M/s. SIEL Limited vs. DCIT, LTU-1
Case No: ITA No.6300/DEL/2015
Court: Income Tax Appellate Tribunal, Delhi Bench ‘E’
Date: 3/26/2025
Parties Involved
appellantM/s. SIEL Limited
respondentDCIT, LTU-1
Facts Summary
The assessee, M/s. SIEL Limited (now known as Mawana Sugars Ltd.), filed seven appeals against the orders of the Commissioner of Income Tax (Appeals)-22, New Delhi, for Assessment Years 2003-04, 2006-07, 2011-12 to 2015-16. The Revenue also filed cross-appeals against the orders for Assessment Years 2006-07, 2012-13, 2014-15, and 2015-16. The appeals involve common issues and are heard together. The main issues pertain to the disallowance of long-term capital loss claimed by the assessee on the …
Decision in favour of
Assessee
Legal Issues
- 1. Whether the transfer of land and investments to M/s Shivaji Marg Properties Limited and M/s Siel Holdings Limited under the SOA constitutes a 'demerger' under section 2(19AA) of the Income Tax Act.
- 2. Whether the disallowance of interest cost on investments and advances to group companies is valid.
Precedents Relied Upon
11 precedents cited in this judgement.