Jindal Steel Power Ltd. New Delhi

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IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH: ‘D’: NEW DELH

BEFORE SH. C.M. GARG, JUDICIAL MEMBER
AND
SH. O.P. KANT, ACCOUNTANT MEMBER

ITA Nos. 3283/Del/2013 & 3128/Del/2014
Assessment Year: 2008-09

M/s. Jindal Steel Power Ltd., Jindal Vs. CIT/ACIT, Hisar
Centre, 12, Bhikaji Cama Place, New
Delhi
(PAN: AAACJ7097D)
(Appellant) (Respondent)

Appellant by Sh. Ajay Vohra, Sr. Advocate, Sh. Rohit
Jain & Sh. Deepesh, Advocates
Respondent by Sh. Ashok Manchanda, Standing Counsel
and Sh. A.K. Arora, CIT(DR)

Date hearing concluded on 07.03.2016
Date of pronouncement 31.03.2016

ORDER
PER O.P. KANT, A.M.:
These two appeals filed by the assessee company relate to assessment year
2008-09. In ITA No. 3283/Del/2013, the assessee has challenged the assumption
of jurisdiction u/s 263 of the Income-tax Act, 1961 (in short ‘the Act’) by the
Commissioner of Income-tax, Hisar (in short ‘CIT’). The ITA No. 3128/Del/2014
arise from an order of assessment u/s 143(3) of the Act passed by the Assessing
Officer in pursuance to the order u/s 263 of the Act. Since the common
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

issues are involved in these appeals, the same were heard together and are being
disposed of by this consolidated order for the sake of convenience and brevity.
ITA No. 3283/Del/2013
2. First we will deal with the appeal in ITA No. 3283/Del/2013. The Grounds
of appeal raised by the assessee in the appeal are as under:
“1. That on the facts and circumstances of the case and in law the order
dated 25.03.2013 passed by the learned Commissioner of Income-tax,
(‘CIT’) under section 263 of the Income-tax Act, 1961 (‘the Act’) holding the
assessment order dated 27.12.2010 to be erroneous and prejudicial to
interests of revenue on certain issues, is beyond jurisdiction, bad in law and
void ab initio.

1.1 That the CIT erred on facts and in law in exercising reversionary
powers under section 263 of the Act in respect of certain issues, without
appreciating that the twin conditions of that section viz., assessment order
being erroneous as well as prejudicial to the interests of the Revenue, were
not satisfied in the appellant’s case.

1.2 That the CIT erred on facts and in law in setting aside the assessment
order on certain issues allegedly on the ground that the assessing officer did
not conduct necessary and proper enquiries/ verification and did not apply
correct position of law, which is outside the scope of revisionary jurisdiction
under section 263 of the Act.

l.3 That the CIT erred on facts and in law in setting aside the assessment
order, without arriving at any conclusive finding on merits as to how the
assessment order was erroneous as well as prejudicial to the interests of
Revenue.

2. That the CIT erred on facts and in law in holding that the order
passed by the assessing officer was erroneous and prejudicial to the interest
of the Revenue on account of the following:

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

(i) Allowing reduction of sales tax incentive/ subsidy amounting to
Rs.81.5 crores from the taxable income by treating the same to be non-
taxable, being in the nature of capital receipt;

(ii) Allowance of additional depreciation of Rs.5,91,106 on computer
software ‘Primavera’.

3. That the CIT erred on facts and in law in holding that the assessing
officer erred in allowing sales tax incentive/ subsidy amounting to Rs.81.5
crores from the taxable income of the appellant.

3.1 That the CIT erred on facts and in law in holding that nothing was
actually received in the form of any incentive/ subsidy by the appellant, the
hypothetical/ notional figure cannot be treated as incentive/ subsidy and
allowed as reduction from the taxable income.

3.2 That the CIT erred on facts and in law in holding that the appellant
was not able to justify/ support the claim of non-taxability of sales tax
incentive/ subsidy, being in the nature of capital receipt, not liable to tax.

3.3 That the CIT erred on facts and in law in holding that the appellant
has failed to link the aforesaid tax concessions/ incentives with any scheme
notification issued by the Government, without appreciating that the
appellant placed on record not only relevant notifications/ scheme policy but
also various representatives made to the State Government pursuant to
which incentive/subsidy was allowed.

3.4 That the CIT erred on facts and in law in holding that incentives
received by the appellant to be in the nature of trading receipt and -could
not be construed as capital subsidy/ receipt.

3.5 That the CIT erred “” facts and in law in recording various incorrect
findings/ conclusions, like, appellant having claimed double benefit, etc.,
without judiciously appreciating the facts and the detailed submissions filed
by the appellant.

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

4. That the CIT erred on facts and in law in holding that additional
depreciation of Rs.5,91,106 claimed by the appellant in respect of computer
software ‘Primavera’ was not allowable under section 32(1)(iia) of the Act.

4.1 That the CIT erred on facts and in law in holding that the aforesaid
computer software was only office equipment and does not qualify as ‘plant
and machinery, for being eligible for additional depreciation.

The appellant craves leave to add, alter, amend or vary from the aforesaid
grounds of appeal at or before the time of hearing.”

