IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1908/MUM/2018 Assessment Year: 2013-14 Assistant Commissioner of Bhandar Power Ltd.

Income Tax, 14th Floor, Essar House, Circle 6(1)(2), 11, K. K. Marg, Mahalaxmi, Vs.

Mumbai Mumbai - 400034 (PAN: AAACB6693B)

(Appellant) (Respondent)

Present for:

Assessee : Shri Vijay Mehta, FCA and Shri Tarang Mehta, Advocate Revenue : Shri Satyaprakash R. Singh, CIT DR Date of Hearing : 29.07.2025 Date of Pronouncement : 13.10.2025

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the Revenue is against the order of Ld. CIT(A), Delhi, vide order dated 25.01.2018 passed against the assessment order by ITO 6(1)(4), Mumbai, u/s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 20.12.2016, for Assessment Year 2013-14.

2. Grounds taken by the Revenue are reproduced as under:

1. On the facts and in the circumstances of the case and in law, the CIT(A) is not justified in deleting the disallowance of deduction u/s 80IA of the Income Tax Act of Rs. 203,13,43,740/-without considering the fact that the provisions of secti