CIT v. Tanfac Industries Ltd.

319 ITR 8Reported decision#7848 most cited

What is CIT v. Tanfac Industries Ltd. authority for?

The value of steam used for captive consumption by an assessee is eligible for deduction under section 80-IA of the Income-tax Act, as steam is considered a source of power with a determinable cost of production.

14

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2018 to 2025.

Also referred to as

CIT v. Tanfac Industries Ltd. · 319 ITR 8 · section 80-IA · deduction for steam · captive consumption · source of power · cost of production

Sections most often in play

Section 10BSection 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 234ASection 234BSection 234C

Issues it is cited on

section 139(3)section 108section 10basection 80ia(8)section 10b(8)cost plus methodinterest on outstanding receivablesinterest u/s 234csection 80a(5)section 80ia(4)specified domestic transactiondeduction under section 80ia

Judgments citing CIT v. Tanfac Industries Ltd.

Dcm Shriram Limited, Delhi vs. Assessment Unit, Delhi

ITA 4328/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

…. In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are metho…

DCIT, New Delhi vs. Dcm Shriram Ltd, New Delhi

ITA 927/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

…In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are meth…

Dcm Shriram Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

ITA 2587/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

…. In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are metho…

Dcm Shriiram Limited, New Delhi vs. Neac, New Delhi

ITA 704/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

…In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are meth…

Dev Priya Products Private Ltd., Delhi vs. DCIT, Central Circle, Meerut

In the result, appeal of the assessee is partly allowed

ITA 4433/DEL/2024[2020-21]Status: DisposedITAT Delhi27 Jun 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2020-21] Dev Priya Products Pvt.Ltd., Vs Dcit/Acit, 4, Shankar Vihar, 1St Floor, Central Circle, Vikas Marg, Delhi-110092. Meerut Pan-Aaacd4276C Appellant Respondent Appellant By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 02.04.2025 Date Of Pronouncement 27.06.2025 Order

Section 143(3)Section 144C(1)Section 80I

…. In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are metho…

Satia Industries Limited, Muktsar, Punjab vs. DCIT, ACIT Circle 1, Bathinda

In the result, the appeal is partly allowed

ITA 527/ASR/2024[2020-21]Status: DisposedITAT Amritsar28 Feb 2025AY 2020-21

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

For Appellant: S/Shri Sudhir SehgalFor Respondent: Shri K. Mehboob Ali Khan, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 80

…decision of the Tribunal, which held that the assessee was entitled to claim a deduction under Section 80-IA on the value of steam used for captive consumption. 27.1 The AR referred to the case of CIT v. Tanfac Industries Ltd [S.L.P.(C) No. 18537 of 2009] (319 ITR 8 & 9), which upheld the position of the assessee. In light of the above discussion, the AR 527-Asr-2024 Satia Industries, Muktsar 39 contended that the steam produced by the assessee in the eligible unit constitutes a product, and the income derived from the sale of steam is income derived from an industrial undertaking, thus qualifying for the…

Tata Chemicals Ltd, Mumbai vs. Addl Ciat 2(3), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 120/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Nov 2023AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 144C(5)Section 14ASection 43BSection 80

…s appeal against the decision of Tribunal holding that the assessee was entitled to claim deduction under section 80-IA of the Act on the value of steam used for captive consumption by the assessee. CIT v. Tanfac Industries Ltd. [S.L.P.(C) No. 18537 of 2009] (319 ITR 8 & 9). In the light of above discussion, we find that the steam produced by the assessee is eligible unit is a bye-product and income from sale of steam is the income derived from industrial undertaking, therefore, deduction under section 80-IA is allow-able. We, accordingly, set aside the order of CIT(A) on this issue and the claim, of the assessee…

Tata Chemicals Ltd, Mumbai vs. ACIT 2(3), Mumbai

Appeal is hereby dismissed as infructuous

ITA 6900/MUM/2012[2007-08]Status: DisposedITAT Mumbai31 Mar 2023AY 2007-08
Section 143(3)Section 144C(5)

…s appeal against the decision of Tribunal holding that the assessee was entitled to claim deduction under section 80-IA of the Act on the value of steam used for captive consumption by the assessee. CIT v. Tanfac Industries Ltd. [S.L.P.(C) No. 18537 of 2009] (319 ITR 8 & 9). In the light of above discussion, we find that the steam produced by the assessee is eligible unit is a bye-product and income from sale of steam is the income derived from industrial M/s. Tata Chemicals Limited undertaking, therefore, deduction under section 80-IA is allow-able. We, accordingly, set aside the order of CIT(A) on this issue a…

Tata Chemicals Ltd, Mumbai vs. ACIT 2(3), Mumbai

Appeal is hereby dismissed as infructuous

ITA 8710/MUM/2011[2007-08]Status: DisposedITAT Mumbai31 Mar 2023AY 2007-08
Section 143(3)Section 144C(5)

…s appeal against the decision of Tribunal holding that the assessee was entitled to claim deduction under section 80-IA of the Act on the value of steam used for captive consumption by the assessee. CIT v. Tanfac Industries Ltd. [S.L.P.(C) No. 18537 of 2009] (319 ITR 8 & 9). In the light of above discussion, we find that the steam produced by the assessee is eligible unit is a bye-product and income from sale of steam is the income derived from industrial M/s. Tata Chemicals Limited undertaking, therefore, deduction under section 80-IA is allow-able. We, accordingly, set aside the order of CIT(A) on this issue a…

