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

Depreciation on Lease Hold Land ₹ 39,98,32,440/- (iii) Land & Crop Compensation ₹ 24,09,000/- (iv) Grants to Sports Recreation & Grants of ₹ 11,67,32,000/- School & Institutions (v) Community Development & Environmental ₹ 12,24,87,000/- Expenditure (vi) Mines Closure Expenses ₹ 47,39,30,000/- (vii) CMPDIL expenses ₹ 56,93,18,000/- (viii) IICM Charges

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, 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

Depreciation on Lease Hold Land ₹ 39,98,32,440/- (iii) Land & Crop Compensation ₹ 24,09,000/- (iv) Grants to Sports Recreation & Grants of ₹ 11,67,32,000/- School & Institutions (v) Community Development & Environmental ₹ 12,24,87,000/- Expenditure (vi) Mines Closure Expenses ₹ 47,39,30,000/- (vii) CMPDIL expenses ₹ 56,93,18,000/- (viii) IICM Charges

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

In the result, both appeals of revenue and the cross objections of the assessee are dismissed and appeals of assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (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 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 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 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011-

depreciation has already been adjudicated in the assessee’s own case by the coordinate bench of the Tribunal, respectfully following the observations of the coordinate bench of the Tribunal and for the identical reasons, the order of the ld. CIT(A) stands upheld and the issue is held in favour of the assessee and against the revenue. 5. Next issue

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

24,766/- office 5 Repairs and maintenance 2,06,44,292/- 6 Store purchase 6,78,69,000/- 7 Explosive purchases 49,43,85,000/- 4. The ld. AO further disallowed the brought forward unabsorbed depreciation loss of Rs. 944,77,29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss

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]

24,766/- office 5 Repairs and maintenance 2,06,44,292/- 6 Store purchase 6,78,69,000/- 7 Explosive purchases 49,43,85,000/- 4. The ld. AO further disallowed the brought forward unabsorbed depreciation loss of Rs. 944,77,29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss

M/S. HIMACHAL CONSTRUCTION CO. PVT. LTD,JAMSHEDPUR vs. ITO, WARD NO.1(5), JAMSHEDPUR

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

Bench: Dr. Manish Borad & Sonjoy Sarma

depreciation. In other words the net addition sustained is Rs.26,34,060/-(Rs.41,43,171 - 15,09,111) as against addition made of Rs.55,24,228/- and the appellant gets a part relief of Rs. 28,90,168/-. Accordingly, this ground is partly allowed.” 6. Now, before us, ld. Counsel for the assessee has referred to the decision of this

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

Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide

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

Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide

CCL,RANCHI vs. DCIT CIR-1, RANCHI

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

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

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

DCIT CIR-1, RANCHI vs. CCL, RANCHI

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

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

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

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

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5.\nWe have considered the submissions of the both the sides.\nAdmittedly

CCL,RANCHI vs. ACIT CIR-1, RANCHI

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

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

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

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

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5.\nWe have considered the submissions of the both the sides.\nAdmittedly

CCL,RNCHI vs. ACIT CIR-1 , RANCHI

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly

DCIT CIR-1, RANCHI vs. CCL, RANCHI

depreciable asset. It was further submission that the Ld. AR on the behalf\nof the assessee that during some of the year the revenue has not made\nany disallowance on this issue of lease rental. Therefore, even if\namortisation is granted, it could lead to computation problems.\n5. We have considered the submissions of the both the sides.\nAdmittedly