5095672025-01-012025-03-315095672025-03-315095672025-01-012025-03-31CompositionOfBoardOfDirectors15095672025-03-31CompositionOfBoardOfDirectors15095672025-01-012025-03-31CompositionOfBoardOfDirectors25095672025-03-31CompositionOfBoardOfDirectors25095672025-01-012025-03-31CompositionOfBoardOfDirectors35095672025-03-31CompositionOfBoardOfDirectors35095672025-01-012025-03-31CompositionOfBoardOfDirectors45095672025-03-31CompositionOfBoardOfDirectors45095672025-01-012025-03-31CompositionOfBoardOfDirectors55095672025-03-31CompositionOfBoardOfDirectors55095672025-01-012025-03-31CompositionOfBoardOfDirectors65095672025-03-31CompositionOfBoardOfDirectors65095672025-01-012025-03-31CompositionOfBoardOfDirectors75095672025-03-31CompositionOfBoardOfDirectors75095672025-01-012025-03-31CompositionOfBoardOfDirectors85095672025-03-31CompositionOfBoardOfDirectors85095672025-01-012025-03-31CompositionOfCommittees145095672025-03-31CompositionOfCommittees145095672025-01-012025-03-31CompositionOfCommittees155095672025-03-31CompositionOfCommittees155095672025-01-012025-03-31CompositionOfCommittees165095672025-03-31CompositionOfCommittees165095672025-01-012025-03-31CompositionOfCommittees175095672025-03-31CompositionOfCommittees175095672025-01-012025-03-31CompositionOfCommittees415095672025-03-31CompositionOfCommittees415095672025-01-012025-03-31CompositionOfCommittees425095672025-03-31CompositionOfCommittees425095672025-01-012025-03-31CompositionOfCommittees435095672025-03-31CompositionOfCommittees435095672025-01-012025-03-31CompositionOfCommittees685095672025-03-31CompositionOfCommittees685095672025-01-012025-03-31CompositionOfCommittees695095672025-03-31CompositionOfCommittees695095672025-01-012025-03-31CompositionOfCommittees705095672025-03-31CompositionOfCommittees705095672025-01-012025-03-31CompositionOfCommittees1225095672025-03-31CompositionOfCommittees1225095672025-01-012025-03-31CompositionOfCommittees1235095672025-03-31CompositionOfCommittees1235095672025-01-012025-03-31CompositionOfCommittees1245095672025-03-31CompositionOfCommittees1245095672025-03-31MeetingOfBoardOfDirectors15095672025-01-012025-03-31MeetingOfBoardOfDirectors15095672025-03-31MeetingOfBoardOfDirectors25095672025-01-012025-03-31MeetingOfBoardOfDirectors25095672025-01-012025-03-31MeetingOfCommittees15095672025-03-31MeetingOfCommittees15095672025-01-012025-03-31MeetingOfCommittees25095672025-03-31MeetingOfCommittees25095672025-01-012025-03-31MeetingOfCommittees35095672025-03-31MeetingOfCommittees35095672025-01-012025-03-31MeetingOfCommittees45095672025-03-31MeetingOfCommittees45095672025-01-012025-03-31MeetingOfCommittees55095672025-03-31MeetingOfCommittees55095672024-12-315095672025-03-31ImpositionOfFineOrPenaltyDomain15095672025-03-31ImpositionOfFineOrPenaltyDomain25095672025-03-31ImpositionOfFineOrPenaltyDomain35095672025-03-31ImpositionOfFineOrPenaltyDomain45095672025-03-31ImpositionOfFineOrPenaltyDomain55095672025-03-31ImpositionOfFineOrPenaltyDomain65095672025-03-31OngoingTaxLitigationsOrDisputesDomain15095672025-03-31OngoingTaxLitigationsOrDisputesDomain25095672025-03-31OngoingTaxLitigationsOrDisputesDomain35095672025-03-31OngoingTaxLitigationsOrDisputesDomain45095672025-03-31OngoingTaxLitigationsOrDisputesDomain55095672025-03-31OngoingTaxLitigationsOrDisputesDomain65095672025-03-31OngoingTaxLitigationsOrDisputesDomain75095672025-03-31OngoingTaxLitigationsOrDisputesDomain85095672025-03-31OngoingTaxLitigationsOrDisputesDomain95095672025-03-31OngoingTaxLitigationsOrDisputesDomain10xbrli:pure509567GOACARBONNOTLISTEDINE426D01013Goa Carbon Limited2024-04-012025-03-31Yearly2025-03-31EquitytruetruefalseDuring the quarter, Goa Carbon Limited did not acquire any Shares or Voting Rights in any Unlisted Company, aggregating to 5% or any subsequent change in holding exceeding 2% in terms of the provisions of Para A (1) of Part A of Schedule III of SEBI (LODR) Regulations, hence Annexure I (Part C) of the SEBI Circular dated December 31, 2024 related to Disclosure of Acquisition of of Shares or Voting Rights in Unlisted Companies is not applicabletruetruefalseDuring the quarter, Goa Carbon Limited did not advance any loan or any other form of debt directly or indirectly, or provided any guarantee/ comfort letter (by whatever name called), in connection with any loan(s) or any other form of debt directly or indirectly, or provided any security, directly or indirectly, in connection with any loan(s) or any other form of debt advanced / availed by the Promoter or any other entity controlled by them, Promoter Group or any other entity controlled by them, Directors (including relatives) or any other entity controlled by them, and KMPs or any other entity controlled by them, hence the same is not applicable.falseTop 2000 listed entitiestrueg00121OriginaltruefalseMrShrinivas Vasudeva Dempo00043413Non-Executive - Non Independent DirectorChairperson related to Promoter1969-02-02falseNA2006-12-302023-08-174221MsKiran DhingraAAGPD8412K00425602Non-Executive - Independent DirectorNot Applicable1953-01-12falseNA2015-07-082020-09-23116.244451MrNagesh Dinkar Pinge00062900Non-Executive - Independent DirectorNot Applicable1958-10-01falseNA2019-05-062024-05-0670.265585MrSubodh Satchitanand NadkarniAAEPN2464M00145999Non-Executive - Independent DirectorNot Applicable1956-04-02falseNA2021-01-072021-01-0750.242220MrRajesh Soiru Dempo05143106Non-Executive - Non Independent DirectorNot Applicable1975-11-29falseNA2016-01-082022-07-281011MrJagmohan Jagdishlal ChhabraACBPC7451L01007714Non-Executive - Non Independent DirectorNot Applicable1962-04-17falseNA2022-04-012024-09-101010MrSubhrakant Panda00171845Non-Executive - Independent DirectorNot Applicable1971-01-05falseNA2022-05-282022-05-2834.034310MrAnupam MisraAAUPM9960H09615362Executive DirectorNot Applicable1972-02-24falseNA2022-05-281010truetruetruetrueAudit Committee00062900Nagesh Dinkar PingeNon-Executive - Independent DirectorChairperson2019-05-06Audit Committee00425602Kiran DhingraNon-Executive - Independent DirectorMember2018-04-12Audit Committee00145999Subodh Satchitanand NadkarniNon-Executive - Independent DirectorMember2021-01-07Audit Committee01007714Jagmohan Jagdishlal ChhabraNon-Executive - Non Independent DirectorMember2024-04-01Nomination and remuneration committee00043413Shrinivas Vasudeva DempoNon-Executive - Non Independent DirectorMember2018-04-12Nomination and remuneration committee00425602Kiran DhingraNon-Executive - Independent DirectorChairperson2019-04-01Ms. Kiran Dhingra has been appointed as Chairperson of the Nomination and Remuneration Committee of the Company with effect from 9-Apr-2021.Nomination and remuneration committee00145999Subodh Satchitanand NadkarniNon-Executive - Independent DirectorMember2021-01-07Stakeholders Relationship