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IN THE INCOME TAX APPELLATE TRIBUNAL

DELHI BENCH ‘E’: NEW DELHI

BEFORE SHRI SUDHIR K UMAR, JUDICIAL MEMBER

AND

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER

ITA No.64/Del/2019

(ASSESSMENT YEAR 2014-15)

ITA No.3714/Del/2024

(ASSESSMENT YEAR 2015-16)

ITA No.255/Del/2020

(ASSESSMENT YEAR 2016-17)

Dy. Commissioner of

Lifestyle and Media Holding

Income Tax,

Limited (formerly known as NDTV

Vs. C.R. Building,

Lifestyle Holdings Limited)

New Delhi.

Plot No.09, Unit No. 055, Ground

Floor Capia, Corporate Suites,

Jasola, New Delhi-110025.

PAN-AADCN3076F

(Appellant) (Respondent)

Assessee by Shri R.P. Mall, Adv.

Department by Ms. Ankush Kalra, Sr. DR

Date of Hearing 29/10/2025

Date of Pronouncement 31/12/2025

O R D E R

[

PER BENCH:

All the captioned appeals filed by the assessee against the separate orders

passed by Learned Commissioner of Income Tax (Appeals)-6, Delhi [ld. CIT(A)]

for AY 2014-15 to 1016017 and having common issues, therefore, they are dispose-

off by a common order. First, we taken assessee appeal for Ay 2014-15 in ITA No.

64/Del/2019.

2 ITA No.64 /Del/2019,

ITA No.3714/Del/2024 &

ITA No.255/Del/2020

Lifestyle and Media Holdings Limited vs. DCI

ITA No.64/Del/2019 for Assessment Year 2014-15

2. This appeal is filed by the assessee against the order passed by Learned

Commissioner of Income Tax (Appeals)-6, Delhi in appeal No. CIT(A), Delhi-

6/10347/2017-18, dated 17.10.2018 arising out of the order passed u/s 143(3) dated

13.08.2016 for Assessment Year 2014-15.

3. Briefly stated that the facts of the case are that assessee is a holding company

of various group of companies and filed his return of income on 20.09.2014

declaring total income at Rs.11,13,99,400/-. The case of the assessee was selected

for scrutiny under CASS and after considering the submission made from time to

time in response to the quarries raised, the assessment order was passed dated

31.08.2016 wherein the business expenses claimed at Rs. 1,30,69,038/- were

disallowed by holding that the assessee has not carried out at any business activity,

therefore, expenses could not be allowed and further denied the set off of the same

against the income declared under other heads of income.

4. Against the said order, assessee preferred an appeal before Ld. CIT(A) who

vide impugned order dated 17.10.2018 confirmed the findings given by AO and

dismissed the appeal of the assessee.

5. Aggrieved by the said order, the assessee is in appeal before the Tribunal by

taking the following grounds of appeal:

1. That on facts and in circumstances of the case and law, the assessment order

dated 31.08.2016 passed by the Ld. Assessing Officer ("Ld. AO") under section

143(3) of the Income Tax Act, 1961 ("the Act") is bad in law.

2. That on the facts and circumstances of the case and in law, the Ld. AO erred in

disallowing the business expenses amounting to Rs. 1,30,69,038/-incurred by the

3 ITA No.64 /Del/2019,

ITA No.3714/Del/2024 &

ITA No.255/Del/2020

Lifestyle and Media Holdings Limited vs. DCI

appellant during the year under consideration. The Hon'ble Commissioner of

Income Tax Appeals too has erred in this regard by affirming the disallowance

made by Ld. AO.

2.1 That on the facts and circumstances of the case Nil for and in law, the Ld. AO

has erred in contending that activities of holding investments do not qualify f

business as defined in section 2(13) of the Act. Further the Hon'ble CIT(A) too

has erred in affirming the view of the Ld. AO

2.2 That on the facts and circumstances of the case and in law, the Hon'ble CIT(A)

has erred in ignoring the contention of the appellant that the appellant company

being artificial person requires some administrative and clerical staff to run

itself, resulting into some operational expenses and will have to incur expenses

for statutory compliance & obligation, irrespective of any income in nature of

business, as defined u/s 2(13) of the Act and in law, the Ld. AO erred in not

allowing the set-off of business losses of Rs 1,30,69,038 against the interest

income u/s 71 of the Act. The Hon'ble