DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances were made: M/s CCL Vs DCIT & 1 Anr. Sl. No. Head of addition/disallowance Amount (i) Income from tax free bonds & applicability ₹ 22,25,826/- of Sec. 14A of the I.T. Act. (ii) Land & Crop Compensation

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

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances were made: M/s CCL Vs DCIT & 1 Anr. Sl. No. Head of addition/disallowance Amount (i) Income from tax free bonds & applicability ₹ 22,25,826/- of Sec. 14A of the I.T. Act. (ii) Land & Crop Compensation

CCL,RANCHI vs. DCIT CIR-1, RANCHI

14A\n10 Disallowance of Prior Period Expenses\n11 Prior Period Expenses as per Note 32 of\nAnnual Report\n12 Prior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n13 Repair expenses\n14 Stripping Activity Adjustment\n15 R & D Expenses and Actuary Payment\n16 Expense u/s 35E\n17 Int. u/s 234A / 234B\nAY 2016-17\n191/RAN/2019\nBy Assessee

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

14A\nDisallowance of Prior Period Expenses\n5,10,00,000\nPrior Period Expenses as per Note 32 of\nAnnual Report\n65,48,51,116\n35,29,25,558\n10,09,00,000\n21,99,00,000\n36,08,20,000\n12 Prior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n13 Repair expenses\n14 Stripping Activity Adjustment

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

14A", "Rule 8D(2)(ii)", "Rule 8D(2)(iii)", "Section 132", "Section 40(a)(ia)", "Section 37(1)", "Rule 46A"], "issues": "The core issues revolved around the allowability of unabsorbed depreciation

DCIT CIR-1, RANCHI vs. CCL, RANCHI

14A\nDisallowance of Prior Period Expenses\nPrior Period Expenses as per Note 32 of\nAnnual Report\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\nRepair expenses\nStripping Activity Adjustment\nR & D Expenses and Actuary Payment\nExpense u/s 35E\nInt. u/s 234A/234B

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

14A\n10\nDisallowance of Prior Period Expenses\n5,10,00,000\n11\nPrior Period Expenses as per Note 32 of\nAnnual Report\n65,48,51,116\n12\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n35,29,25,558\n13\nRepair expenses\n14\nStripping Activity Adjustment\n15\nR & D Expenses and Actuary Payment\n16\nExpense

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

14A\n10\nDisallowance of Prior Period Expenses\n5,10,00,000\n11\nPrior Period Expenses as per Note 32 of\nAnnual Report\n65,48,51,116\n12\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n35,29,25,558\n13\nRepair expenses\n14\nStripping Activity Adjustment

CCL,RANCHI vs. ACIT CIR-1, RANCHI

14A\nDisallowance of Prior Period Expenses\n5,10,00,000\nPrior Period Expenses as per Note 32 of\nAnnual Report\n65,48,51,116\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n35,29,25,558\n10,09,00,000\n21,99,00,000\nRepair expenses\n36,08,20,000\nStripping Activity Adjustment

CCL,RNCHI vs. ACIT CIR-1 , RANCHI

14A\nDisallowance of Prior Period Expenses\n5,10,00,000\n65,48,51,116\nPrior Period Expenses as per Note 32 of\nAnnual Report\n35,29,25,558\n10,09,00,000\n21,99,00,000\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n36,08,20,000\nRepair expenses\nStripping Activity Adjustment\nR & D Expenses

DCIT CIR-1, RANCHI vs. CCL, RANCHI

14A\nDisallowance of Prior Period Expenses\nPrior Period Expenses as per Note 32 of\nAnnual Report\n5,10,00,000\n65,48,51,116\n35,29,25,558\n10,09,00,000\n36,08,20,000\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\nRepair expenses\nStripping Activity Adjustment\nR & D Expenses and Actuary Payment\nExpense

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

depreciation has already been\nadjudicated in the assessee's own case by the coordinate bench of the\nTribunal, respectfully following the observations of the coordinate bench of\nthe Tribunal and for the identical reasons, the order of the Id. CIT(A) stands\nupheld and the issue is held in favour of the assessee and against the\nrevenue.\n5. Next issue

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

depreciation has already been\nadjudicated in the assessee's own case by the coordinate bench of the\nTribunal, respectfully following the observations of the coordinate bench of\nthe Tribunal and for the identical reasons, the order of the Id. CIT(A) stands\nupheld and the issue is held in favour of the assessee and against the\nrevenue.\n5.\nNext issue

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

14A\nDisallowance of Prior Period Expenses\nPrior Period Expenses as per Note 32 of\nAnnual Report\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\nRepair expenses\nStripping Activity Adjustment\nR & D Expenses and Actuary Payment\nExpense u/s 35E\nInt. u/s 234A / 234B

M/S. CENTRAL COAL FIELDS LTD.,,RANCHI vs. ACIT/DCIT CIRCLE-1, RANCHI

Section 37(1) of the Income-tax Act, 1961 - Business expenditure\nAllowability of (Welfare expenses of employees)\nAssessee-\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. DCIT CIR-1 , RANCHI

14A\nDisallowance of Prior Period Expenses\nPrior Period Expenses as per Note 32 of\nAnnual Report\nPrior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\nRepair expenses\nStripping Activity Adjustment\nR & D Expenses and Actuary Payment\nExpense u/s 35E\nInt. u/s 234A / 234B\nBy Assessee\n68,31,00,000\n1,00,000\nNo appeal\nBy Assessee

NIRMAL KUMAR PRADEEP KUMAR ,MAIN ROAD. RANCHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RANCHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: S/ S/Hri George Mathan & Ratnesh Nandan Sahayratnesh Nandan Sahayratnesh Nandan Sahayassessment Year : 2017-18 Nirmal Nirmal Kumar Kumar Pradeep Pradeep Vs. Asst. Asst. Commissioner Commissioner Of Of Kumar, Kumar, Godrej Godrej Dealers, Dealers, Income Tax,Central Circle-1, Income Tax,Central Circle Ranchi Ranchi Pan/Gir No. .Aaahn 6882 K (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Shubham Choudhary, Adv Shubham Choudhary, Adv Revenue By : Shri Khubchand T Pandya, Revenue By Ld Sr Dr Date Of Hearing : 21/08/202 2025 Date Of Pronouncement : 21/08/2 2025

section 14A r.w. Rule 8D in P a g e 2 | 6 Assessment Year : 2017-18 respect of disallowance u/s.14A r.w 8D. In regard to depreciation, ld DR submitted that the business of the assessee has stopped, therefore, the order of the AO and ld CIT(A) are liable to be upheld. 5. We have considered the rival submissions

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

depreciation has already been\nadjudicated in the assessee's own case by the coordinate bench of the\nTribunal, respectfully following the observations of the coordinate bench of\nthe Tribunal and for the identical reasons, the order of the Id. CIT(A) stands\nupheld and the issue is held in favour of the assessee and against the\nrevenue.\n5.\nNext issue