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DCIT Circle 1(2)(1), Mumbai Vs. MSPL Ltd.

Case No: ITA No.5433/Mum/2025
Court: INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH, MUMBAI
Date: 1/28/2026

Parties Involved

appellantDCIT Circle 1(2)(1), Mumbai
respondentMSPL Ltd.

Facts Summary

The present appeal has been preferred by the Revenue against the order dated 06/06/2025 passed by the learned Addl./JCIT(A)-7, Kolkata, arising out of the reassessment framed under section 143(3) read with section 147 of the Income-tax Act, 1961, for the assessment year 2011-12. The assessee, MSPL Ltd., had received Rs. 15,16,16,644/- on sale of Carbon Emission Reduction Certificates / Carbon Credits during the year under consideration. The assessee treated this receipt as capital in nature and

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the amount received by the assessee on sale of carbon credits is a capital receipt or business income.

Precedents Relied Upon

4 precedents cited in this judgement.

Judgment Outcome

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Version 2.0.1Last updated: October 2025
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