CIT v. Meghalaya Steels Ltd.

383 ITR 217Supreme Court of India2016#507 most cited

What is CIT v. Meghalaya Steels Ltd. authority for?

The Supreme Court determines the eligibility of subsidies for deduction under industrial incentive sections, specifically 80IB and 80IC of the Income-tax Act, 1961.

186

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

Meghalaya Steels Ltd. · CIT v. Meghalaya Steels Ltd. · section 80IB deduction · section 80IC deduction · subsidy eligibility for deduction · industrial incentive deduction · Income Tax Act 1961 · deduction of subsidy · Supreme Court subsidy · 383 ITR 217

Issues it is cited on

Judgments citing CIT v. Meghalaya Steels Ltd.

DALMIA CEMENT (BHARAT) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 26, NEW DELHI

ITA 5417/DEL/2017[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…d. held that nature of any subsidy is to be determined with respect to the purpose for which is granted. Time of disbursal and source/mode of subsidy is immaterial. We have noted that ld. CIT(A) has rightly distinguished the decision of Meghalaya Steels Ltd. (383 ITR 217) of Hon’ble Apex Court concluding that in the impugned case, the issue was as to whether subsidy is admissible for deduction under section 80IB/80IC or not. The issue of capital receipt vs revenue receipts was not agitated there. The ld. CIT(A) after examining various documents placed by the assessee held that the ITA Nos. 5416 & 5417/Del/2017 al…

DALMIA CEMENT (BHARAT) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 26, NEW DELHI

ITA 5416/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…d. held that nature of any subsidy is to be determined with respect to the purpose for which is granted. Time of disbursal and source/mode of subsidy is immaterial. We have noted that ld. CIT(A) has rightly distinguished the decision of Meghalaya Steels Ltd. (383 ITR 217) of Hon’ble Apex Court concluding that in the impugned case, the issue was as to whether subsidy is admissible for deduction under section 80IB/80IC or not. The issue of capital receipt vs revenue receipts was not agitated there. The ld. CIT(A) after examining various documents placed by the assessee held that the ITA Nos. 5416 & 5417/Del/2017 al…

ACIT CIRCLE 1, TRICHY vs. DALMIA CEMENT BHARAT LTD., DALMIAPURAM

ITA 3158/CHNY/2017[2014-15]Status: DisposedITAT Chennai31 Dec 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…d. held that nature of any subsidy is to be determined with respect to the purpose for which is granted. Time of disbursal and source/mode of subsidy is immaterial. We have noted that ld. CIT(A) has rightly distinguished the decision of Meghalaya Steels Ltd. (383 ITR 217) of Hon’ble Apex Court concluding that in the impugned case, the issue was as to whether subsidy is admissible for deduction under section 80IB/80IC or not. The issue of capital receipt vs revenue receipts was not agitated there. The ld. CIT(A) after examining various documents placed by the assessee held that the ITA Nos. 5416 & 5417/Del/2017 al…

ACIT CIRCLE 1, TRICHY vs. DALMIA CEMENT BHARAT LTD., DALMIAPURAM

ITA 3157/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…d. held that nature of any subsidy is to be determined with respect to the purpose for which is granted. Time of disbursal and source/mode of subsidy is immaterial. We have noted that ld. CIT(A) has rightly distinguished the decision of Meghalaya Steels Ltd. (383 ITR 217) of Hon’ble Apex Court concluding that in the impugned case, the issue was as to whether subsidy is admissible for deduction under section 80IB/80IC or not. The issue of capital receipt vs revenue receipts was not agitated there. The ld. CIT(A) after examining various documents placed by the assessee held that the ITA Nos. 5416 & 5417/Del/2017 al…

ACIT (CIR.) - 6(1)(2), MUMBAI vs. BHANDAR POWER LTD., MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 1908/MUM/2018[2013-14]Status: DisposedITAT Mumbai13 Oct 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Assistant Commissioner Of Bhandar Power Ltd. Income Tax, 14Th Floor, Essar House, Circle 6(1)(2), 11, K. K. Marg, Mahalaxmi, Vs. Mumbai Mumbai - 400034 (Pan: Aaacb6693B) (Appellant) (Respondent) Present For: Assessee : Shri Vijay Mehta, Fca & Shri Tarang Mehta, Advocate Revenue : Shri Satyaprakash R. Singh, Cit Dr Date Of Hearing : 29.07.2025 Date Of Pronouncement : 13.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Ld. Cit(A), Delhi, Vide Order Dated 25.01.2018 Passed Against The Assessment Order By Ito 6(1)(4), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 20.12.2016, For Assessment Year 2013-14. 2. Grounds Taken By The Revenue Are Reproduced As Under: 1. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Is Not Justified In Deleting The Disallowance Of Deduction U/S 80Ia Of The Income Tax Act Of Rs. 203,13,43,740/-Without Considering The Fact That The Provisions Of Section 801A(10) Is Clearly Attracted In This Case Hence The Assessee Is Not Eligible For Claiming Deduction U/S 801A Of The Income Tax Act.

For Appellant: Shri Vijay Mehta, FCA and Shri Tarang Mehta, AdvocateFor Respondent: Shri Satyaprakash R. Singh, CIT DR
Section 143(3)Section 801ASection 801A(10)Section 80I

…on'ble Supreme Court and High Courts to conclude that income received by the assessee has direct nexus with the business of the eligible undertaking. He followed the ratio laid down by the Hon'ble Supreme Court in the case of CIT(A) vs. Meghalaya Steels Ltd., 383 ITR 217 (SC) and at the same time distinguished the judicial precedents relied upon by the ld. Assessing Officer. 7. Aggrieved by the outcome of the first appellate order, Revenue is in appeal before the Tribunal contending that decision rendered by ld. CIT(A) in favour of the assessee is without going into the substance of the PPA and without analysing…

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