3. The facts in brief are that the assessee company was engaged in generation
of power and manufacturing of sponge iron products during the previous year
relevant to the assessment year under consideration. For the year under
consideration, the assessee filed its return of income electrically on 29.09.2008,
declaring income of Rs. 766,99,04,200/- under normal provisions of the Act, after
availing of various deductions under the provisions of the Act. The case was
selected for scrutiny and notice under Section 143(2) of the Act was issued on
28.03.2009. Subsequently, on 29.03.2010, the assessee filed revised return of
income reducing income under normal provisions of the Act to Rs. 766,72,79,900/-
. In the case of the assessee, the tax on the book profit under section 115JB of the
Act was higher than the tax under normal provisions of the Act, and therefore, the
assessee company paid tax as per the provisions of section 115JB of the Act. The
assessment was completed under Section 143(3) of the Act at an assessed income
of Rs. 1033,26,17,030/- by the Assessing Officer on 27.12.2010. Subsequently, the
ld. CIT, Hisar who was having administrative control over the Assessing Officer,
called for records for examination and observed that the assessment order passed
by the Assessing Officer under Section 143(3) of the Act on 27.12.2010 was
erroneous in so far as it was prejudicial to the interest of the revenue as sales tax
subsidy which was revenue in nature was omitted for addition, there was omission
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

to disallow of claim of deduction of gratuity and additional depreciation on the
computer software and he thus issued notice dated 3.1.2013 under section 263 of
the Act to the assessee allowing opportunity of being heard. After considering the
reply of the assessee in an order dated 25.3.2013 he set aside the assessment order
invoking provisions of section 263(1) of the Act in respect of above stated issues
and matter was restored back to the file of the AO with direction to make fresh
assessment after making necessary and property enquiry/investigation in light of
the discussion (but not necessarily, limiting to the same) and providing opportunity
of being heard to the assessee company. Hence this appeal is before us.

4. In Grounds of appeal raised, the main issue in dispute is whether the finding
of the CIT that the assessment order dated 27.12.2010 was erroneous and
prejudicial to the interest of revenue on issue of taxability of incentive/subsidy
amounting to Rs. 81.59 crores and other issues, was beyond jurisdiction, is bad in
law and void ab-initio. In Ground 1.1 the assessee has raised that twin conditions
of Section 263 i.e. assessment order being erroneous as well as prejudicial to the
interest of the Revenue were not satisfied. In Ground 1.2, the assessee has raised
that the findings of the CIT that the Assessing Officer did not conduct the
necessary and proper inquiries/verifications and did not apply the correct
proposition of law, was outside the scope of the revisionary powers under section
263 of the Act.

5. In Ground 1.3, the assessee has raised the issue that the CIT has not arrived
at any conclusive finding on the merit as to how the assessment order was
erroneous as well as prejudicial to the interest of revenue. All the above grounds
revolve around the legality of proceedings under section 263 of the Act. Further,
in Ground 2, it has been specifically contended that the CIT erred on facts and in

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

law in holding that the order passed by the assessing officer was erroneous and
prejudicial to the interest of the revenue on account of the following:

i) Allowing reduction of sales tax incentive/ subsidy amounting to
Rs.81.5 crores from the taxable income by treating the same to be
non- taxable, being in the nature of capital receipt;

ii) Allowance of additional depreciation of Rs.5,91,106 on computer
software ‘Primavera’.

6. So far as the taxability of sales tax subsidy is concerned the relevant facts
are that in the financial year 2000-01, the assessee company was granted an
exemption from Central Sales Tax (CST) vide notifications of even no. dated 24 th

April, 2000 in respect of sale of goods manufactured/ by-products etc. from its new
industrial unit(s) established in the state of Madhya Pradesh, with a commitment of
capital investment in fixed assets exceeding Rupees 100 crores over a period of
five years commencing from 1 st
April, 2000. Under the notification, the assessee
was granted exemption for twelve years from date of commencement of
commercial production, if the capital investment in fixed assets made was upto Rs.
500 crores and exemption was to be extended to eighteen years from the date of
commencement of commercial production, if the investment in fixed assets
exceeded Rs. 1000 crores. The above notification was issued under sub-section (5)
of section 8 of the Central Sales Tax Act, 1956, wherein it is provided that in case
of sale in course of inter-state trade or commence by a dealer to a registered dealer
or to government, the state government in public interest by notification direct that
no tax shall be payable by a dealer having place of business in the state of Madhya
Pradesh in respect of sales of specific goods in the course of inter-state trade or
commerce to a registered dealer or government. Similar exemptions were granted
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

to the assessee company for Entry Tax and Electricity Duty through separate
notification of even number dated 24-4-2000 and dated 29-07-2000 respectively.
Accordingly, the assessee company made investments in their ‘Raigarh’ unit,which
was granted various exemption mentioned in the notifications. In the month of
November, 2000 a new state of ‘Chhattisgarh’ was carved out of part of state of
Madhya Pradesh and the ‘Raigarh’ unit of the assessee became part of the state of
‘Chhattisgarh’. The exemptions granted by State of Madhya Pradesh were not only
endorsed by the new state of Chhattisgarh but in case of electricity duty, exemption
period was extended. The assessee company in the years, subsequent to the year of
notification, worked out the benefit availed of under the CST exemption
notification and other notifications. In the statement of computation to the return
of income filed, the assessee company reduced the amount of sales tax exemption
entitled out of the profit & gain of the assessee company as sales tax subsidy of
capital nature. However, the claim of the assessee was not accepted by the
Assessing Officers and the benefit of sales tax exemption was held by the
Assessing Officers as taxable revenue receipt. The CIT(A) confirmed the stand of
the Assessing Officer and on appeal by the assessee to the Tribunal in AY 2004-
05, the bench of the Tribunal in ITA No. 3319/Del/2008 held the benefit of sales
tax exemption as taxable revenue receipt. The aforesaid decision of the Tribunal
has been followed by the Tribunal in assessment year 2002-03 & 2004-05 in ITA
No. 368/Del/2001 and 136/Del/2000 respectively vide order dated 06.03.2014.
7. During the proceedings under 263 of the Act before the CIT, on the issue of
the sales tax subsidy, the assessee vide its letter dated 17.12.2013 submitted that
the order was not erroneous and prejudicial to the interest of the revenue as sales
tax subsidy was claimed and allowed in accordance with the purpose test held by
the Hon’ble Supreme court in the case of Ponni Sugar and Chemical Limited v

