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 Sahayd.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 M/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

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: DCIT Vs M/s CCL & 1 Anr. Sl. Head of addition/disallowance Amount No. (i) Disallowance u/s 14A ₹ 1,64,80,500/- (ii) Prior period expenses ₹ 91,73

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

DCIT,CIRCLE-1RANCHI, 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 Sahayd.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 M/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

disallowance of expenses is as under :- Sl. Head Amount Issue involved 1 Lease Rent paid for 133,78,37,000/- Whether revenue the acquisition of expenditure or capital Forest land expenditure. 2 Prior period 8,99,66,000/- Whether ascertained & expenses crystalized during the year. 3 Land & Crop 89,82,07,000/- Whether of enduring Compensation nature i.e. Capital

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 Sahayd.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 M/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

disallowance of expenses is as under :- Sl. Head Amount Issue involved 1 Lease Rent paid for 133,78,37,000/- Whether revenue the acquisition of expenditure or capital Forest land expenditure. 2 Prior period 8,99,66,000/- Whether ascertained & expenses crystalized during the year. 3 Land & Crop 89,82,07,000/- Whether of enduring Compensation nature i.e. Capital

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

In the result, appeal of the assessee is allowed

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

Disallowance u/s 14A ₹ 2,12,51,000/- (ii) Prior period expenses ₹ 2,21,98,000/- (iii) Land & Crop Compensation ₹ 2,80,62,000/- (iv) Sports grant and grants of school ₹ 4,73,83,000/- (v) Community development and environmental ₹ 8,73,15,000/- expenses (vi) Mines development expenses ₹ 1,63,23,000/- (vii) CMPDIL Expenses ₹ 18,36,39,000/- (viii

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 5. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 6. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance of under loading charges of Rs. 547.68 lakhs" In the aforesaid judgment the Hon'ble ITAT has cited the judgment of Hon'ble ITAT in ITA No. 289 and 290/Nag/2006 order dated 30.06.2009 for AY 2002-03 and 2003-04. While allowing the appeal of the appellant on the issue of under loading charges, in para

DCIT CIRCLE-1, DHANBAD vs. BHARAT COKING COAL LTD.,, DHANBAD

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance of under loading charges of Rs. 547.68 lakhs" In the aforesaid judgment the Hon'ble ITAT has cited the judgment of Hon'ble ITAT in ITA No. 289 and 290/Nag/2006 order dated 30.06.2009 for AY 2002-03 and 2003-04. While allowing the appeal of the appellant on the issue of under loading charges, in para

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

73,87,499.00 4,91,29,462.00 2016-17 29,71,64,279.00 23,13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

73,87,499.00 4,91,29,462.00 2016-17 29,71,64,279.00 23,13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were

NEERAJ KUMAR SINHA,JAMSHEDPUR vs. ITO WARD-1(1), JAMSHEDPUR

In the result, this appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayneeraj Kumar Sinha, I.T.O., Prop.-M/S Neeraj Engineering, Chota Ward-1(1), Vs. Ghamaria, Saraikela-Kharsawan, Jamshedpur. Jamshedpur-832108 (Jharkhand) Pan No. Bopps 2885 K Appellant/ Assessee Respondent/ Revenue

73,500/- making adjustment of Rs. 21,82,243/-being late deposit of employee's contribution towards ESI and PF within the due date specified in the respective statute. 1.3 That after filing of rectification at CPC, vide Rectification Order u/s 154 dated 17.10.2022, the Return was processed on the same income as per earlier processing u/s 143(1) dated

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

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 (Α.Υ: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 (Α.Υ: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 (अपीलार्थी /Appellant) स्थायी लेखा सं./Pan No. : Aaacc 7476 R (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.Κ.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 Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017, 30.01.2019, 21.12.2023, 19.02.2024, 20.02.2024 & 30.01.2024 For The

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