Eastern Coalfield Limited.....................................Respondent [PAN: AAACE 7590 E] Appearances by: Sh. Praveen Kishore, CIT, appeared on behalf of the Revenue. Sh. Arvind Agarwal, Adv., appeared on behalf of the Assessee. Date of concluding the hearing : April 27th, 2022 Date of pronouncing the order : July 19th, 2022 ORDER Per Manish Borad, Accountant Member: The captioned appeals filed by the Revenue pertaining to the Assessment Years (in short "AY") 201011 & 201112 are directed against the common order passed u/s 250 of the Income Tax Act, 1961 (in short the "Act") of ld. Commissioner of Incometax (Appeals), Asansol [in short ld. "CIT(A)"] dated 14.02.2020 arising out of separate assessment orders framed u/s 147/143(3) of the Act. 2. Registry has informed that both the appeals are time barred by 245 days. Condonation applications have been filed by the I.T.A. Nos.: 634 & 635/Kol/2020 Assessment Years: 201011 & 201112 Eastern Coalfield Limited. Revenue. Perusal of the same shows that the delay was on account of COVID19 restrictions. We, therefore, in view of the judgment of The Hon'ble Supreme Court vide Miscellaneous Application No. 21 of 2022 find that the limitation period in filing appeal between 15.03.2020 till 28.02.2022 has been excluded for calculating the limitation period in filing appeal under this period. Since the period of limitation in this case falls during this period, the same deserves to be extended and we, therefore, condone the delay of 245 days and admit the Revenue's appeals for adjudication. 3. Brief facts of the case are that the assessee is a subsidiary of Coal India Ltd. Its main business is raising coal and selling it as per the guidelines issued by the Ministry of Coal from time to time. Assessment under Section 147 r.w.s. 143(3) of the Act for assessment years 201011 & 201112 was completed on 30.11.2015 after making various additions. The additions made by the Assessing Officer were challenged by the assessee before learned CIT(A) and appeal of the assessee was partly allowed. 4. Now, the Revenue is in appeal for assessment years 201011 & 201112 raising the following grounds of appeal: Assessment Year 201011: "1. Whether on the facts and circumstances and in law, the Ld. CIT(A) had erred in deleting the PRP of Rs. 29,97,00,000/ by holding that the said amount is not recoverable advances or loans, without corroborating the office memorandum issued by the Coal India Limited on 15.11.2011. 2. Whether on the facts and circumstances of the case and law, the Ld. CIT(A) is justified in deleting the difference in closing and opening value of nonvendible coal of Rs. 25,73,000/ by holding that the same is unverifiable whereas as per accountancy principle the Page 2 of 28 I.T.A. Nos.: 634 & 635/Kol/2020 Assessment Years: 201011 & 201112 Eastern Coalfield Limited. valuation of the same quantum of nonvendible coal cannot be different in opening & closing stock without any valid reason. 3. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting Stowing subsidy amounting to Rs. 1,43,41,000/ by holding that the amount of addition relates to the last year's subsidy receivable. 4. Whether on the facts and circumstances of the case and in law, the Ld. C1T(A) is justified in allowing 80% of additional depreciation of Rs. 7,85,50,480/ claimed u/s 32(1)(iia) of the I. T. Act, whereas the assessee company not only failed to produce the detailed breakup of assets but also failed to justify the admissibility of additional depreciation on assets as required u/s 32(1)(iia) of the I.T. Act. 5. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in allowing 80% of additional depreciation of Rs. 7,85,50,480/ claimed u/s 32(1)(iia) of the I.T. Act, whereas the assessee company is n