7

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

CIT, 306 ITR 392. Further the assessee submitted that the judgment in the case of
Abhishek Industries Ltd. 286 ITR 1 (P&H) was not applicable as the Hon’ble
Court was not having benefit of the judgment of the Hon’ble Supreme court in the
case of Ponni Sugar and Chemicals (supra). Further, the assessee submitted that the
Hon’ble Punjab & Haryana High Court in the case of CIT v. Siyaram Garg (HUF),
237 CTR 321 has followed the judgment in the case of Ponni Sugar and Chemical
Limited (supra) and subsidy received for setting up of industrial unit in backward
area was held as capital receipt. Further, the assessee submitted that the action
proposed by CIT under section 263 of the Act was beyond the jurisdiction as twin
conditions of the order being erroneous and prejudicial to the interest of the
Revenue were not fulfilled. The assessee further submitted that according to the
judgment of the Hon’ble Supreme Court in the case of Malabar Industrial
Company Ltd. v CIT, (2000) 243 ITR 83, where two view are possible and the ITO
has taken one view with which the CIT does not agree, the order of the ITO cannot
be treated as erroneous order prejudicial to the interest of Revenue unless the view
taken by the ITO is unsustainable in law. The assessee also supported its stand with
a plethora of other judgments.
8. The CIT, however, held that on the issue of sales tax subsidy actually no
view was formed by the ld. Assessing Officer at all and the Assessing Officer
allowed the claim of sales tax exemptions without noticing the fact that the said
amount was rooted by the assessee through the reserve and surplus account in the
year under consideration as against the claim for subsidy used to make in the
computation of income in earlier years. The CIT observed that the sales tax
exemptions amount was held by the Assessing Officer in earlier years as revenue
expenditure and the same was also upheld by the CIT(A) and thus the action on the
part of the Assessing Officer, though having clear departmental view before him,

8

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

rendered the assessment order erroneous. The CIT concluded that the omission on
the part of the Assessing officer leaving the issue unconsidered has caused
prejudice to the Revenue. He has held that in the assessment completed under
section 143(3) of the Act by the Assessing officer, though addition for Entry Tax
and Electricity Duty exemption benefit have been made but no addition was made
in respect of sales tax benefit by the Assessing Officer. The CIT has also observed
as under:

i) that Rs. 81.59 crores shown by the assessee as sales tax
subsidy/capital reserve under the head ‘Revenue and surplus’ in Schedule -2
of the balance-sheet as on 31.03.2008 , was not received by the assessee
from the State Government.
(ii) that the invoices were raised in respect of inter-state sales from the
exempted unit, without incorporating any sales tax component and entire
amount of sale proceeds were credited as revenue item to the P & L
Account, however, at the financial year end the profit of the assessee
company was reduced by passing journal entry for appropriation of Rs.
81.59 crores as sales tax subsidy.
iii) that the unit of the assessee was exempt from payment of sales tax
and thus was not authorize to collect any amount of sales tax, however, the
assessee assumed that within the total sales proceed, there was a component
of sales tax subsidy, which was equivalent to the amount of exempted
amount of sales tax, which would have been payable but for said exemption
by the State Government, not paid.
iii) that the assessee claimed the above sales tax exemption benefit as
non-taxable capital subsidy but the assessee did not subtract the said amount
from the cost of the capital asset, on which depreciation was claimed and
thus the assessee took double benefit of something which was actually not
received from the State Government; and
iv) that the sales tax exemption was available to the assessee in earlier
years also and the part of which was treated as sales tax subsidy, was not
taken to the balance-sheet, but it was claimed as deduction at the time of
computation of income and the Assessing Officer as well as the CIT(A)
rejected the claim of the assessee and treated the same as revenue in nature
in view of the decision of Jurisdictional High Court in the case of Abhishek

9

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

Industries Ltd. 286 ITR 1 (P&H) wherein it is held that subsidy in the form
of sales tax exemption was revenue receipt and chargeable to tax.

9. In respect of the claim of the assessee that on merit the assessee was entitled
for deduction of sales tax subsidy as capital receipt and Assessing Officer had
rightly allowed, the CIT in his order under 263 of the Act observed as under:
i) No right to collect sales tax.
As vide notification of even no. 24th
April, 2000 the Govt. of Madhya
Pradesh exempted the Raigarh Unit of the assessee company from levy of
sales tax. The Govt. was having no right of collection and transfer the same
amount back to the assessee as the subsidy, as against the sales tax
deferment schemes of various Governments, where the assessee was given
right to collect the sales tax and retain the same for a particular period as a
loan. Further the sales tax benefit was not specified in the sales invoices
issued by the relevant unit of the assessee. Further, only accounting entries
have been passed at the end of the previous year transferring the amount
corresponding to the sales tax exempted to the reserve and surplus account
from the sales account. The entire sale proceeds shown in invoice accrued to
the assessee by way of transferring of property and the goods under sales
and by not recognizing the entire sale proceeds (shown in the sales invoice
as revenue), the assessee violated the provisions of Sales of Goods Act and
provisions of Section 145(2) of the Act in the light of definition of ‘Accrual’
and ‘substance over form’ issued in notification no. SO 69(E) dated
25.01.1996 by the Central Govt. Since there was no right of the State Govt.
in respect of this amount there was no question that the State Government
could give it to the assessee and since the State Government could not give
anything, there was absolutely no question as to whether it was capital or
revenue receipt and thus the act of the assessee in passing of entry at the year
ending treating part of the sale receipts as capital subsidy was against all
principle of law as well as accountancy.