Committee05143106Rajesh Soiru DempoNon-Executive - Non Independent DirectorChairperson2016-01-08Mr. Rajesh S. Dempo has been appointed as Chairperson of the Stakeholders Relationship Committee of the Company with effect from 12-Apr-2018.Stakeholders Relationship Committee00425602Kiran DhingraNon-Executive - Independent DirectorMember2020-02-02Stakeholders Relationship Committee09615362Anupam MisraExecutive DirectorMember2022-05-28Corporate Social Responsibility Committee00043413Shrinivas Vasudeva DempoNon-Executive - Non Independent DirectorChairperson2014-10-17Corporate Social Responsibility Committee00171845Subhrakant PandaNon-Executive - Independent DirectorMember2022-05-28Corporate Social Responsibility Committee09615362Anupam MisraExecutive DirectorMember2022-05-282024-11-08true8842025-01-3082true884Audit Committee2024-11-08true4430Audit Committee2025-01-3082true4430Stakeholders Relationship Committee2024-11-07true3310Stakeholders Relationship Committee2025-01-3083true3310Corporate Social Responsibility Committee2025-01-11true3310truetruetruetrueNAtruetruetruePravin SatardekarCompany Secretary and Compliance OfficerYeshttps://www.goacarbon.com/index.phpYeshttps://goacarbon.com/downloads/NEW_Memorandum_Articles_of_Association_GCL.pdfYeshttps://www.goacarbon.com/board-of-directors.phpYeshttps://goacarbon.com/downloads/Draft_Letter_of_Appointment_Reappointment_ID.pdfYeshttps://goacarbon.com/downloads/Board%20Committees.pdfYeshttp://www.goacarbon.com/downloads/Code_of_Conduct_Board.pdfYeshttp://www.goacarbon.com/downloads/Vigil_Mechanism_Whistle_Blower_Policy.pdfYeshttps://goacarbon.com/downloads/Nomination%20and%20Remuneration%20Policy_GOA%20CARBON%20LIMITED.pdfYeshttp://www.goacarbon.com/downloads/Related_Party_Transaction_Policy.pdfYeshttp://www.goacarbon.com/downloads/Policy%20for%20determining%20material%20subsidiaries_GOA%20CARBON%20LIMITED.pdfYeshttps://goacarbon.com/downloads/Familiarization_Programme_for_Independent_Directors.pdfYeshttps://www.goacarbon.com/shareholders-information.phpYeshttps://www.goacarbon.com/shareholders-information.phpYeshttps://www.goacarbon.com/financial-results.phpYeshttps://www.goacarbon.com/shareholding-pattern.phpYeshttps://goacarbon.com/downloads/Agreement_with_Media_Companies.pdfYeshttp://goacarbon.com/downloads/GCL_Presentation_-_Aug_2008.ppsNANAYeshttps://www.goacarbon.com/extract-of-financial-results.phpYeshttps://www.goacarbon.com/disclosures-to-stock-exchange.phpYeshttps://www.goacarbon.com/annual-reports.phpYeshttps://www.goacarbon.com/secretarial-compliance-report.phpYeshttp://www.goacarbon.com/downloads/Policy%20for%20Determination%20of%20Material%20Events%20or%20Information.pdfYeshttps://goacarbon.com/downloads/Policy%20for%20Determination%20of%20Material%20Events%20or%20Information.pdfYeshttps://www.goacarbon.com/disclosures-to-stock-exchange.phpNANAYeshttps://www.goacarbon.com/annual-reports.phpNAYeshttps://goacarbon.com/Yeshttps://goacarbon.com/YesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesNANANANAYesYesYesNAYesNANANAYesYesYesYesYesYesNAYesYesYesNANAPravin SatardekarCompany Secretary and Compliance OfficerNAPravin SatardekarCompany Secretary and Compliance OfficerfalsePravin SatardekarCompany Secretary and Compliance OfficerPanaji2025-04-2804400Labour Court Bilaspur - ChattisgarhOrder by the Labour Court Bilaspur - Chhatisgarh2025-01-29Violation of Rule 108(4) of Factories Act & Rule 7A(1)120000Labour Court Bilaspur - ChattisgarhOrder by the Labour Court Bilaspur - Chhatisgarh2025-01-29Minumum Wages Act Section 18 Rule 2D(1)5000Labour Court Bilaspur - ChattisgarhOrder by the Labour Court Bilaspur - Chhatisgarh2025-01-29Motor Traffic Labour Act 19617000Transport Department Government of Odisha JagatsinghpurRoad Tax and Fitness renewal OD21J33772025-04-17The Orissa Motor Vehicles Taxation Act, 197519000Transport Department Government of Odisha JagatsinghpurRoad Tax and Fitness renewal OD21J30662025-04-17The Orissa Motor Vehicles Taxation Act, 197539188Transport Department Government of Odisha JagatsinghpurRoad Tax and Fitness renewal ODJ21B24992025-04-17The Orissa Motor Vehicles Taxation Act, 197514810State of Goa2023-09-14Goa Green Cess Matter The Government of Goa vide notifications dated 22.05.2013 and 18.02.2014, enacted the Goa Cess on Products and Substances Causing Pollution (Green Cess) Act, 2013 & Goa Cess on Products and Substances Causing Pollution (Green Cess) (Functions and Duties of the Competent Authority, Assessment, Levy and Collection of Cess) Rules, 2014 respectively, imposing Green Cess on Petroleum Coke at 2% of the sale value. Further vide notification dated 12.09.2014, the Cess rate was revised to 0.5% of the sale value. The Company has since, begun collection the Green Cess from its customers, however, the amount has not been deposited with the State Government as the registration formalities could not be initiated on account of the concerned government department being unable to provide us the required assistance. In the meanwhile, it was learnt that two companies i.e. M/s. South West Port Ltd. and Vedanta Ltd. filed Writ Petitions before the Hon’ble High Court challenging the constitutional validity of the afore-said Act for which the Hon’ble High Court has passed interim order directing no coercive steps against the petitioners in connection with the disputed claim. Based on the above actions, the Company also filed Writ Petition before the Hon’ble High Court on the same grounds. However, Hon'ble High Court vide its Order dated 14 Sept 2023 dismissed the writ petition filed by the Company on 7 Oct 2019 and vacating the stay order on the proceedings of Goa Green Cess as levied by the Government of Goa, the Company had received show cause notices (SCN) dated 22 Sept 2023 for the period FY 2014-15 to FY 2019-20 for principal amount of Cess along with interest and penalty on the same u/s 54,55,57,58,59 of the Goa Value Added Tax Act, 2005. Subsequently, Assessment Orders Cum Demand Notices for FY 2014-15 to FY 2023-24 were received by the Company. The Total Demanded Goa Green Cess Amount from FY 2014-15 to FY 2023-24 is about Rs 6.28 Crore. A brief status of the matter is as under: 1) Company officials attended a hearing at the State Commercial Officer’s office on 4th October 2023, where the matter was discussed at length. Detailed submissions were filed on 20th October 2023, with additional submissions made on 20th November 2023. These submissions requested the dropping of assessment proceedings for FY 2014-15 to FY 2019-20 on the grounds of the limitation period. 2) The Company filed a Special Leave Petition before the Hon'ble Supreme Court on 11th November 2023. The Supreme Court, via its interim order dated 7th December 2023, directed the Company to pay 50% of the demand to the State Government while staying the payment of the remaining 50% pending a final order. 