Tata Chemicals Ltd, Mumbai vs. DCIT 2(3), Mumbai

Appeal is hereby dismissed as infructuous

ITA 9057/MUM/2010[2006-07]Status: DisposedITAT Mumbai31 Mar 2023AY 2006-07
Section 143(3)Section 144C(5)

…s appeal against the decision of Tribunal holding that the assessee was entitled to claim deduction under section 80-IA of the Act on the value of steam used for captive consumption by the assessee. CIT v. Tanfac Industries Ltd. [S.L.P.(C) No. 18537 of 2009] (319 ITR 8 & 9). In the light of above discussion, we find that the steam produced by the assessee is eligible unit is a bye-product and income from sale of steam is the income derived from industrial M/s. Tata Chemicals Limited undertaking, therefore, deduction under section 80-IA is allow-able. We, accordingly, set aside the order of CIT(A) on this issue a…

Pepakayala Veerabhadrarao, Kakinada vs. Income Tax Officer, Ward-2, Kakinada

In the result, appeal of the assessee is allowed

ITA 259/VIZ/2021[2018-19]Status: DisposedITAT Visakhapatnam08 Apr 2022AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अऩीऱ सं./I.T.A.No.259/Viz/2021 (ननधधारण वषा / Assessment Year : 2018-19) Pepakayala Veerabhadrarao Vs. Income Tax Officer D.No.68-10-20/B, Vidyut Nagar Ward-2 Kakinada Kakinada East Godavari Dist. [Pan : Akxpp4235H] (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri P.Prabhakara Murthy, ARFor Respondent: Shri SPG Mudaliar, DR
Section 139(1)Section 143(1)Section 36Section 36(1)(va)Section 43B

…आयकरअपीऱीयअधिकरण, विशाखापटणम पीठ, विशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM श्री दुव्िूरु आर एऱ रेड्डी, न्याययक सदस्य एिं श्री एस बाऱाकृष्णन, ऱेखा सदस्य के समक्ष BEFORE SHRI DUVVURU RL REDDY, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकर अऩीऱ सं./I.T.A.No.259/Viz/2021 (ननधधारण वषा / Assessment Year : 2018-19) Pepakayala Veerabhadrarao Vs. Income Tax Officer D.No.68-10-20/B, Vidyut Nagar Ward-2 Kakinada Kakinada East Godavari Dist. [PAN : AKXPP4235H] (अपीऱार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अऩीऱधथी की ओर से/ Appellant by : Shri P.Pra…

Dcm Shriiram Ltd., New Delhi vs. Addl.CIT, Special Range- 3, New Delhi

In the result appeal of assessee is partly allowed

ITA 7362/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Oct 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Pradeep Dinodia, C. A.; &For Respondent: Shri Surendra Pal [CIT] – DR
Section 133(6)Section 143Section 143(3)Section 144Section 92C

…. In such circumstances, the "steam" produced by the assessee can be termed as power and would qualify for the benefits available under section 80IA(4) of the Act.” 45. Further Hon’ble Supreme Court in CIT v. Tanfac Industries Ltd., SLP (C) No. 18537 of 2009 [319 ITR 8 (st)] wherein while applying section 80-IA of the IT Act, the Hon’ble Supreme Court took a view that the value of steam used for captive consumption by the assessee was entitled to be deducted under section 80-IA of the Act. 46. Therefore it is apparent that i. steam is a valuable sources of power ii. it has cost of production, iii. There are metho…

Itc Limited, Kolkata vs. ACIT, RG-8, Kolkata

Appeal is dismissed

ITA 685/KOL/2014[2009-2010]Status: DisposedITAT Kolkata28 Nov 2018AY 2009-2010

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ]

For Appellant: Shri Md. Usman, CIT DRFor Respondent: Shri J.P. Khaitan, Senior Counsel
Section 143(3)

…[S3 TT] 866 (2004)] and DCIT v. Maharaja Shree Umaid Mills [120 TTJ 711 (2009)]. Further, the Hon'ble Supreme Court had dismissed the Department's SLP against the judgement of the Madras High Court in the case of Tanfac Industries Ltd. (TC No. 1773 of 2008) [319 ITR 8, 9] wherein the High Court had dismissed the Department's appeal against the decision of the Tribunal which had held the deduction under section 80IA was applicable on the value of steam used for captive consumption. The appellant company has also submitted that it is a separate / independent undertaking which produces power in the form of steam an…

DCIT, Cir-8, Kolkata vs. M/S Itc Limited, Kolkata

Appeal is dismissed

ITA 1267/KOL/2014[2009-2010]Status: DisposedITAT Kolkata28 Nov 2018AY 2009-2010

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ]

For Appellant: Shri Md. Usman, CIT DRFor Respondent: Shri J.P. Khaitan, Senior Counsel
Section 143(3)

…[S3 TT] 866 (2004)] and DCIT v. Maharaja Shree Umaid Mills [120 TTJ 711 (2009)]. Further, the Hon'ble Supreme Court had dismissed the Department's SLP against the judgement of the Madras High Court in the case of Tanfac Industries Ltd. (TC No. 1773 of 2008) [319 ITR 8, 9] wherein the High Court had dismissed the Department's appeal against the decision of the Tribunal which had held the deduction under section 80IA was applicable on the value of steam used for captive consumption. The appellant company has also submitted that it is a separate / independent undertaking which produces power in the form of steam an…

CIT v. Tanfac Industries Ltd. (319 ITR 8) — Cited in 14 Judgments | BharatTax