ii) Only simple tax exemption rather than subsidy/incentive under any
scheme of the Govt. of Madhya Pradesh.
The claim of the assessee that the assessee company was granted sales tax
exemption vide notification of even no. dated 24 th
April, 2000 , relying on
the earlier notification of even numbers dated 3.6.1993 and Industrial Policy
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

of 1994 of Govt. of Madhya Pradesh, was without any basis as there was
no live link between the notification of 1993/Industrial Policy, 1994 and the
notification of even number dated 24 th
April, 2000. There was no mention of
any objects of granting exemption like development of backward areas or
generation of employment etc in the notification under which the assess was
granted exemption from payment of CST.
iii) The benefit granted under the notification was more than the
investment made by the company in the said unit.
(iv) The Industrial Policy and notifications issued clearly mentioned that
the scheme of state capital investment subsidy was in operation before the
issue of notification in the case of the assessee and if the assessee had
availed any benefit under the said scheme, the same was required to be
refunded back. Thus the exemption granted was not part of any scheme of
subsidy or Industrial Policy.

10. Furthermore CIT after analyzing various judgments of the Hon’ble Supreme
Court and the Hon’ble High Courts held that the judgment in those cases were not
applicable to the facts of the case as in the case of the assessee as there was no
clear scheme specifying the objects of development or providing employment etc.
and it was a mere simple sales tax exemptions.

11. As regards deduction of Rs. 1.81 crores under the head provision of gratuity;
the CIT observed variation in the statutory liabilities in respect of provision for
leave encashment and provision for gratuity amounting to Rs. 2.55 crores and thus
in the notice issued under Section 263(1), the CIT asked the assessee as why that
the assessment order may not be held as erroneous and prejudicial to the interest of
the Revenue on that issue. After getting submissions from the assessee, the CIT
was satisfied with the explanation in respect of leave encashment, however, the
explanations in respect of provisions for gratuity was not accepted. According to
the CIT figures of the last year could not be reconciled and the assessee also
accepted omission of the addition of Rs. 88,00,000/- on gratuity liability
transferred to general reserve. According to the CIT failure on the part of the
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

Assessing Officer rendered the assessment order erroneous and prejudicial to the
interest of the Revenue on that issue.

12. As regards additional depreciation of Rs. 5,91,106/- on computer software
‘primavera’, the CIT observed that the assessee company claimed the additional
depreciation of Rs. 5,91,106/- on the computer software ‘Prima Vera’, which
according to the CIT was entitled for being office appliances/machinery and not
part of the plant and machinery engaged in the manufacturing and thus in the
notice issued under Section 263(1), the CIT asked as to why the assessment order
may not be suitably modified as it was erroneous and prejudicial to the interest of
the revenue on this issue. The contention of the assessee was that software ‘Prima
Vera’ was focused exclusively on helping the project intensive business, manage
the entire project portfolio live cycle and it was a multi planning project. Further,
the assessee submitted that the software was for enabling online management of
projects at various site locations in pro-active coordination with respective
personal commencing from project conceptualization, finalization of projects, real
time monitoring and information exchange with site on progress made etc.
According to the CIT the software was not actually installed within any
manufacturing machinery and it was independent office equipment which helped
the assessee to manage the project in better ways. Thus, it was only office
equipment and not eligible for additional depreciation available in respect of plant
and machinery used in manufacturing activity. Thus, failure on the part of the
Assessing Officer to consider this issue caused a prejudice to the Revenue
according to the CIT. Aggrieved with the order of the CIT, the assessee filed an
appeal before us.

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

13. At the time of hearing before us, the ld Authorized Representative of the
assessee (in short ‘AR’) referred to the application for admission of additional
evidence in terms of Rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963
containing certain documents/notification/correspondence between various
departments of the State Government and the representatives of the assessee
company. According to the ld. Authorized Representative, the said
documents/notifications/correspondences were received recently by the assessee
under the Right to Information Act and, therefore, the same could not be submitted
before either the Assessing Officer or the Commissioner of Income Tax in
proceedings under Section 263 of the Act. He further submitted that these
evidences were crucial for adjudication of grounds of the appeal filed by the
assessee. It was further submitted that these documents were filed only in support
of the averment of the assessee before the lower authorities. The ld AR drawn our
attention to the judgment of the Hon’ble Delhi High Court in the case of the CIT v
Text Hundred India (P.) Ltd 351 ITR 57, wherein their Lordship has held that Rule
29 is made to enable the Tribunal to admit any additional evidence which would be
necessary to do so substantial justice in the matter.

14. On the other hand, the counsel of the Revenue Sh. Manchanda opposed
admission of the additional evidences stating that English version of most of the
correspondences/notifications were already considered and reproduced by the CIT
in the impugned order. The ld. counsel further submitted that sufficient opportunity
was already provided to the assessee by ld. Assessing Officer in proceedings under
Section 143(3) and also by the ld. CIT in the proceedings under Section 263 of the
Act. Further, the ld Counsel submitted that the additional evidences are submitted
in respect of addition of sales tax subsidy and that issue has already been discussed
at length by the Tribunal for AYs 2002-03, 2004-05 and 2005-06 and the issue in
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

dispute has been held against the assessee. In the rejoinder, ld. counsel for the
assessee submitted that the correspondence with various department of the State
Govt. is having bearing on the issue in dispute in respect of sales tax subsidy and
all these information could only be collected through the Right to Information Act
(RTI) and thus could not be produced in earlier proceedings.

