CIT v. Karnal Co-operative Sugar Mills Ltd.

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

In the result, the appeal of the assessee is allowed

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

…ts 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 CIT(A) recorded that though the project may have continued in…

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

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.

…nds 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, did not accept the explanation furnished by the assessee.…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. MATIX FERTILISERS AND CHEMICALS LTD, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. MATIX FERTILISERS AND CHEMICALS LTD, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. MATIX FERTILISERS AND CHEMICALS LTD, MUMBAI

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

…ex Court held that "if the assessee receives any amounts which are inextricably linked with the process of setting up its plant and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of credit for the purchase of the machinery required for setting up the plant was incidental to the acquisition of the assets and ruled in favour of the assessee". In view of the decision of the Hon'ble Apex Court, by respectfully following the same, this ground…

MATIX FERTILISERS AND CHEMICALS LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX, CIT(A)53, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

MATIX FERTILISERS AND CHEMICALS LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX, CIT(A)53, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

MATIX FERTILISERS AND CHEMICALS LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX, CIT(A)53, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…

MATIX FERTILISERS AND CHEMICALS LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX, CIT(A)53, MUMBAI

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

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

…machinery, such receipts will go to reduce the cost of its and machinery, such receipts will go to reduce the cost of its assets". In the case of CIT vs. Karnal Co assets". In the case of CIT vs. Karnal Co-operative Sugar Mills Ltd. operative Sugar Mills Ltd. 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out 243 ITR 2, the Hon'ble Apex Court held that "the interest earned out of deposits to open a letter of cr of deposits to open a letter of credit for the purchase of the edit for the purchase of the machinery required for set…