आयकर अपीलीय अिधकरण (cid:586)ाय पीठ मुंबई म(cid:336)।

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JM &

SHRI ARUN KHODPIA, AM I.T.A. No. 2117/Mum/2025 (Assessment Year: 2014-15) I.T.A. No. 2118/Mum/2025 (Assessment Year: 2015-16) I.T.A. No. 2170/Mum/2025 (Assessment Year: 2016-17) I.T.A. No. 2171/Mum/2025 (Assessment Year: 2018-19) I.T.A. No. 2172/Mum/2025 (Assessment Year: 2019-20)

DCIT, CC-8(2), Abhinand Ventures Private Ltd. Room No. 658, 6^th Floor, (Earlier known as Balaji Trust), Aayakar Bhavan, M.K. Road, , V s . 1 1 , E ssar House, KK Marg, Mumbai-400020. Mahalaxmi, Mumbai - 400034 PAN: AACTB0950C Revenue -अपीलाथ(cid:334) / Appellant Assessee - (cid:366)(cid:529)थ(cid:334) / Respondent :

C. O. No. 110/Mum/2025 in I.T.A. No. 2170/Mum/2025 (Assessment Year: 2016-17)

Abhinand Ventures Private Ltd. DCIT, CC-8(2), (Transferee of dissolved Balaji Room No. 260A, 2^nd Floor, Trust), Aayakar Bhavan, M.K. Road, , Vs.

11, Essar House, KK Marg, Mumbai-400020.

Mahalaxmi, Mumbai - 400034 PAN: AACTB0950C Assessee -अपीलाथ(cid:334) / Appellant Revenue - (cid:366)(cid:529)थ(cid:334) / Respondent :

Assessee by : Shri Vijay Mehta, & Shri Narendra Baheti, AR Revenue by : Shri Biswanath Das-CIT-DR &

Shri Leyaqat Ali Aafaqui, Sr. DR Date of Hearing : 07.01.2026 Date of Pronouncement : 28.01.2026 O R D E R Per Arun Khodpia, AM:

The aforesaid appeals are filed by the revenue challenging the respective orders of Ld. Commissioner of Income Tax (Appeals)-50, Mumbai (for short “The Ld. CIT(A)”), for the Assessment Years (AY) 2014-15, 2015-16, 2016-

17, 2018-19 & 2019-20 and C.O by the assessee for the AY 2016-17.

2. All the aforesaid appeals of the revenue and the Cross Objection (C.O.) of the assessee are directed to assail the common issues under parallel grounds of appeal, having identical, interconnected and interwoven facts and circumstances qua the additions / disallowances made (except the quantum involved therein), thus, for the sake of concision, as agreed by the parties herein, it is deemed appropriate to perceive all the captioned Appeals/CO collectively and to adjudicate under this common order.

3. To decide the common issues raised in aforesaid appeals/CO, ITA No. 2117/Mum/2025 for AY 2014-15 has been taken up as the lead case, wherein, the discussion, observations and our adjudication on the identical issues shall apply mutatis mutandis to the remaining appeals, as well. If there is any new issue, which does not fall within the compass of common grounds, that shall be dealt with separately under the respective appeals.

4. The grounds of in ITA No. 2117/Mum/2025 for appeal for AY 2014-15 are culled out as under:

“1. "Whether on the facts and circumstances of the case, the Learned CITIA) erred in deleting the addition made on account of disallowance of branding expenses of Rs. 1,99,00,000/- by treating the payment made by the assessee- Trust to its associate concern as relating to business expenses without appreciating the facts as discussed in the assessment order by the AOP "2. Whether on the facts and circumstances of the case, the Learned CIT(A) erred in deleting the addition made on account of disallowance of legal fees of Rs. 89,18,266/- by treating these expenses as revenue expenditure instead of capital expenditure?

"3. Whether on the facts and circumstances of the case, the Learned CIT(A) was right in upholding that cash system of accounting followed by the assessee in contravention of accounting standard AS-9 is correct?

4. The appellant prays that the order of the CIT(A) on the above ground be set aside and that of the Assessing Officer be restored.”

5. Concisely stated, the assessee “Abhinand Ventures Pvt. Ltd. (for an on behalf of Balaji Trust, now dissolved)” has filed its return of income (ROI) for AY 2014-15 on 30.03.2016, declaring total income at Rs. 95,30,01,340/-. The case of assessee was selected for scrutiny; accordingly, statutory notices were issued, wherein various issues were raised by ld. AO, wh