15. We have heard the rival submissions on the issue of admission of additional
evidences. The additional evidences are undisputedly correspondence with the
various departments of Govt. of Madhya Pradesh in respect of the issue in dispute.
It is also seen that these documents were normally not available in public domain
and the assessee could obtained through query under Right to Information Act
(RTI) and thus we feel it appropriate to admit these evidences for consideration,
and thus we admit accordingly.

16. At the time of hearing, ld. Authorized Representative/ counsel for the
assessee highlighted the legal position as held by various courts in respect of
Section 263 of the Act. Referring to the judgment of Hon’ble Supreme Court in the
case of Malabar Industrial Co. Ltd. Vs. CIT, reported in 243 ITR 83, the ld.
Authorized Representative submitted that under Section 263 of the Act, the
Commissioner can revise the order of the assessment only if the twin conditions
i.e. the order is erroneous and the order is prejudicial to the interest of revenue, are
satisfied cumulatively. The ld. AR also referred to the judgment of the Hon’ble
Apex Court in the case of CIT v. Max India Ltd. 295 ITR 282 in this regard.
Further the ld. AR submitted that once the relevant details/documents are available
on record and a view can be formed by the Assessing Officer on the basis of
material available on record and it may not be necessary for the Assessing Officer
to conduct the detailed inquiry. In support of the proposition, he relied on the

14

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ITA Nos. 3283/Del/2013 &
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M/s. Jindal Steel & Power Ltd.

judgment of the Hon’ble Delhi High Court in the case of CIT Vs. Eicher India
Ltd, 294 ITR 310 (Del.). Further, the ld. AR made a proposition that where on a
particular issue all the material facts are available on record sufficient to form an
opinion on the matter that even if no inquiry was conducted by the Assessing
Officer during the assessment proceedings, the assessment order cannot be held to
be erroneous so as to exercise the jurisdiction under Section 263 of the Act. In
support of the above, the ld. AR placed reliance on the judgment of the Hon’ble
Delhi High Court in the case of CIT v. DLF Ltd., 350 ITR 555 and CIT v Hero
Auto Ltd., 343 ITR 342 (Del.). In his written submission, he provided a long list of
judgments of various High Courts. Further, the ld. AR submitted that wherein the
issue has been examined by the Assessing Officer, the CIT(A) cannot set aside the
assessment merely because according to the CIT, the inquiry should have been
conducted in a particular manner and/or further inquiry ought to have been
conducted by the Assessing Officer. Further, he stated that no jurisdiction under
Section 263 of the Act can be assumed merely on the inadequacies of the inquiry.
In support of the above proposition, he relied on the judgment of the Hon’ble Delhi
High Court in the case of CIT v New Delhi Television Ltd. 360 ITR 44 and list of
other decisions which were given in the written submission. Further, the ld. AR
submitted that where two views are possible and the Assessing Officer has taken
the one view with which the Commissioner is not agreed, then the assessment
order cannot be held as erroneous, until the view taken by the Assessing Officer is
unsustainable in law. In support of the proposition also, the ld. AR submitted a list
of cases including the judgment of the Hon’ble Supreme Court in the case of
Malabar Industrial Co. Ltd. (supra) and Max India Ltd. (supra) and other of cases.

17. Further on facts of the case, the ld AR submitted that the sale tax subsidy
received of Rs. 81.5 crores was a capital receipt and not liable to tax. He submitted
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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

that from the year 2000 new industrial unit was set up at Raigarh in the state of
Madhya Pradesh by the assessee. It was contended that Govt. of Madhya Pradesh
vide notification dated 24.4.2000 read with notification dated 3.6.1993, exempted
the assessee company u/s 8(v) of the Central Sales Tax Act’ 1956 from payment of
Central Sales Tax. It was thus submitted that in accordance with the above Scheme
of exemption, Rs. 81.59 crores was availed on account of sales tax in the instant
year. It was submitted that such a exemption was provided to the appellant for
setting up new industrial unit in the backward area, to promote industrialization,
create employment and therefore such an incentive was an capital receipt. As
regards the complete disclosure of facts of sales tax subsidy/ incentive, it was
submitted that such incentive was disclosed under the sub-head sales tax
subsidy/capital reserve in schedule 2 to Reserves and Surplus of Balance sheet in
compliance with Accounting Standard 12 i.e. accounting for government grants
issued by Institute of Chartered Accountants of India (ICAI). The ld. AR further
invited our attention to the notification issued by the Govt. of Madhya Pradesh to
contend that the observation of the CIT that the sales tax subsidy was a revenue
receipt was an erroneous observation. He emphasized that the scheme/notification
were available only to industrial units and therefore any benefit/incentive was
intended for the industrial and economic development of the state and therefore a
capital receipt. He placed reliance on the judgment of the Apex Court in the case
of VSSV Meenakshi Achi 60 ITR 253 and Sahni Steel and Press Works Ltd. vs.
CIT 228 ITR 253 to submit that the character of the subsidy is to be determined
having regard to the purpose and the subsidy was to help the assessee to setup a
industrial unit in backward area , hence such a subsidy is to be treated as capital
receipt and not revenue receipt. Further it was submitted that Special Bench of the
Tribunal in the case of DCIT vs. Reliance Industries Ltd. 88 ITD 273 (Mum) (SB)

