, 1685, 1683, 1684, 2148 to 2154 & CO No. 108/Mum/2023 5. *Whether the Ld.CIT (A) is justified in deleting disallowance u…

Assistant Commissioner of Income Tax, Mumbai vs. Matix Fertilisers and Chemicals Ltd, Mumbai

In the result, the appeals of the Revenue for assessment year

ITA 2149/MUM/2023[2017-2018]Status: DisposedITAT Mumbai18 Jan 2024AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Ita Nos. 1688, 1687, 1686, 1685, 1683, 1684/Mum/2023 Assessment Years: 2014-15 To 2019-2020

For Appellant: Mr. Ajay R. Singh, &

…) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 4. "Whether the Ld.CIT (A) is justified in relying upon the decision of Hon 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and 'ble Apex Court in the case of CIT vs. Bokaro Sieel Lid. 236 ITR 315 and CIT Vs. Karnal Co CIT Vs. Karnal Co-op Sugar Mills Lid., as the facts of the present case is e present case is completely different than the judicia! pronouncement relied upon by the completely diff…