3) Additionally, the Company filed a writ petition before the Hon'ble Bombay High Court at Goa on 10th November 2023, challenging the SCNs related to the limitation period. 4) The Hon’ble High Court in its order dated 16th January 2024, directed the State Commercial Tax Department to address the notices, taking into account the objections raised by the Company regarding the limitation period. 5) The Company received assessment orders cum demand notices for FY 2014-15 to FY 2022-23 from the Goa State Tax Authorities on 20th February 2024 and 13th March 2024 and has deposited 50% of the demand under protest. 6) Following the Hon’ble High Court's order as mentioned at point 4 above, the Company filed an appeal for FY 2014-15 to FY 2019-20 on 15th April 2024 before the Assistant/Additional Commercial Officer of State Tax, citing the limitation period as a key issue. The matter is scheduled for a hearing on January 23rd, 2025. 7) The Company has also submitted a representation to the Government of Goa for a waiver of the Green Cess on the sale of CPC, invoking their powers under section 8 of the Act. 8) The Company also received a Notice of Assessment on 16th July 2024 for FY 2023-24. The assessment for FY 2023-24 was completed on 14th August 2024, after which GCL deposited 50% of the demanded amount, in accordance with the Assessment Order, under Protest. 9) For FY 2024-25, the Company started filing monthly returns for the period from April 2024 to December 2024 and made deposit of 50% of the Green Cess amount under protest (i.e. Rs 17.83 Lacs)Goa Green Cess Matter The Government of Goa vide notifications dated 22.05.2013 and 18.02.2014, enacted the Goa Cess on Products and Substances Causing Pollution (Green Cess) Act, 2013 & Goa Cess on Products and Substances Causing Pollution (Green Cess) (Functions and Duties of the Competent Authority, Assessment, Levy and Collection of Cess) Rules, 2014 respectively, imposing Green Cess on Petroleum Coke at 2% of the sale value. Further vide notification dated 12.09.2014, the Cess rate was revised to 0.5% of the sale value. The Company has since, begun collection the Green Cess from its customers, however, the amount has not been deposited with the State Government as the registration formalities could not be initiated on account of the concerned government department being unable to provide us the required assistance. In the meanwhile, it was learnt that two companies i.e. M/s. South West Port Ltd. and Vedanta Ltd. filed Writ Petitions before the Hon’ble High Court challenging the constitutional validity of the afore-said Act for which the Hon’ble High Court has passed interim order directing no coercive steps against the petitioners in connection with the disputed claim. Based on the above actions, the Company also filed Writ Petition before the Hon’ble High Court on the same grounds. However, Hon'ble High Court vide its Order dated 14 Sept 2023 dismissed the writ petition filed by the Company on 7 Oct 2019 and vacating the stay order on the proceedings of Goa Green Cess as levied by the Government of Goa, the Company had received show cause notices (SCN) dated 22 Sept 2023 for the period FY 2014-15 to FY 2019-20 for principal amount of Cess along with interest and penalty on the same u/s 54,55,57,58,59 of the Goa Value Added Tax Act, 2005. Subsequently, Assessment Orders Cum Demand Notices for FY 2014-15 to FY 2023-24 were received by the Company. The Total Demanded Goa Green Cess Amount from FY 2014-15 to FY 2023-24 is about Rs 6.28 Crore. A brief status of the matter is as under: 1) Company officials attended a hearing at the State Commercial Officer’s office on 4th October 2023, where the matter was discussed at length. Detailed submissions were filed on 20th October 2023, with additional submissions made on 20th November 2023. These submissions requested the dropping of assessment proceedings for FY 2014-15 to FY 2019-20 on the grounds of the limitation period. 2) The Company filed a Special Leave Petition before the Hon'ble Supreme Court on 11th November 2023. The Supreme Court, via its interim order dated 7th December 2023, directed the Company to pay 50% of the demand to the State Government while staying the payment of the remaining 50% pending a final order. 3) Additionally, the Company filed a writ petition before the Hon'ble Bombay High Court at Goa on 10th November 2023, challenging the SCNs related to the limitation period. 4) The Hon’ble High Court in its order dated 16th January 2024, directed the State Commercial Tax Department to address the notices, taking into account the objections raised by the Company regarding the limitation period. 5) The Company received assessment orders cum demand notices for FY 2014-15 to FY 2022-23 from the Goa State Tax Authorities on 20th February 2024 and 13th March 2024 and has deposited 50% of the demand under protest. 6) Pursuant to Hon’ble High Court's order, referred at point 4 above, the Company filed an appeal for FY 2014-15 to FY 2019-20 on 15th April 2024 before the Deputy/Additional Commissioner (Appeals-North) of State Tax, citing the limitation period as a key issue. The matter was heard by the Deputy/Additional Commissioner (Appeals-North) before whom company made its oral and written submissions. Hearings are ongoing. 7) The Company has also submitted a representation to the Government of Goa for a waiver of the Green Cess on the sale of CPC, invoking their powers under section 8 of the Act. 8) During the year, the Company received a Notice of Assessment dated 16th July 2024 for FY 2023-24. Pursuant to completion of Assessment on 14th August 2024, a demand of Rs.96.44 lacs was raised. Subsequently GCL, under protest, deposited 50% of the demanded amount totaling Rs.48.22 lacs. 9) For FY 2024-25, the Company has filed returns for the period from April 2024 to March 2025 and, under protest deposited of 50% of the Green Cess amounting to Rs 30.94 lacs.State of Goa & Central GST Department2023-09-26Order u/s 73(9) of Goods and Service Tax Act, 2017 dated 28.12.2023 for FY 2017-18: - 1) GST Tax liability has been determined as per Show Cause Notice in Form GST DRC-01 vide ref no. ZD300923006927E dated 30.09.2023 Rs 5.54 crores for FY 2017-18. The Company had availed input tax credit of CVD of Rs 5.59 crores paid against unfulfilled export obligations which has been disallowed for taking input credit, for which credit should have been availed under TRAN-1. As per the Order dated 28th Dec 2023, tax determined is Rs 5.54 crores and interest thereon is Rs 5.73 crores. As advised by our Tax Consultant, the Company has deposited Rs 5.54 crores of disallowed input credit under protest pursuant to the order dated December 28, 2023. The company submitted that this deposit was made under protest to prevent further interest levies and penalties on the outstanding tax, asserting that the right to credit cannot be denied. 