16

———————Page 17———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

dealt with a similar issue and held that exemption from liability from payment of
sales tax for a period of five years is a capital receipt not liable to tax. It was
specifically highlighted that the basis adopted by the CIT in the impugned order is
identical to what was adopted before the Special Bench and since the objectives of
the scheme applicable to the assessee are pari materia with the incentives scheme
before the Special Bench, applying the purpose test the sales tax incentive be held
to be a capital receipt. It was contended that the finding of CIT that subsidy was
granted for day-to-day business function was contrary to the purpose of the scheme
which is to bring about necessary infrastructure in the backward area of the state.
It was further submitted that even the observation of the CIT that the subsidy
exemption was hypothetical, is incorrect. It was stated that the CIT has failed to
appreciate that in view of the exemption no sales tax was separately charged in the
invoice , but that could not change the basic character of the incentive granted to
the appellant company. Our attention was drawn to few bills to state that final price
of the products sold by the appellant company both from the exempt unit and non
exempt unit was identical and therefore mere fact that sales tax was not charged
specifically in case of an exempt unit, it could not be held that such incentive was
notional. It was further contended that the observation of the CIT that appellant
was unable to link the subsidy with scheme of the Government was also
unsustainable. It was also submitted that the CIT has erroneously applied the
judgment of Apex Court in the case of Ponni Sugars & Chemicals Ltd. (supra) to
hold that such subsidy is revenue receipt. It was submitted that mere fact that the
amount of subsidy was to be utilized for the repayment of term loan was not the
basis for the Apex Court in the case of Pooni Sugar (supra) to hold that subsidy
was a capital receipt. It was submitted that in facts of the case there was no
specific obligation in the scheme for utilization of subsidy but as a matter of fact

17

———————Page 18———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

that assessee had no other alternative but to utilize subsidy for repayment of
secured borrowing. The learned AR emphasized that such an treatment has no
application to regard the receipt as revenue receipt. It was further submitted that
no doubt that in the case of the assessee in assessment year 2002-03, 2004-05 and
2005-06 in ITA Nos 368/D/2009, 3319/D/2008 and 168/D/2009 has vide separate
orders held that the subsidy to be revenue receipt and appeals filed by assessee are
pending before the Hon’ble Jurisdictional High Court of Punjab & Haryana yet
since such a decision is contrary to the binding decision of Special Bench in the
case of Reliance Industries (supra) therefore the same cannot be treated as binding
precedent. He has further referred to various paragraphs of the order of Tribunal
for the A.Y. 2004-05 to contend that such a conclusion was not in accordance with
the decision of Special Bench. It was specifically submitted that the appeal filed
by the Revenue against the order of Special Bench stands dismissed by the Hon’ble
Bombay High Court vide judgment reported as CIT vs. Reliance Industries Ltd.
339 ITR 632 and on further appeal the Hon’ble Supreme Court in Civil Appeal No.
7769 of 2011 merely set aside the order of Bombay High Court and directed High
Court to consider the matter on merits but such a finding does not overrule or set-
aside the decision of Special Bench which continues to be operating and binding.
He further also drew our attention to notes to accounts of the audited financial
statement, audit report and tax audit report to submit that complete disclosure was
made by the appellant company and view taken by the AO was a plausible view
which could not by any stretch of arguments be regarded as erroneous and
prejudicial to the interest of revenue warranting exercise of revisionary jurisdiction
u/s 263 of the Act. He further submitted that during the assessment proceedings
the specific query was raised by Questionnaire 1.2.2010 and same was replied vide
reply dated 12.11.2010 and therefore the presumption of CIT that the issue was not

18

———————Page 19———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

examined in absence of an office note is incorrect with the fact, which clearly
demonstrate that enquiries were made by the Assessing Officer.

18. It was further submitted that the allegation of CIT that disallowance of
provision for gratuity expenses was lower on the ground that there was a difference
in the amount outstanding statutory liabilities as per balance sheet as on 31.3.2008
and amount outstanding as per tax audit report, was also not justified. It was
submitted that complete disclosure viz-a-viz the aforesaid provision was made by
the assessee and such issue was specifically examined by the AO during the
assessment proceedings as would be seen from reply dated 12.7.2010 and
15.9.2010, copies placed on record. Lastly, even viz-a-viz the additional
depreciation it was submitted that computer software also constituted plant and
machinery which was for eligible depreciation u/s 32(1)(ii)(a) of the Act. He
supported his contention by the judgment of Gujarat High Court in the case of CIT
vs. Statronics & Enterprises (P.) Ltd. 288 ITR 455 and CIT vs. Radla Machinery
Export 155 Taxman 131 (All). It was further submitted that viz-a-viz the aforesaid
claim complete disclosure was made which was duly examined by the learned AO
in the order of assessment. Having regard to the above, it was submitted that the
order of assessment was framed with due application of mind and after considering
all requisite information and explanation tendered and therefore such an order
could not be regard as erroneous and prejudicial to the interest of revenue, so as to
exercise jurisdiction u/s 263 of the Act.

19. Before us the ld counsel for the Revenue Sh. Ashok Manchanda alongwith
ld. CIT DR Sh. Saroha pleaded that order in exercise of power u/s 263 of the Act
was in accordance with law. It was submitted that major issue in this case revolves
around the amount of Rs. 81.59 crores which the assessee claimed as capital

