DCIT, CIRCLE-1, BATHINDA vs. TALWANDI SABO POWER LTD, MANSA
The appeal stand dismissed
ITA 232/ASR/2024[2014-15]Status: DisposedITAT Amritsar16 Apr 2025AY 2014-15
Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm (Hybrid Hearing) आयकरअपील सं. / Ita No.232/Agr/2024 (िनधा"रणवष" / Assessment Year: 2014-15) Dcit, Central Circle-1 M/S Talwandi Sabo Power Ltd. बनाम/ Vs. Bhatinda -151 001 Village Banawala, Mansa Talwandi Sabo Road, Punjab. 151302. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacct-6775-G (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Neeraj Jain, Sh. Deepesh Jain, (Advs) & Ms Aditi Garg, Ca – Ld. Ars Revenue By : Sh. Manpreet Singh Duggal – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 27-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2014-15 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Dated 22-03-2024 In The Matter Of Impugned [Enalty Levied By Ld. Ao U/S 271(1)(C) Vide Its Order Dated 31-01-2019. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.
For Appellant: Sh. Neeraj Jain, Sh. Deepesh Jain, (Advs) &For Respondent: Sh. Manpreet Singh Duggal – Ld. Sr. DR
Section 143(3)Section 271(1)(c)Section 37
disallowed capital expenditure of Rs.41.80 Crores in computation of income and accordingly, claimed loss of Rs.5.08 Crores. Since there was no commercial operation, Ld. AO held that remaining expenditure was also required to be capitalized. Finally, the assessment was framed which stood confirmed in first appeal vide order dated 04-10-2017. 3. Consequently, penalty