What is CIT v. Tata Iron & Steel Co. Ltd. authority for?

The actual cost of an asset is distinct from the cost of borrowing money for its purchase. Foreign exchange fluctuations on loan repayment do not alter the asset's actual cost and are not covered by Section 43A.

How many judgments cite CIT v. Tata Iron & Steel Co. Ltd.?

81 judgments on BharatTax cite CIT v. Tata Iron & Steel Co. Ltd. (231 ITR 285), spanning 2007 to 2026.

Which sections of the Income Tax Act does CIT v. Tata Iron & Steel Co. Ltd. come up under?

It is most often cited in judgments turning on Section 1961, Section 37(1), Section 14A, Section 43A, Section 115JB, Section 143(3).

CIT v. Tata Iron & Steel Co. Ltd. (231 ITR 285)

S RAJASEKARAN,CHENNAI vs. DCIT, NCC-7(1), CHENNAI

In the result, the appeal of the assessee is partly allowed for statistical purposes, in the manner indicated above

ITA 2821/CHNY/2025[2023-24]Status: DisposedITAT Chennai02 Feb 2026AY 2023-24

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. M. Karunakaran, AdvocateFor Respondent: Shri. Kumar Chandan, JCIT

Section 143(3)Section 37Section 40

…alized over the past years but are holding that the interest on loans borrowed for acquiring the land cannot be considered as cost of acquisition. 5. The learned NFAC relying on the decision of the Apex Court in the case of CIT Vs. Tata Iron & Steel Co. Ltd. (231 ITR 285) has held that the price originally paid for purchase of the property alone constitute "cost" and not subsequent payment of interest. The appellant submits that the subsequent payment of interest capitalized on the loans availed for acquiring the asset has to be allowed if not as cost of acquisition but as cost of improvement as they were made su…

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

ITA 5143/MUM/2024[2016]Status: DisposedITAT Mumbai30 Jan 2026

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 254Section 80Section 801ASection 80A(6)

…f borrowing of money for purchase of a capitalasset and the transaction of purchase of capital asset are themselves two independent transactions. This has been held so by the Hon'ble Supreme Court in the case of CIT vs. Tata Iron and Steel Company Ltd. (1998) 231 ITR 285 wherein it has been observed that cost of an asset and cost of raising money for purchase of the asset are two different and independent transactions. The relevant observation as appearing in the judgment reads as under; "It is difficult to follow how the manner of repayment of loan can affect the cost of the assets acquired by the assessee. What…

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

ITA 5142/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Jan 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 254Section 80Section 801ASection 80A(6)

…f borrowing of money for purchase of a capitalasset and the transaction of purchase of capital asset are themselves two independent transactions. This has been held so by the Hon'ble Supreme Court in the case of CIT vs. Tata Iron and Steel Company Ltd. (1998) 231 ITR 285 wherein it has been observed that cost of an asset and cost of raising money for purchase of the asset are two different and independent transactions. The relevant observation as appearing in the judgment reads as under; "It is difficult to follow how the manner of repayment of loan can affect the cost of the assets acquired by the assessee. Wha…

EVRY INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1) , BANGALORE

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

ITA 837/BANG/2025[2013-14]Status: DisposedITAT Bangalore31 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2013-14

For Appellant: Shri Nitin Surana, ARFor Respondent: Shri N Balusamy, JCIT (DR)

Section 234CSection 37Section 43ASection 44A

…It is further submitted that the borrowing of money and the acquisition of assets are two different and independent transactions. This principle has been clearly stated by the Hon’ble Supreme Court in the case of CIT vs. Tata Iron & Steel Co. Ltd. reported in 231 ITR 285. The Hon’ble Court held that the cost of assets does not change because of later exchange fluctuations on loan repayment. Following this principle, the present exchange loss cannot be added to the cost of assets, especially when no payment has been made during the year. 8.3 It was claimed that the assessee followed AS-11, which is mandatory. AS-…

GRAPHITE INDIA LTD.,KOLKATA vs. PR.CIT-4, KOLKATA

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

ITA 1014/KOL/2019[2013-14]Status: DisposedITAT Kolkata25 Mar 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 115JSection 142(1)Section 143(3)Section 263Section 37(1)Section 48

…as been claimed as allowable deduction since the above fluctuation in the rate of foreign exchange does not alter the actual cost of the asset and is also not covered by the provisions of Section 43A of the Act. Refer CIT vs. Tata Iron & Steel Co. Ltd. [1998] 231 ITR 285 (SC) & CESC Ltd. vs. CIT [1998] 233 ITR 50 (SC). In the event, the same is not allowed, this loss shall form part of actual cost for the purpose of tax depreciation and same may accordingly be allowed.” We further find that in the present case the assessment proceedings was initiated vide notice u/s 142(1) and in response to the said notice a det…

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

ITA 672/CHNY/2017[2012-13]Status: DisposedITAT Chennai24 Jan 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri A. Sasikumar, CIT

Section 143(3)

…of the Hon'ble Supreme Court in the cost of assets. We find the decision of the Hon'ble Supreme Court in the cost of assets. We find the decision of the Hon'ble Supreme Court in the case of CIT v. Tata Iron & Steel Co. Ltd. CIT v. Tata Iron & Steel Co. Ltd. (231 ITR 285 231 ITR 285) to be relevant in the facts of the present case relevant in the facts of the present case. In the decided case, it was held . In the decided case, it was held that the cost of an asset and the cost of raising money for purchase of the that the cost of an asset and the cost of raising money for purchase of the that the cost of an ass…

PRAGATI POWER CORPORATION LTD,NEW DELHI vs. ACIT, CIRCLE 20(1), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1617/DEL/2023[2018-19]Status: DisposedITAT Delhi14 Aug 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 115JSection 145(2)Section 32Section 36Section 36(1)(iii)Section 37Section 43ASection 46ASection 80I

…precedence in which it is held that section 43A is not applicable in the case of Indigenous / domestic asset even if payment is made to the supplier in foreign currency. viii) Hon'ble Supreme Court in the case of CIT vs. Tata Iron & Steel Company Ltd. (1998) 231 ITR 285 (SC) held that cost of an asset and cost of raising money for purchase of asset are two different and independent transactions. Thus, events subsequent to acquisition of assets cannot change the price paid for it. Pragati Power Corporation vs. ACIT ix) Hon'ble Supreme Court in the case of CIT vs Woodward Governor India (P) Ltd. (2009) 312 ITR 25…