2) Refund of CVD Application with Assistant Commissioner CGST Margao was simultaneously filed on 26th September 2023. The department rejected the appeal on 20.12.2023 based on the period of limitation. 3) Pursuant to the rejection of refund by the Assistant Commissioner CGST and denial of ITC by STO Goa State Commercial Tax, the Company filed Writ Petition in High Court of Bombay at Goa on 15th January 2024. 4) The Honb’le High Court to save limitation allowed the Company to file appeals against the Orders of the State Tax Officer Goa and Assistant Commissioner of CGST. Accordingly, the Company has filed two appeals: i) to Adnl Commissioner (Appeals), State Commercial Tax Department – Goa for allowance of Input Credit and Waiver of Interest demanded ii) to Commissioner (Appeals) Central GST, Panaji 5) Appeal with Commissioner of Central Excise (GST) (Appeals) Panaji (i) The matter was concerning for allowance of Refund. (ii) On 26th September 2023, the Company filed an application for refund of CVD paid, before the Asst. Commissioner Central GST Margao under section 11B of Central Excise Act 142(3) The department rejected the appeal on 20.12.2023 based on the period of limitation. (iii) then, an Appeal against the above order was filed before Commissioner of Central Excise (GST) (Appeals) Panaji on 13.03.2024 who directed the Asst. Commissioner Central GST Margao vide their Order dated June 5, 2024 to remand back the matter as CVD refund could not be rejected solely based on the period of limitation. The merits of the case, including procedural aspects related to limitation, were also to be considered. The case was remanded to the Assistant Commissioner CGST Margao for a decision on the refund matter. (iv) Following the above directions and post required submissions, the Asst Comm of CGST Margao again rejected the refund claim in an order dated 30.07.2024. (v) GCL again filed an appeal on September 30, 2024, before the Commissioner of Central Excise (GST) (Appeals) contesting the rejection order issued by the Asst Comm of CGST Margao. A) Status of Appeal with Commissioner of Central Excise (GST) (Appeals) Panaji (i) The Hon’ble Commissioner (Appeals), in its O-i-A GOA-CEX-APP(SBD)-030-2024-25 dated 13.11.2024, ruled in favor of the company, setting aside the earlier order of the Assistant Commissioner of CGST Margao on 30.07.2024. CIT (A) held that the company is eligible for a refund of CVD amounting to Rs. 5.54 crores. (ii) Subsequently, in compliance with the order, the Assistant Commissioner of CGST issued a refund of Rs. 5.54 crores in his order dated 09.12.2024. (iii) the Company has accordingly received refund of Rs 5.54 crore from Central GST. B) Status of Writ Petition at High Court of Bombay at Goa As the matter has been resolved and relief granted by Commissioner of Excise & GST (Appeals), the Company has withdrawn its petition. C) Status of Appeal with Adnl. Commissioner (Appeal) of State Commercial Tax (GST) Panaji (i) The matter concerns allowance of Input Credit and waiver of interest demanded. (ii) The Company filed an appeal on 28th March 2023 before Adnl. Commissioner (Appeals), State Commercial Tax Goa for allowance of Input Credit against the Order passed by State Tax Officer Goa. (iii) A hearing was held on 24th September 2024 and 9th December 2024, pursuant to which the necessary submissions were made. During the hearing held on 9th December 2024, it was informed by the Company to Adnl Commissioner (Appeals) that it has received refund order from Central GST for an amount of Rs 5.54 crore. Therefore, the matter is now limited to waiver of interest demanded by the tax authorities. (iv) Accordingly, the only remaining issue pertains to waiver of interest. (v) Recent hearing held on 24th Jan 2025 and matter is listed for hearing on 5th Feb 2025.Order u/s 73(9) of Goods and Service Tax Act, 2017 dated 28.12.2023 for FY 2017-18: - 1) GST Tax liability has been determined as per Show Cause Notice in Form GST DRC-01 vide ref no. ZD300923006927E dated 30.09.2023 Rs 5.54 crores for FY 2017-18. The Company had availed input tax credit of CVD of Rs 5.59 crores paid against unfulfilled export obligations which has been disallowed for taking input credit, for which credit should have been availed under TRAN-1. As per the Order dated 28th Dec 2023, tax determined is Rs 5.54 crores and interest thereon is Rs 5.73 crores. As advised by our Tax Consultant, the Company has deposited Rs 5.54 crores of disallowed input credit under protest pursuant to the order dated December 28, 2023. The company submitted that this deposit was made under protest to prevent further interest levies and penalties on the outstanding tax, asserting that the right to credit cannot be denied. 2) Refund of CVD Application with Assistant Commissioner CGST Margao was simultaneously filed on 26th September 2023. The department rejected the appeal on 20.12.2023 based on the period of limitation. 3) Pursuant to the rejection of refund by the Assistant Commissioner CGST and denial of ITC by STO Goa State Commercial Tax, the Company filed Writ Petition in High Court of Bombay at Goa on 15th January 2024. 4) The Honb’le High Court to save limitation allowed the Company to file appeals against the Orders of the State Tax Officer Goa and Assistant Commissioner of CGST. Accordingly, the Company has filed two appeals: i) to Adnl Commissioner (Appeals), State Commercial Tax Department – Goa for allowance of Input Credit and Waiver of Interest demanded ii) to Commissioner (Appeals) Central GST, Panaji 5) Appeal with Commissioner of Central Excise (GST) (Appeals) Panaji (i) The matter was concerning allowance of Refund. (ii) On 26th September 2023, the Company filed an application for refund of CVD paid, before the Asst. Commissioner Central GST Margao under section 11B of Central Excise Act 142(3) The department rejected the appeal on 20.12.2023 based on the period of limitation. (iii) then, an Appeal against the above order was filed before Commissioner of Central Excise (GST) (Appeals) Panaji on 13.03.2024 who directed the Asst. Commissioner Central GST Margao vide their Order dated June 5, 2024 to remand back the matter as CVD refund could not be rejected solely based on the period of limitation. The merits of the case, including procedural aspects related to limitation, were also to be considered. The case was remanded to the Assistant Commissioner CGST Margao for a decision on the refund