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2012 Supreme(Del) 2566

SANJIV KHANNA, R.V.EASWAR
Steel Authority of India Ltd. – Appellant
Versus
Comissioner of Income Tax – Respondent


Advocates:
For the Appellant :Mr. S. Ganesh, Sr. Advocate with Ms. Monika Garg, Advocate.
For the Respondent: Ms. Rashmi Chopra, Sr. Standing Counsel.

JUDGMENT :

R.V. Easwar, J.

1. These are four appeals filed by the assessee under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as “Act”). They relate to the assessment years 2000-01 to 2003-04 and are directed against the decision of the Income Tax Appellate Tribunal (hereinafter referred to as “Tribunal) with regard to the claim of depreciation.

2. The facts giving rise to the appeals may be noticed. The assessee is a public sector undertaking engaged in the manufacture and sale, including export, of iron and steel of various grades. It has several steel plants in India. At some point of time the Indian Iron and Steel Company Ltd. (IISCO) was taken over by the assessee and the steel plant of IISCO also became the steel plant of the assessee. In order to meet the requirements of the assessee company, the Government of India sanctioned huge loans from the Steel Development Fund (SDF). The loans were to bear interest and had been taken over a period of years (1979-80 to 1993-94) in the past. Such loans stood at Rs. 5,277.16 crores as on 31.3.1999 in the assesse
























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