ACIT CIR-1 , DHANBAD vs. M/S BHARAT COKING COAL LTD, DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

INDIAN PROGRESSIVE CONSTRUCTION PVT. LTD.,,DEOGHAR vs. DCIT CIRCLE-3,, DEOGHAR

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

69,20,470/-, subsequently, the ld. Pr.CIT, Dhanbad vide its order dated 31/03/2017 set aside the assessment order dated 26/03/2015 under Section 263 of the Act with a direction to Assessing Officer to pass the assessment order afresh after making proper enquiries and necessary investigations on the issues raised therein. Accordingly, the Assessing Officer passed assessment order under Section

BADRINATH SALES PRIVATE LIMITED,ADITYAPUR, WEST SINGHBHUM vs. DCIT/ACIT CIRCLE 1 JSR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

69,680.\n3.\nAggrieved by the above order the assessee went in appeal where the\nld. CIT(A) dismissed the appeal and sustained the reassessment as well\nas additions.\n4.\nDissatisfied with the above order the assessee is in appeal before\nthis tribunal, the assessee contended that notice under section 148,\nthough dated 31.03.2018, was never served within the period

ACIT CIR-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

69,67,114/-\nTotal value: - Rs. 36,44,00,000/-\nReconciliation for AY 2009-10 is being submitted below: -\nLB Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 4,03,54,585/-\nK N Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 1,42,79,657/-\nBharat Singh disclosed

ACIT CIRCLE-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

69,67,114/-\nTotal value: - Rs. 36,44,00,000/-\nReconciliation for AY 2009-10 is being submitted below: -\nLB Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 4,03,54,585/-\nK N Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 1,42,79,657/-\nBharat Singh disclosed

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

69,67,114/-\nTotal value: - Rs. 36,44,00,000/-\nReconciliation for AY 2009-10 is being submitted below: -\nLB Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 4,03,54,585/-\nK N Singh disclosed in Profit & Loss a/c of his proprietorship concerns from BCCL: - Rs. 1,42,79,657/-\nBharat Singh disclosed

CCL,RANCHI vs. DCIT CIR-1, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

DCIT CIR-1 , RANCHI vs. M/S CENTRAL COALFIELDS LTD, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

DCIT CIR-1,, RANCHI vs. CCL, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

DCIT CIR-1, RANCHI vs. CCL, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

DCIT CIRCLE-1 , RANCHI vs. CCL LTD , RANCHI

Section 37(1) of the Income-tax Act, 1961 - Business expenditure\nAllowability of (Welfare expenses of employees) - Assessee-\ncompany was engaged in business of coal mining It claimed\nexpenses incurred towards welfare of of its employees like canteen,\nhostels, etc. business expenditure Commissioner disallowed same\non ground that said expenditures had not been properly explained\nand that assessee

CCL,RANCHI vs. ACIT CIR-1, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT, CIRCLE-1,, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

CCL LTD ,RANCHI vs. DCIT CIRCLE-1, RANCHI

TDS is liable to be\nducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision. It\nwas the submission that in April 2008 the holding company being

CCL,RNCHI vs. ACIT CIR-1 , RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

DCIT CIR-1, RANCHI vs. CCL, RANCHI

TDS is liable to be\ndeducted on the said payment. Thus, this issue is in held in favour of the\nassessee.\n20. Next issue is in regard to provisions towards NCWA VIII. It was the\nsubmission that this is an interim relief on account of the pay revision.\nIt was the submission that in April 2008 the holding company being

CCL ,RANCHI vs. DCIT CIR-1 , RANCHI

In the result, appeal of the assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.164,165,166,167,168,169,170&266/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita Nos.32/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.190 & 191/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.119, 120, 74/Ran/2024 (Ay: 2018-19, 2019-20 & 2020-21) M/S Central Coalfields Limited, Vs. Addl.Cit, Range-1, Ranchi Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R & आयकर अपील सं./Ita Nos.172,173,174,175,176,177,178 & 235/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita No.37/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.174 & 175/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.47, 203, 204, 128/Ran/2024 (Ay: 2017-2018, 2018-19, 2019-20 & 2020-21) Addl.Cit, Range-1, Ranchi Vs. M/S Central Coalfields Limited, Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 05/01/2026 घोषणा की तारीख/Date Of Pronouncement : 05/01/2026 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

Section 14A of the Act was in existence and the some disallowances were called for. It was submitted that the disallowance should be proportionate to the investment made. 33. In rejoinder, ld. AR submitted that the bonds were on account of securitization of the debts. It was the submission that in the earlier years the ld.CIT(A) has held this

CCL,RNACHI vs. ADDITIONAL CIT ,RG -1 , RANCHI

In the result, appeal of the assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.164,165,166,167,168,169,170&266/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita Nos.32/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.190 & 191/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.119, 120, 74/Ran/2024 (Ay: 2018-19, 2019-20 & 2020-21) M/S Central Coalfields Limited, Vs. Addl.Cit, Range-1, Ranchi Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R & आयकर अपील सं./Ita Nos.172,173,174,175,176,177,178 & 235/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita No.37/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.174 & 175/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.47, 203, 204, 128/Ran/2024 (Ay: 2017-2018, 2018-19, 2019-20 & 2020-21) Addl.Cit, Range-1, Ranchi Vs. M/S Central Coalfields Limited, Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 05/01/2026 घोषणा की तारीख/Date Of Pronouncement : 05/01/2026 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

Section 14A of the Act was in existence and the some disallowances were called for. It was submitted that the disallowance should be proportionate to the investment made. 33. In rejoinder, ld. AR submitted that the bonds were on account of securitization of the debts. It was the submission that in the earlier years the ld.CIT(A) has held this