IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI ARUN KHODPIA, ACCOUNTANT MEMBER (Assessment Year :2020-21 Rohan Landscape Vs. The Principal Private Limited Commissioner of 11^th Floor, Tower 2A Income Tax, Mumbai-8 One World Center Senapati Bapat Marg Mumbai – 400 013 PAN/GIR No.AAECR5961N (Appellant) .. (Respondent Assessee by Shri Dhanesh Bafna; Shri Hardik Nirmal & Ms.Hinal Shah Revenue by Shri Umashankar Prasad, CIT DR Date of Hearing 17/12/2025 Date of Pronouncement 10 /02/2026 / O R D E R आदेश PER AMIT SHUKLA (J.M):

The aforesaid appeal has been filed by the assessee against order dated 21/03/2025 passed by PCIT, Mumbai – 8 in revisionary jurisdiction u/s.263 for the A.Y.2020-21.

2. The assessee, Rohan Landscape Private Limited, is a company engaged in the business of developing, operating and leasing modern industrial real estate and logistics and warehousing facilities. Its business model, as consistently explained on record, involves acquisition of land, development and construction of warehousing infrastructure, completion of projects, and thereafter monetisation through long-term lease arrangements. During the previous