M/s. Coal India Ltd. Vs. DCIT, Circle-5(1), Kolkata

Parties Involved

Facts Summary

The assessee, M/s. Coal India Ltd., is a public sector enterprise engaged in mining and extraction of coal. For the assessment years 2011-12 to 2014-15, the assessee filed returns of income showing total income under normal provisions and under section 115JB of the Income Tax Act, 1961. The Assessing Officer made assessments by disallowing certain deductions and adding certain incomes. Aggrieved by the assessment orders, the assessee and the Revenue filed cross-appeals before the Income Tax Appellate Tribunal (ITAT). The appeals were heard together and decided by a common order. The issues raised by the assessee included disallowance of mark to market loss, disallowance of prior period expenses, addition of undisclosed income, and disallowance of notional lease rent and penalty charges. The Revenue raised issues related to disallowance under section 14A, disallowance of provision for Mine Closure Expenses, and disallowance of interest earned on Shifting and Rehabilitation Fund.…

Legal Issues

• 1. Disallowance of ₹48.72 crores on account of provision for mark to market loss.
• 2. Disallowance of prior period expenses amounting to ₹19,25,000/-.
• 3. Addition of ₹1,92,32,107/- as undisclosed income.
• 4. General grounds of appeal.
• 5. Deletion of disallowance of ₹31.58 crores u/s 14A of the Act.
• 6. Disallowance of provision for Mine Closure Expenses.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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