THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Sl.No. ITA No. AY Name of Name of Appellant Respondent

1. 713/Del/2024 2019-20 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi-

110001 PAN-AAACD3494N

2. 714/Del/2024 2020-21 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi-

110001 PAN-AAACD3494N

3. 715/Del/2024 2021-22 DCIT, DLF Limited [Revenue’s Circle-7(1) 9th Floor, DLF appeal] Delhi-110002 Centre, Sansad Marg H.O.Sansad Marg, New Delhi-

110001 PAN-AAACD3494N

4. 676/Del/2024 2020-21 DLF Limited National Faceless [Assessee’s 9th Floor, DLF Assessment Centre, appeal] Centre, Sansad Delhi Marg New Delhi-110001 PAN-

AAACD3494N

5. 677/Del/2024 2021-22 DLF Limited National Faceless [Assessee’s 9th Floor, DLF Assessment Centre, appeal] Centre, Sansad Delhi Marg New Delhi-110001 PAN-

AAACD3494N Assessee by Shri Vijay Mehta, CA Revenue by Ms. Pooja Swaroop, CIT DR &

Shri Rajesh Kumar Dhanesta, Sr. D.R.

Date of hearing: 04.08.2025 Date of Pronouncement: 30.10.2025 ORDER PER MANISH AGARWAL, AM :

The captioned appeals are filed by the Assessee and by the Revenue in case of captioned assessee for Assessment years 2019-

20, 2020-21 and 2021-22.

2. Since the issues involved in all these cross appeals filed by both the parties are common therefore, all these cross appeals are taken together and decided through a common order.

ITA No.713/Del/2024 (AY 2019-20) M/s DLF Ltd

3. We first take the appeal filed by the Revenue in ITA No.

713/Del/2024 for AY 2019-20.

4. Brief facts of the case are that the assessee was incorporated under the Companies Act, 1956 and since inception is engaged in the business of real estate development including working in the field of colonization and township developments in and around Delhi NCR besides projects spread across India. The assessee e-filed its return of income on 31.10.2019 declaring loss of Rs.

55,33,78,55,356/-. The return of income was subsequently revised on 30.09.2020 at a loss of Rs.55,33,78,55,356/-. The case of assessee was selected for complete scrutiny and notice u/s 143(2) was issued on 31.3.2019 followed by the notices issued u/s 142(1) asking the assessee to file various details which were duly replied. Thereafter, the Assessment order was passed on 30.9.2021 u/s 143(3) r.w.s. 144B of the Act wherein following additions/

disallowances were made:-

1. Disallowance of adjustment claimed towards one-time Adoption of Indian Accounting Standard (Ind-AS') 115:

Rs.50,49,59,76,000/-

2. Disallowance of delayed payment of employee contribution to PF Rs. 53,74,605/-

3. Disallowance u/s 14A read with Rule 8D of Rs.

98,99,04,701/-

4. Reclassification of Income from house property Rs.

22,33,67,403/-

5. Disallowance out of Aircraft and Helicopter expenses Rs.

3,17,34,000/-

5. Besides the AO while computing the total income at page 50 of its order inadvertently taken the loss at Rs. 55,32,91,87,098/- as against the correct returned loss of Rs. 55,33,78,55,356/-, thereby ignoring the Long-term capital loss amounting to Rs. 86,68,259/-.

6. Against such order, assessee preferred an appeal before the ld. CIT(A) who vide impugned order, allowed part relief to the assessee, wherein the ld. CIT(A) has deleted major additions/disallowance by following the orders of coordinate bench of Tribunal in the case of the assessee itself for earlier assessment years.

7. Aggrieved by the said order, the revenue is in appeal before the Tribunal by taking following grounds of appeal:

1. “Whether on the facts & circumstances of the case and in law, the Ld. NFAC has erred in allowing the Principal claim of deduction of Rs. 6,09,185.90 lacs ignoring that the assessee had to follow consistency in method of accounting i.e. POCM for the year under consideration and accordingly, the AO has rightly rejected the change i