आदेश/ORDER

PER PRABHASH SHANKAR [A.M.] :-

The above captioned appeals have been preferred by the Revenue against the orders of even date passed by the Learned Commissioner of Income-tax, Appeal, CIT(A) 52, Mumbai [hereinafter referred to as “CIT(A)”] pertaining to the order passed u/s. 143(3) r.w.s. 254 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for the Assessment Years [A.Y.] 2013-14 and 2014-15. Since the issue involved is common, these appeals are being taken up together for adjudication vide this composite order for the sake of brevity. ITA No.3494/Mum/2025 for AY 2013-14 is taken up as the ‘Lead case’. Decision herein would apply mutatis mutandis to the other appeal.

2. The grounds of appeal are as under:-

ITA No.3494/MUM/2025(AY 2013-14)

1. “On the facts and in the circumstances of the case and in law, Ld.CIT(A) erred in directing the AO to delete the addition made u/s 36(1) (iii) of Rs.2,23,93,835/-without properly appreciating the facts that assessee company failed to prove that interest expenses claimed have been utilized wholly and exclusively for its business purpose?

2. “On the facts and in the circumstance of the case and in law the Ld. CIT(A) erred in r