matter. (iv) Following the above directions and post required submissions, the Asst Comm of CGST Margao again rejected the refund claim in an order dated 30.07.2024. (v) GCL again filed an appeal on September 30, 2024, before the Commissioner of Central Excise (GST) (Appeals) contesting the rejection order issued by the Asst Comm of CGST Margao. A) Status of Appeal with Commissioner of Central Excise (GST) (Appeals) Panaji (i) The Hon’ble Commissioner (Appeals), in its O-i-A GOA-CEX-APP(SBD)-030-2024-25 dated 13.11.2024, ruled in favor of the company, setting aside the earlier order of the Assistant Commissioner of CGST Margao on 30.07.2024. CIT (A) held that the company is eligible for a refund of CVD amounting to Rs. 5.54 crores. (ii) Subsequently, in compliance with the order, the Assistant Commissioner of CGST issued a refund of Rs. 5.54 crores in his order dated 09.12.2024. (iii) the Company has accordingly received refund of Rs 5.54 crore from Central GST. B) Status of Writ Petition at High Court of Bombay at Goa As the matter has been resolved and relief granted by Commissioner of Excise & GST (Appeals), the Company has withdrawn its petition from High Court of Bombay at Goa. C) Status of Appeal with Adnl. Commissioner (Appeal) of State Commercial Tax (GST) Panaji (i) The matter concerns allowance of Input Credit and waiver of interest demanded. (ii) The Company filed an appeal on 28th March 2023 before Adnl. Commissioner (Appeals), State Commercial Tax Goa for allowance of Input Credit against the Order passed by State Tax Officer Goa. (iii) A hearing was held on 24th September 2024 and 9th December 2024, pursuant to which the necessary submissions were made. During the hearing held on 9th December 2024, it was informed by the Company to Adnl Commissioner (Appeals) that it has received refund order from Central GST for an amount of Rs 5.54 crore. Accordingly, the only remaining issue was of waiver of interest. (iv) The Company took the benefit of the Amnesty scheme, inserted vide Finance Act, 2024, and in compliance with Section 128A of the CGST Act, the Company withdrew its Appeal before the Adnl Commissioner (Appeals) and made an application for waiver of interest in FORM SPL-02. (v) After reviewing the records, the proper officer granted the waiver of interest of Rs. 5,73,18,285/- under both the CGST Act and the Goa Goods and Services Tax Act, 2017 vide FORM GST SPL-05 bearing reference No. ZD300325000628W, dated 10/03/2025 and order reference No. MA300325001695D, dated 10/03/2025. Entire Matter of Principal Input Credit/Refund and Interest Demand stands closed.Asst. Commissioner CGST & Central Excise, Cuttack2024-10-161) Matter is related to rejection of refund of ITC for FY 2017-18 for Rs.48,37,468/- 2) The Company had availed input tax credit of CVD of Rs 48,37,468/- paid against unfulfilled export obligations which has been disallowed for taking input credit, for which credit should have been availed under TRAN-1. 3) During GST Audit for FY 2017-18, it was disallowed by the GST Officer as input credit. Accordingly, the Company paid the ITC availed and applied for refund to Asst Commissioner Central GST & CES Department Cuttack vide its application dated 05.01.2024. 4) Asst Commissioner Central GST & CEX vide its order dated 16.10.2024 rejected the refund of ITC paid. 5) Accordingly, the Company has an Appeal to Commissioner of Central Excise (Appeals) Bhubaneswar on 02.01.2025 on the same lines of Goa Plant. The hearing is yet to be scheduled1) Matter is related to rejection of refund of ITC for FY 2017-18 for Rs.48,37,468/- 2) The Company had availed input tax credit of CVD of Rs 48,37,468/- paid against unfulfilled export obligations which has been disallowed for taking input credit, for which credit should have been availed under TRAN-1. 3) During GST Audit for FY 2017-18, it was disallowed by the GST Officer as input credit. Accordingly, the Company paid the ITC availed and applied for refund to Asst Commissioner Central GST & CES Department Cuttack vide its application dated 05.01.2024. 4) Asst Commissioner Central GST & CEX vide its order dated 16.10.2024 rejected the refund of ITC paid. 5) Accordingly, the Company has filed an Appeal to Commissioner of Central Excise (Appeals) Bhubaneswar on 02.01.2025 on the same lines of Goa Plant. Hearing is yet to be scheduled.Commercial Tax, Cuttack-II Range, Cuttack2023-01-051) The matter is relating to VAT Assessment for the period from 01.04.2005 to 28.02.2007. 2) In assessment orders, the department disallowed ITC on FO and some other material of Rs.33 Lacs. 3) Company filed appeal against the assessment order. The Appellate Authority allowed the ITC on FO and disallowed the other consumable ITC of Rs.2 Lacs and charged penalty of Rs.5 Lacs. 4) Again, we had filed the appeal before the Sales Tax Tribunal for waiver off the Penalty. The Tribunal allowed the appeal and issued order for payment of Tax and waived the penalty. 5) The Company has paid the entire Tax demand. Then the Sales Tax Deptt filed appeal in Hon'ble High Court against the Tribunal Order for recovery of penalty of Rs 5 Lacs The matter is pending for hearing.1) The matter is relating to VAT Assessment for the period from 01.04.2005 to 28.02.2007. 2) In assessment orders, the department disallowed ITC on FO and some other material of Rs.33 Lacs. 3) Company filed appeal against the assessment order. The Appellate Authority allowed the ITC on FO and disallowed the other consumable ITC of Rs.2 Lacs and charged penalty of Rs.5 Lacs. 4) Again, we had filed the appeal before the Sales Tax Tribunal for waiver off the Penalty. The Tribunal allowed the appeal and issued order for payment of Tax and waived the penalty. 5) The Company has paid the entire Tax demand. Then the Sales Tax Deptt filed appeal in Hon'ble High Court against the Tribunal Order for recovery of penalty of Rs 5 LacsDy. Commis-sioner of Income Tax Panaji2021-03-18AY 1994-95 1) The Asstt. Commissioner of Income Tax, Panaji passed an order dated 18.07.2011 for AY 1994-95 giving effect to the ITAT Order dated 18.03.2011 disallowing 100% depreciation on the leased assets. Consequently, a tax demand of Rs. 2,47,44,414/- has been raised. 2) The Income Tax Department has recovered the tax demand to the extent of Rs. 2.47 crores against the refund orders of the other assessment years. The Company filed a rectification application on 29.05.2012 to give effect to the ITAT Order same.AY 1994-95 1) The Asstt. Commissioner of Income Tax, Panaji passed an order dated 18.07.2011 for AY 1994-95 giving effect to the ITAT Order dated 18.03.2011 disallowing 100% depreciation on the leased assets. Consequently, a tax demand of Rs. 2,47,44,414/- has been raised. 