IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Assessment year : 2013-14 DCIT (Exemption) Dr D Y Patil Unitech Society Circle, Pune Flat No.101, Shree Motisagar Vs.

Apartment, G G Thakkar Road, S No.173A, Pune – 411001 PAN: AABTD1482A (Appellant) (Respondent)

Assessee by : Shri Nikhil S Pathak Department by : Shri Amol Khairnar, CIT-DR Date of hearing : 27-10-2025 Date of pronouncement : 04-11-2025

O R D E R

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated

06.03.2025 of the Ld. Addl / JCIT(A)-3, Delhi relating to assessment year 2013-

14.

2. Facts of the case, in brief, are that the assessee is a trust primarily engaged in educational activities. It is also engaged in providing medical ayurvedic services. It filed its return of income on 30.09.2014 declaring total loss at Rs.10,87,42,880/-. The Assessing Officer completed the assessment u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) on 03.03.2015 assessing the total income at Rs.7,04,69,855/- after making disallowance of depreciation amounting to Rs.4,50,27,084/-.

3. Subsequently,