19

———————Page 20———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

receipt whereas by the Revenue’s stands it is revenue receipt. It was contended by
the ld. counsel of the Revenue that the facts of the various cases relied upon by the
ld AR are different from the facts of the assessee and thus ratios of those cases
were not applicable on the issue in dispute. It was further submitted that in the case
of the assessee the sales tax exemption was merely in the nature of revenue receipt
from an exemption granted by the Government and not in the nature of subsidy or
incentive to be considered as Capital Receipts. As regards to disclosure of the
transactions of sales tax exemption , the ld. Counsel of the Revenue submitted that
in the years prior to the year under consideration, the receipts corresponding to
sales-tax exemption were shown as part of sales receipts in trading account and the
assessee used to claim the deduction holding the same as capital receipts in the
statement of computation of Income, but in the year under consideration, the
assessee at the end of the year transferred the said sum corresponding to the sales
tax exemption directly to reserve and surplus account as part of Balance sheet and
did not claim the same under the statement of computation of income. This was a
marked departure from the accounting policy followed by the assessee in earlier
years, and despite this departure, the assessee omitted to make necessary disclosure
in the return of income filed. The ld Counsel submitted that this treatment to the
sales-tax exemption was done deliberately to avoid any notice by the Assessing
Officer. He further submitted that the assessee has made accounting entry of
transfer of sales- tax exemption directly to reserve and surplus account, stated to be
following accounting guidelines in respect of Government Grants but the assessee
failed to explain as why the same accounting guidelines were not followed in case
of other exemptions of Electricity Duty and Entry Tax, etc. The ld Counsel of the
Revenue submitted that the order of the Assessing Officer was erroneous as he
failed to apply mind to the position of the claim of the Revenue in earlier years,

20

———————Page 21———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

where the Revenue was consistently disallowing the sales-tax exemption claimed
by the assessee as capital receipt before the Assessing Officer and the appeals of
the assessee were dismissed by the CIT(A). The Counsel submitted that no query
was made by the AO on the issue of sales-tax exemption and therefore he cannot to
be deemed to have formed a view on this point in the assessment order. He further
submitted that inadvertent mention of the word ‘ sales-tax’ by the AO in composite
query in relation to other exemptions of Entry tax and Electricity duty cannot be
termed as enquiry done in respect of sales-tax exemption and had the AO aware of
the sales tax exemption amount included in sum of the Entry Tax and Electricity
duty, he would have taken the same view that he had taken in respect of Entry Tax
and Electricity duty and no different view would have been taken and thus the
view of the CIT has not substituted the view of the Assessing Officer. The ld.
counsel of the Revenue contended that there was no office note by the Assessing
officer to justify change in stand. The revenue relied on the decision of the
Tribunal in the case of NIIT Vs CIT reported at (2015) 60 taxmann.com 313
(Delhi), judgement of the High Court of Madras in the case of CIT vs Smt Laxmi
Narayana reported at 157 ITR 816, judgment of High Court of Delhi in the case
of CIT v. Goetz (India) Ltd. 361 ITR 505 and submitted that it was a case of no
enquiry and due to these errors on the part of the Assessing Officer prejudice was
caused to the Revenue and the CIT was fully justified in directing the AO to pass a
fresh assessment order. He also relied on the following judgements in support of
his contention that the AO has not applied his mind to the facts of the assessee and
non application of mind has resulted in assessment order as erroneous as
prejudicial to the Revenue:
i) Malabar Industrial Co. ltd Vs CIT 243 ITR 83 (SC)
ii) Gee Vee Enterprise Vs. Addl CIT 99 ITR 375 (Delhi)

21

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

iii) K.A. Ramaswamy Chettiar v CIT 220 ITR 657 (Mad)
iv) Toyota Motor Corporation v CIT 306 ITR 52 (SC)

20. The ld counsel of the Revenue also presented in detail that even on merit, the
issue of sales-tax exemption as revenue receipt in the hands of the assessee stood
in favour of the Revenue. He narrated in details the concerned notifications issue
by the Government of Madhya Pradesh granting exemption for central sales-tax
(CST), Entry Tax, Electricity Duty and submitted that those notifications were not
linked in any way with the Industrial Policy of the State of Madhya Pradesh and
the letters of correspondence between the management of the Company and the
Official of the Government of Madhya Pradesh also could not establish that
notification under which exemption was granted to the assessee was a result of
Industrial policy of the Government and thus various decisions and judgments
relied upon by the assessee in respect of the issue whether the sales-tax subsidy is a
capital subsidy or revenue subsidy were not applicable over the facts of the
assessee. It was further contended that there was improper disclosure on part of the
assessee in tax audit report and note 5 of schedule 20 to the Balance Sheet also did
not state that sales tax subsidy was of a capital nature. It has been also contended
that double benefit has been claimed by including sales tax subsidy as part of
eligible profit under sections 80IA/80IB of the Act and by not reducing the same
from cost of assets as per Explanation 10 to section 43(1) of the Act. It was also
submitted that sales tax subsidy claimed by the assessee was notional in nature as
the assessee did not charge the same in invoice(s). The Revenue has relied on the
decision of Tribunal in assessee’s own case for assessment year 2004-05. It was
also contended that sales tax formed part of trading receipts and there was no
specific section for excluding the same. It was further contended that assessee

22

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

could not produce sufficient number of invoices pertaining to the relevant period
comparable in terms of quality, quantity and time in case of two types of sales. The
learned CIT DR contended that the assessee did not take an alternate plea before
the lower authorities to allow claim of Rs. 81.59 crores under section 80IB of the
Act in case sales tax subsidy be not held to be non taxable capital receipt, goes to
substantiate that the amount was in the nature of taxable revenue receipt. It was
further contended that subsidy has been assigned a very narrow meaning as per
Oxford Advanced learned Dictionary to include only cases where money is
actually paid. It was also contended that disclosures made in tax audit report and
other documents were not relevant.

21. So far as the second issue is concerned, it was submitted that there was
difference of Rs. 1.81 crores under the head provision for “gratuity”. The Revenue
contended that instead of disallowance of Rs. 49.41 lakhs entire amount of Rs. 1.92
crores ought to have been disallowed under section 40A(7) of the Act. It was
further contended that appellant had not filed reconciliation and ledger account of
gratuity in the assessment proceedings and had in fact concluded that there was
prejudice to interest of revenue. The third issue i.e. claim of additional deprecation
of Rs. 5,91,106/- on computer software ‘Primavera’, the Revenue relied upon the
findings of the CIT to support the order u/s 263 of the Act.

