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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Narendra Kumar Billatya, AM, Saktijit Dey, VP
Sabarmati Capital One Limited – Appellant
Versus
Deputy Commissioner of Income Tax - 14(1)(2), Mumbai – Respondent
| Table of Content |
|---|
| 1. taxable income from house property. (Para 3 , 5) |
| 2. jurisdiction and application of income tax on unsold inventory. (Para 7 , 8 , 10) |
| 3. limitations on assessing officer's jurisdiction under section 263. (Para 9 , 11) |
| 4. final ruling on appeals. (Para 14) |
आदेश/ORDER
PER NARENDRA KUMAR BILLATYA, AM:
I.T.A. No. 3633 /Mum/2024 & LT.A. No. 3687 /Mum/2024 are cross-appeals by the assessee and the revenue preferred against the order dated 14/08/2023 by NFAC, Delhi [hereinafter ‘the 1d. CIT(A)’] pertaining to AY 2015-16.
2. These cross-appeals were heard together and are disposed off by this common order for the sake of convenience and brevity.
3. The sum and substance of the grievance of the assessee is that the Id. CIT(A) erred in confirming the addition of Rs. 10,59,48,467/- under the head income from house property as per Section 22 of the Act.
4. Representatives were heard at length. Case records carefully perused and the judicial decisions relied upon by the representatives duly considered.
5. Briefly stated, the facts of the case are that the assessee company is engaged in real-estate business. The return for the year under consideration was filed on 29/09/2015, disclosi
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