Appeal partly allowed, issues restored for reconsideration. Disallowances upheld, actions directed.

The appeal was partly allowed for statistical purposes, with specific issues restored to the AO for reconsideration and verification. The Tribunal upheld several disallowances and directed appropriate actions based on precedents and judicial pronouncements.

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Issues Involved:
1. Disallowance of Prospecting & Boring expenses.
2. Disallowance of Development expenditure.
3. Disallowance of capital expenditure on assets not belonging to the company.
4. Disallowance on reclamation of land.
5. Reversal of interest on income tax refund as expenditure.
6. Addition on account of donation and subscription.
7. Addition on account of deterioration of stock and re-handling of coal.
8. Addition on account of reduction in value of stores due to obsolescence and shortage of stores.
9. Addition on account of loss on sale/discard of assets.
10. Short credit of TDS.
11. Depreciation on leasehold rights of coal-bearing land as an intangible asset.

Detailed Analysis:

1. Disallowance of Prospecting & Boring Expenses:
The assessee claimed Rs. 448.53 lakhs as prospecting & boring expenses, which the Assessing Officer (AO) allowed only 10% of, following the precedent of earlier years. The CIT(A) confirmed this, and the Tribunal upheld the order, dismissing the assessee's ground as there was no change in facts.

2. Disallowance of Development Expenditure:
The AO disallowed Rs. 49.32 lakhs out of Rs. 1244.27 lakhs claimed as development expenditure, allowing only depreciation. The CIT(A) confirmed this disallowance, and the Tribunal, following its earlier decision, dismissed the assessee's appeal.

3. Disallowance of Capital Expenditure on Assets Not Belonging to the Company:
This ground was not pressed by the assessee during the hearing and was dismissed.

4. Disallowance on Reclamation of Land:
The AO disallowed Rs. 858.94 lakhs claimed as a provision for reclamation of land, as it was a provision for future expenditure. The CIT(A) upheld this disallowance, citing the Supreme Court's decision in Indian Molasses Co. Pvt Ltd vs CIT. The Tribunal restored the issue to the AO for verification of whether the provision was offered for taxation in subsequent years.

5. Reversal of Interest on Income Tax Refund as Expenditure:
This issue was not pressed by the assessee and was dismissed.

6. Addition on Account of Donation and Subscription:
The AO disallowed Rs. 5.25 lakhs claimed as donation & subscription due to lack of evidence. The CIT(A) directed the AO to allow such expenditure where the assessee could establish its relation to the business and allow deductions under Section 80G upon submission of evidence. The Tribunal directed the AO to allow the deduction of Rs. 5.25 lakhs.

7. Addition on Account of Deterioration of Stock and Re-handling of Coal:
The AO disallowed Rs. 384.30 lakhs due to the absence of technical reports or evidence. The CIT(A) directed reconsideration based on technical support or evidence. The Tribunal upheld this directive for reconsideration.

8. Addition on Account of Reduction in Value of Stores Due to Obsolescence and Shortage of Stores:
The AO disallowed Rs. 130.09 lakhs claimed for obsolescence of stores. The CIT(A) upheld this disallowance. The Tribunal restored the issue to the AO for fresh consideration in light of details furnished by the assessee.

9. Addition on Account of Loss on Sale/Discard of Assets:
The AO disallowed depreciation of Rs. 110.09 lakhs on loss from sale/discard of assets. The CIT(A) directed the AO to verify the correctness of the claim. The Tribunal found no infirmity in this directive and dismissed the assessee's ground.

10. Short Credit of TDS:
The AO did not allow credit for TDS while processing the return. The CIT(A) held that credit should be allowed based on original TDS certificates. The Tribunal confirmed this order.

11. Depreciation on Leasehold Rights of Coal-bearing Land as an Intangible Asset:
The Tribunal dismissed the assessee's additional grounds regarding depreciation on leasehold rights, following judicial pronouncements that such rights are not eligible for depreciation under Section 32(1)(ii).

Conclusion:
The appeal was partly allowed for statistical purposes, with specific issues restored to the AO for reconsideration and verification. The Tribunal upheld several disallowances and directed appropriate actions based on precedents and judicial pronouncements.

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