22. The learned AR in his rejoinder submission contended that there was no
change in the method of accounting (mercantile basis) requiring any specific
disclosure in return of income. It was submitted that treatment was duly supported
by AS-12, on the opinion of expert’s advisory committee of the ICAI and
complete/specific/adequate disclosures were made in the audited financial
statements, audit report and tax audit report. The learned Authorized

23

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

Representative also contended that on the issue of sales tax exemption, the assessee
filed reply dated 11.2.2010 in response to the questionnaire dated 1.2.2010 during
the course of assessment proceedings. It was further contended that assessee made
proper disclosure in financial statements and specific disclosures were made vide
clause 13(e) of tax audit report. Further, vide No. 5 of Schedule 20 of audited
accounts, it was specifically disclosed/stated that sales tax subsidy was accounted
under “sales tax subsidy reserve account”. It was contended that allegation of
double deduction is patently erroneous and denied. It was submitted that the
assessee had excluded sales tax subsidy from sales of respective units, thereby
excluding the same while computing deduction u/s 80IB of the Act. It was further
submitted that assessee was not required to reduce the subsidy from cost of assets
since subsidy was received for industrialization of the backward area and for
employment generation and not for reimbursing/recouping the cost of fixed assets.
It was contended that exemption granted is not blanket exemption/notional, which
is evident from the fact that assessee charged central sales tax and VAT in certain
invoices. It was contended that sales tax department has quantified/modified
exempt sales and has charged tax on sales not accepted to be exempt. It was
contended that recovery proceedings were initiated and dropped in year 2013. It
was also contended that additional burden on buyer of exempt unit, pertinently no
credit of CST is available to the buyer even if the same is charged in the invoice. It
was further contended that order of Tribunal for A.Y. 2004-05 is not referred by
the CIT and therefore, cannot be relied upon to justify proceedings u/s 263 of the
Act. Reliance was placed on the judgment of Jagadhri Electric Supply: 140 ITR
490 (P&H). Further the AR has filed a chart. titled as “Incentive Scheme –
Sequences Showing Purpose of Incentive” (Annexure I to detailed rebuttal)
bringing out complete sequence and purpose of granting subsidy, which is

24

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ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

industrial development of backward and tribal areas, employment generation, etc.
i.e., objects in larger public interest. The learned AR also contended that decisions
relied by the Revenue are not applicable. It was also contended that to determine
the character of subsidy, “purpose test” has to be applied and form, mode, manner
and time at which subsidy is granted is irrelevant. It was next contended that the
CIT DR conveniently chose to ignore the definition of subsidy in the Black’s Law
Dictionary wherein much wider meaning has been given and has been stated that
subsidy is usually in indirect form (tax breaks etc.). It was contended that assessee
placed reliance on circular no. 9/2006 and various judicial precedents wherein it
has been held that disclosures made in the audited accounts and tax audit report
form integral part of the income tax return. As regards certain specific allegations
of the Department, it was contended that the assessee has never claimed exemption
under Notification dated 3.6.1993, the assessee relied on the Industrial Policy,
1994 and the specific discussion between the Council of Ministers for granting
exemption to the assessee. It was submitted that industrial Policy 1994 was in
force till 2003 as against allegation of the Department that the same expired in
1999 and, decision in case of Reliance Industries Ltd. 88 ITD 273 (Mum) (SB) was
identical to the facts of the present case.

23. So far as the second issue is concerned that there was a difference of Rs.
1.81 crores under the head provision for “gratuity”, the learned AR in his rejoinder
submission has contended that section 40A(7) of the Act applies to contribution
made to unapproved gratuity fund and not otherwise. Accordingly, contribution to
unapproved fund amounting to Rs. 49.41 lakhs in respect of Tensa, Barbil and
Angul units was suo-motu disallowed by the assessee. As regards other unpaid
amount which was not at all in respect of contribution to be made to unapproved
gratuity fund, the same was disallowed under section 43B of the Act since under
25
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Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order
Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order Jindal Steel Power Ltd, tribunal delhi, sec263, erroneous assessment order

———————Page 26———————

ITA Nos. 3283/Del/2013 &
3128/Del/2014, AY: 2008-09
M/s. Jindal Steel & Power Ltd.

that section deduction of gratuity is allowed only on payment basis. It was further
contended that allegation of Revenue that assessee had not filed reconciliation and
ledger account of gratuity was factually incorrect. It was submitted that ledger
accounts were filed before the CIT as Annexure 3 to letter dated 11.3.2013 and
reconciliation was filed vide letters dated 17.1.2013 and 11.3.2013. It was
contended that the assessee has filed the certificate from the tax auditor to support
its contention that the omission to offer for tax the amount of Rs. 88 lacs, which
had been credited to general reserve and separately shown as such in financial
statements on account of following AS-15 for the first time in AY 2008-09 was on
account of the said inadvertent error in the tax audit report.
24. Taking up third issue i.e. claim of additional deprecation of Rs. 5,91,106/-
on computer software ‘Primavera’, the learned AR in his rejoinder submission has
contended that pictorial representation makes it patently clear that the software,
owing to its nature was installed at the plants and data input rights (level III
authorization) was merely available with plants. It was submitted that certain
access rights were available for accessing the data available in the software at
various locations, including the corporate office; but that however, does not mean
that the s

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Ashni Shah is pursuing Chartered Accountancy and is currently engaged as Article Assistant at Rasesh Shah and Associates and can be reached at ashnishah2017@gmail.com. She loves Dancing and Gyming.

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