2) The Income Tax Department has recovered the tax demand to the extent of Rs. 2.47 crores against the refund orders of the other assessment years. The Company filed a rectification application on 29.05.2012 to give effect to the ITAT Order.Dy. Commissioner of Income Tax Panaji.2010-10-21AY 1993-94 to AY 2003-04 Company had exported Calcined Petroleum Coke and claimed deduction under Section 80HHC of the Income Tax Act, 1961 during the period 1992-93 to 2003-2004, for the profit derived from export of CPC. The Assessing Officer disallowed the same and held that the product `CPC' is a `Mineral Oil'. The appeal was filed with Income Tax Appellate Tribunal, (ITAT) against the Order of the Assessing Officer. ITAT has confirmed the disallowance. The Company then filed an appeal to the High Court of Bombay at Goa against the order of the ITAT. The Hon’ble High Court of Bombay at Goa vide its Order dated 21.10.2010 has ruled in favour of the Company by setting aside the impugned Tribunal’s Order. The Deputy Commissioner of Income Tax has filed a Petition before the Supreme Court for Special Leave to Appeal with prayer for interim relief against the Order of the Hon’ble High Court. The matter was to be listed on Regular Hearing Days before the Bench presided by Hon’ble Chief Justice. Tax demand amount of appx Rs. 9 crores have already been paid. Supreme Court, in its order dated 24.09.2024 in Civil Appeal No. 2396/2011, disposed off Civil Appeal No. 4960/2013 (related to AY 1999-00) due to low tax effect (less than Rs 5 crore threshold limits). The Company has submitted an application to the Department on January 16th, 2025, requesting the AO that the Order of the Hon’ble Bombay High Court be given effect.AY 1993-94 to AY 2003-04 Company had exported Calcined Petroleum Coke and claimed deduction under Section 80HHC of the Income Tax Act, 1961 during the period 1992-93 to 2003-2004, for the profit derived from export of CPC. The Assessing Officer disallowed the same and held that the product `CPC' is a `Mineral Oil'. The appeal was filed with Income Tax Appellate Tribunal, (ITAT) against the Order of the Assessing Officer. ITAT has confirmed the disallowance. The Company then filed an appeal to the High Court of Bombay at Goa against the order of the ITAT. The Hon’ble High Court of Bombay at Goa vide its Order dated 21.10.2010 has ruled in favour of the Company by setting aside the impugned Tribunal’s Order. The Deputy Commissioner of Income Tax has filed a Petition before the Supreme Court for Special Leave to Appeal with prayer for interim relief against the Order of the Hon’ble High Court. Tax demand amount of appx Rs. 9 crores have already been paid. Pursuant to Circular dated 17.09.2024 issued by the CBDT the monetary threshold of the tax effect for filing an appeal to the Hon’ble SC was increased from 2 Crores to 5 Crores. Accordingly, all appeals are dismissed by the Hon’ble Supreme Court. In light of the above, we have obtained Legal Opinion from our Advocate and following is the Assessment year wise status: AY Way Forward A.Y. 1993-94 As there is no litigation pending in relation to the amount allowed under Section 80 HHC by the Assessing Officer in its OGE, the deduction amount of Rs. 3,35,214 stands crystallized. No further action is required, and the matter is concluded Rs NIL A.Y. 1994-95 As there is no litigation pending in relation to the amount allowed under Section 80 HHC by the Assessing Officer in its OGE, the deduction amount of Rs. 4,10,761 stands crystallized. No further action is required, and the matter is concluded. Rs NIL A.Y. 1995-96 The Company has a negligible chance of success against the Hon’ble Bombay High Court order dated 04.08.2021, as the limitation period has lapsed. Accordingly, no further action is warranted. Rs NIL A.Y. 1997-98 The Company has a negligible chance of success against the Hon’ble Bombay High Court order dated 04.08.2021, as the limitation period has lapsed. Accordingly, no further action is warranted. Rs. 1,98,71,578 A.Y. 1998-99 Rs. 2,63,92,221 The Company has a negligible chance of success against the Hon’ble Bombay High Court order dated 04.08.2021, as the limitation period has lapsed. However, we note that the Hon’ble Supreme Court has dismissed Civil Appeal No. 4954/2013 filed by the Department on 30.01.2025 on grounds of monetary threshold. On the basis of the aforesaid development, the Company may prefer an application before the Assessing Officer to pass OGE with respect to AY 1998-99. However, the Assessing Officer is likely to reject the request of the Company by stating that OGE for AY 1998-99 has already been passed. A.Y. 1999-00 Rs. 3,37,12,929 The OGE for AY 1999-00 is still pending approval by the Department. As the issue concerning the computation of ‘profits of business’ is currently pending before the Hon’ble Supreme Court, we recommend that the Company file an appeal before the CIT (Appeals) if the Department reduces the deduction under Section 80HHC for AY 1999-00. In such a scenario, the CIT (Appeals) is likely to rely on the decision of the Hon’ble Bombay High Court and uphold the reduction. However, to save limitation and keep the matter open for further litigation, the Company should proceed with the appeal. The Company will challenge the OGE for AY 1999-00 if the Department reduces the deduction amount allowed under Section 80HHC of the Act. A.Y. 2000-01 The Company has a fair chance on merits. Thus, we shall proceed with the SLP filed before the Hon’ble Supreme Court. Rs. 57,53,281 The Company has a fair chance on merits. Thus, we shall proceed with the SLP filed before the Hon’ble Supreme Court. A.Y. 2001-02 Rs. 43,01,357 A.Y. 2002-03 The Company has incurred losses during the said period and has not applied for an OGE, no deduction under Section 80HHC is due to the Company. Accordingly, no further action is warranted. Rs. NIL A.Y. 2003-04 The Company has a fair chance on merits. Thus, we shall proceed with the SLP filed before the Hon’ble Supreme Court. Rs. 70,000 A.Y. 2004-05 As there is no litigation pending in relation to the amount allowed under Section 80 HHC by the Assessing Officer in its OGE, the deduction amount of Rs. 22,58,421 stands crystallized. No further action is required, and the matter is concluded. Rs. NIL Total Rs. 9,01,01,366/-Dy. Commissioner, Income Tax, Panaji.2018-12-23AY 2016-17 1) The Joint Commissioner of Income Tax, Range-I, Panaji has passed an Order dated 23.12.2018 for AY 2016-17 u/s 143(3), disallowing the following expenses: Exchange difference – Rs. 8,95,99,583/- (ii) Forward Premium Expenses – Rs. 5,50,394/- (iii) Guarantee Commission – Rs. 60,00,000/- (iv) Disallowance u/s 14A – Rs. 21,85,005/-. The Company had filed an Appeal against the Order with the C.I.T. (Appeals), Panaji on 29.12.2018. 