IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Years : 2016-17 &

2017-18 M/s. Karnataka Industrial Areas The Deputy Development Board, Commissioner of No. 49, 4th & 5th Floors, Income Tax, Khanija Bhavan, Exemptions Circle – 1, Race Course Road, Vs. Bangalore.

Bangalore – 560 001.

PAN: AAATK1305J APPELLANT RESPONDENT Assessee by : Shri Sudheendra B.R, Advocate Revenue by : Shri Shivanand H Kalakeri, CIT-DR Date of Hearing : 02-12-2025 Date of Pronouncement : 02-03-2026

ORDER

PER SOUNDARARAJAN K., JUDICIAL MEMBER These two appeals are filed against the separate orders of the NFAC, Delhi both dated 14/02/2024 in respect of the A.Ys. 2016-17 and 2017-18. The assessee being the same and also the issues involved in the appeals are almost similar, the appeals are heard together for the sake of convenience and a common order has been passed. The facts in the A.Y. 2016-17 has been taken and the said appeal is taken as the lead case and the decision arrived in the said appeal would apply automatically to the appeal in respect of A.Y. 2017-18 mutatis mutandis. The grounds raised in resp