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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Satbeer Singh Godara, Judicial Member, Manish Agarwal, Accountant Member
Income Tax Officer – Appellant
Versus
DLF Info City Developers Kolkata Limited – Respondent
| Table of Content |
|---|
| 1. revenue appeals against cit(a) orders on reopening u/s 147. (Para 1 , 2) |
| 2. dispute over interest expense deduction eligibility u/s 80ia. (Para 3) |
| 3. ao reopens assessment treating interest as other sources income. (Para 4) |
ORDER
PER SATBEER SINGH GODARA, JM
These Revenue’s five appeals ITA Nos. 2926, 2927, 2928, 2929 & 2930/Del/2024 for assessment years 2013-14 to 2017-18, are directed against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, all dated 13.12.2023, having DIN and order nos. ITBA/NFAC/S/250/2023-24/1058723162(1); ITBA/NFAC/S/250/2023-24/1058723640(1); ITBA/NFAC/S/ 250/2023-24/1058724011(1); ITBA/NFAC/S/250/2023-24/ 1058724386(1) and ITBA/NFAC/S/250/2023-24/1058724846(1), involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively.
2. Heard both the parties. Case files perused.
3. The Revenue’s “lead” appeal ITA No. 2926/Del/2024 raises the following substantive grounds:
“"Whether on the facts and circumstances of the case and law, because the decision of the Ld. CIT(A)'s order regarding claim of Bank's Loan Interest
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