2) After the hearings held in March 2019, the C.I.T. (Appeals) passed an Order on 29.03.2019, partly in favour of the Company i.e. The disallowance of Exchange difference, Forward Premium Expenses and Guarantee Commission of Rs.8,95,99,583/-, Rs. 5,50,394/- and Rs. 60,00,000/- respectively, were deleted. 3) The Joint Commissioner of Income Tax, Special Range, Panaji, filed an appeal against the order of the Commissioner of Income Tax (Appeals) dated March 29, 2019. At the hearing held on September 4, 2023, the matter was decided in favor of the company and remanded back to the Assessing Officer through the ITAT order dated September 20, 2023, for both AY 2013-14 and AY 2016-17. This remand was in accordance with the directions outlined in the ITAT order for AY 2011-12, allowing expenses after verifying the forward cover against which foreign exchange losses and forward cover expenses were incurred. 4) On 22nd July 2024, GCL received a letter from the Assessing Officer requesting its appearance to pass an order in line with the ITAT's directions. In response, GCL submitted the required documents for verification. Following the ITAT’s directions, the Assessing Officer issued an order on 28th October 2024, approving the forward premium expenses and exchange losses, and granting remaining refund of Rs. 62,760/- as the refund of Rs 46,85,830/- was already granted on 27th March 2018. The Company has received the said refund amounts. The only remaining issue is Guarantee Commission of Rs 60 Lacs. The Company has again submitted an application on 24th December 2024, to the AO to pass an Order Giving Effect to the CIT(A)'s decision dated March 29, 2019 for allowing Guarantee Commission. The Order giving effect is awaited.AY 2016-17 1) The Joint Commissioner of Income Tax, Range-I, Panaji has passed an Order dated 23.12.2018 for AY 2016-17 u/s 143(3), disallowing the following expenses: Exchange difference – Rs. 8,95,99,583/- (ii) Forward Premium Expenses – Rs. 5,50,394/- (iii) Guarantee Commission – Rs. 60,00,000/- (iv) Disallowance u/s 14A – Rs. 21,85,005/-. The Company had filed an Appeal against the Order with the C.I.T. (Appeals), Panaji on 29.12.2018. 2) After the hearings held in March 2019, the C.I.T. (Appeals) passed an Order on 29.03.2019, partly in favour of the Company i.e. The disallowance of Exchange difference, Forward Premium Expenses and Guarantee Commission of Rs.8,95,99,583/-, Rs. 5,50,394/- and Rs. 60,00,000/- respectively, were deleted. 3) The Joint Commissioner of Income Tax, Special Range, Panaji, filed an appeal against the order of the Commissioner of Income Tax (Appeals) dated March 29, 2019. At the hearing held on September 4, 2023, the matter was decided in favor of the company and remanded back to the Assessing Officer through the ITAT order dated September 20, 2023, for both AY 2013-14 and AY 2016-17. This remand was in accordance with the directions outlined in the ITAT order for AY 2011-12, allowing expenses after verifying the forward cover against which foreign exchange losses and forward cover expenses were incurred. 4) On 22nd July 2024, GCL received a letter from the Assessing Officer requesting its appearance to pass an order in line with the ITAT's directions. In response, GCL submitted the required documents for verification. Following the ITAT’s directions, the Assessing Officer issued an order on 28th October 2024, approving the forward premium expenses and exchange losses, and granting remaining refund of Rs. 62,760/- as the refund of Rs 46,85,830/- was already granted on 27th March 2018. The Company has received the said refund amounts. The only remaining issue is Guarantee Commission of Rs 60 Lacs. The Company has again submitted an application on 24th December 2024, to the AO to pass an Order Giving Effect to the CIT(A)'s decision dated March 29, 2019 for allowing Guarantee Commission. The Order giving effect is awaited.GCL v/s. Dy. Commissioner of Income Tax Panaji.2021-08-04AY 1995-96, 1997-98, 1998-99, 2000-01, 2001-02 & 2003-04 Pursuant to the Order passed by the Hon’ble High Court of Bombay at Goa in favour of the Company, the Asstt. Commissioner of Income Tax, Panaji while giving effect to the said Order has erred in restricting the claim of deduction of the Company under Section 80HHC of the Income Tax Act, 1961 as follows: i) To Rs. 34,84,383/- instead of Rs. 66,84,194/- for AY 1995-96; ii) To Rs. 9,42,853/- instead of Rs. 1,75,83,131/- for AY 1997-98 iii) To Rs. 3,02,51,863/- instead of Rs. 4,54,42,599/- for AY 1998-99 iv) To Rs. 2,61,82,642/- instead of Rs. 3,28,99,174/- for AY 2000-01 v) To Rs. 1,30,90,892/- instead of Rs. 2,00,28,130/- for AY 2001-02 To Rs. 65,99,005/- instead of Rs. 67,60,312/- for AY 2003-04 1) The Company has filed appeals with the Commissioner of Income Tax (Appeals), Panaji-Goa on 13.06.2011 & 23.11.2011. 2) The Commissioner of Income Tax (Appeals), Panaji-Goa has disposed off the Company’s appeals for the AY 1995-96, 1997-98, 1998-99, 2000-01, 2001-02 & 2003-04 against the Company, giving relief for expenditure. Appeals with the Income Tax Appellate Tribunal have been filed on 01.09.2016. 3) ITAT vide its order dated 23.11.2016 confirmed the order passed by CIT(A) in respect of AY 1995-96, 1997-98 & AY 1998-99 and vide order dated 17.08.2022 in respect of AY 2000-01, AY 2001-02 & AY 2003-04. 4) The Company’s appeals were admitted by the Hon’ble Bombay High Court of Panaji Bench for AY 1995-96, AY 1997-98 & AY 1998-99 in 2017 with Tax Appeal Nos. 146, 148 & 149 of 2017. 5) The above Tax appeals nos. 146,148 & 149 were decided against the Company vide order dated 11th August 2011. No further appeals were filed. 6) The Company’s appeals in respect of AY 2000-01, AY 2001-02 & AY 2003-04 in 2023 with Tax appeal Nos. 2, 4 & 5 of 2023. were admitted by the Hon’ble Bombay High Court of Panaji Bench in January 2023. 7) The above Tax appeals nos. 2, 4 & 5 have been decided against the Company vide order dated 31st July 2023. 8) The Company has filed the SLPs before the Supreme Court bearing Diary No. 45516/2023 (pertaining to TXA 2/2023) and Diary No. 45522/2023 (pertaining to TXA 4 & 5/2023) on 31.10.2023. Matter to be admitted and to be scheduled for hearing.AY 1995-96, 1997-98, 1998-99, 2000-01, 2001-02 & 2003-04 Pursuant to the Order passed by the Hon’ble High Court of Bombay at Goa in favour of the Company, the Asstt. Commissioner of Income Tax, Panaji while giving effect to the said Order has erred in restricting the claim of deduction of the Company under Section 80HHC of the Income Tax Act, 1961 as follows: i) To Rs. 34,84,383/- instead of Rs. 66,84,194/- for AY 1995-96; ii) To Rs. 9,42,853/- instead of Rs. 1,75,83,131/- for AY 1997-98 iii) To Rs. 3,02,51,863/- instead of Rs. 4,54,42,599/- for AY 1998-99 iv) To Rs. 2,61,82,642/- instead of Rs. 3,28,99,174/- for AY 2000-01 v) To Rs. 1,30,90,892/- instead of Rs. 2,00,28,130/- for AY 2001-02 vi) To Rs. 65,99,005/- instead of Rs. 67,60,312/- for AY 2003-04 1) The Company has filed appeals with the Commissioner of Income Tax (Appeals), Panaji-Goa on 13.06.2011 & 23.11.2011. 2) The Commissioner of Income Tax (Appeals), Panaji-Goa has disposed off the Company’s appeals for the AY 1995-96, 1997-98, 1998-99, 2000-01, 2001-02 & 2003-04 against the Company, giving relief for expenditure. Appeals with the Income Tax Appellate Tribunal have been filed on 01.09.2016. 3) ITAT vide its order dated 23.11.2016 confirmed the order passed by CIT(A) in respect of AY 1995-96, 1997-98 & AY 1998-99 and vide order dated 17.08.2022 in respect of AY 2000-01, AY 2001-02 & AY 2003-04. 4) The Company’s appeals were admitted by the Hon’ble Bombay High Court of Panaji Bench for AY 1995-96, AY 1997-98 & AY 1998-99 in 2017 with Tax Appeal Nos. 146, 148 & 149 of 2017. 5) The above Tax appeals nos. 146,148 & 149 were decided against the Company vide order dated 4th August 2021. No further appeals were filed. 6) The Company’s appeals in respect of AY 2000-01, AY 2001-02 & AY 2003-04 in 2023 with Tax appeal Nos. 2, 4 & 5 of 2023. were admitted by the Hon’ble Bombay High Court of Panaji Bench in January 2023. 7) The above Tax appeals nos. 2, 4 & 5 have been decided against the Company vide order dated 31st July 2023. 8) The Company has filed the SLPs before the Supreme Court bearing Diary No. 45516/2023 (pertaining to TXA 2/2023) and Diary No. 45522/2023 (pertaining to TXA 4 & 5/2023) on 31.10.2023. Matter to be admitted and to be scheduled for hearing.Assessing Officer (Faceless assessment scheme)2024-03-25AY 2022-23 The Assessing Officer under faceless assessment has passed an Order dated 25.03.2024 for AY 2022-23 u/s 143(3), disallowing the following expenses: (i)Sponsorship (Advertisement)– Rs. 1,43,00,000/- (ii) Difference in Exchange Loss – Rs 3,35,51,351/- (iii) Guarantee Commission – Rs. 83,89,808/- The Company had filed an Appeal against the Order with the C.I.T. (Appeals), on 15.04.2024. 1) The company filed appeals with the Commissioner of Income Tax (Appeals), Panaji-Goa, on April 15, 2024. 2) The company discussed with department and deposited 20% of the demand amount (Rs 35 Lacs) under protest to obtain a stay on penal proceedings under Section 270A of the Income Tax Act, 1961. 3) The Appeal is yet to be heard.AY 2022-23 The Assessing Officer under faceless assessment has passed an Order dated 25.03.2024 for AY 2022-23 u/s 143(3), disallowing the following expenses: (i)Sponsorship (Advertisement)– Rs. 1,43,00,000/- (ii) Difference in Exchange Loss – Rs 3,35,51,351/- (iii) Guarantee Commission – Rs. 83,89,808/- The Company had filed an Appeal against the Order with the C.I.T. (Appeals), on 15.04.2024. 1) The company filed appeals with the Commissioner of Income Tax (Appeals), Panaji-Goa, on April 15, 2024. 2) The company discussed with the department and deposited 20% of the demand amount (Rs 35 Lacs) under protest to obtain a stay on penal proceedings under Section 270A of the Income Tax Act, 1961. 3) The Appeal is yet to be heard.Assessing Officer (Faceless Assessment scheme)2025-03-19Matter not under dispute in previous quarterAY 2023-24 The Assessing Officer (Assessment Unit, Income Tax Department - under Faceless Assessment Scheme) has passed an assessment order bearing DIN ITBA/AST/S/143(3)/2024-25/1074691771(1) dated 19.03.2025 without proper service of the statutory show cause notice mandated under Section 144B of the IT Act, thereby denying the Company an opportunity to be heard and present its case. Assessing Officer assessed the taxable income of the Company for the said AY at Rs. 1,91,66,44,697/- as against the returned income at Rs. 1,12,01,42,778/- by: i) adding Rs. 74,00,00,000/- under Section 68 read with Section 115BBE of the Income Tax Act, 1961 (‘IT Act’) in respect of the unsecured loan availed from its promoter Mr. Shrinivas Dempo for meeting working capital requirement based on the conclusion of the AO that Mr Shrinivas Dempo does not have the credit worthiness to provide such unsecured loan to Goa Carbon Ltd and ii) disallowing expense amounting to Rs. 5,65,01,919/- under Section 37 of the IT Act in respect of the interest paid on the aforesaid loan to the lender of the unsecured loan Mr Shrinivas Dempo based on the conclusion made by the AO, that Mr Shrinivas Dempo has not offered entire interest income for taxability during the assessment year. Consequently, the Assessing Officer has raised total demand of Rs. 73,70,76,740/- vide Demand Notice bearing number ITBA/AST/S/156/2024- 25/1074691846(1) issued under Section 156 of the IT Act and initiated penalty proceedings against the Company under Section 270A and Section 271AAC(1) of the IT Act. The Company has filed a writ petition (bearing lodging number 928/2025) before the Hon’ble Bombay High Court, Goa Bench on 01.04.2025. Grounds in respect of violation of principles of natural justice The impugned assessment order has been passed by the Assessing Officer without proper service of the statutory show cause notice as required under Section 144B of the Income-tax Act, 1961. Consequently, the Company was denied a fair opportunity to be heard and to present its case. Despite having duly updated its primary and secondary email addresses on the Income Tax e-filing portal—an update that was duly acknowledged by the Income Tax Department—the statutory show cause notice was erroneously sent to the Company’s old & non-functional email addresses. This action is in contravention of the provisions of Section 282 of the Income-tax Act, 1961 read with Rule 127 of the Income-tax Rules, 1962. Further, the assessment order has disallowed interest expenditure amounting to Rs 5,65,01,919/- without any prior proposal or intimation in the show cause notice, thereby violating the principle of natural justice. The writ petition was last heard on April 22, 2025, and the Hon’ble Court has scheduled the next hearing for June 16, 2025. The Company has a strong case on merits. It is more than likely that the Hon’ble Bombay High Court will quash the assessment order and grant de novo hearing to the Company ie. reasonable opportunity would be granted to the company to suitably respond to the final show cause notice and to convince the AO that Mr Shrinivas Dempo has credit worthiness to lend unsecured loan of Rs. 74 crores to Goa Carbon Ltd. Even in the event of an unfavourable outcome before the Hon’ble High Court, the Company has the remedy to file an alternative appeal against the assessment order.