ORDER

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These captioned appeals filed by the Revenue and assessee are against the orders of CIT(A) / National Faceless Appeal Centre (NFAC), Delhi, vide order nos.-

i. ITBA/NFAC/S/250/2025-26/1078104301(1), dated, 02.07.2025, passed against the assessment order by Income- tax Officer (E)-1(1). Mumbai, u/s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 31.03.2016, for Assessment Year 2013-14.

ii. ITBA/NFAC/S/250/2025-26/1078306290(1), dated, 08.07.2025 passed against the assessment order by Deputy Commissioner of Income-tax (Exem.)-I(1), Mumbai, u/s. 143(3) of the Act, dated 23.12.2016, for Assessment Year 2014-15.

iii. ITBA/NFAC/S/250/2025-26/1080751796(1), dated, 15.09.2025, passed against the assessment order by Income- tax Officer (Exem.)-1(1), Mumbai, u/s. 143(3) of the Act, dated 25.12.2017, for Assessment Year 2015-16.

2. The present set of four appeals comprises of three appeals by the Revenue and one by the assessee. Issues raised by the Revenue in these appeals are common except for variation in the quantum under consideration. Owing to such commonality, we take up the entire set of four appeals together for adjudication by passing this consolidated order. The common issues raised in the appeals by the Revenue with their respective ground numbers are tabulated below:

3. Brief facts of the case are that assessee was settled by the Deed of Trust, dated 23.09.1994 with charitable objects inter alia, of giving medical relief to the poor. Assessee is registered u/s. 12A of the Act with Registration No. TR-30884, dt. 28.12.1994. Assessee is also registered with the Charity Commissioner as a charitable trust under the Maharashtra Public Trust Act, 1950.

3.1. Assessee had acquired 16 acres of land in Pune and constructed hospital complex consisting of hospital building including the service structure and staff quarter as per the plan sanctioned by the Pimpri- Chinchwad Municipal Corporation. As the assessee did not have the necessary expertize to maintain, administer and run the full-fledged hospital, it decided to lease out the hospital building to another entity for management, administration and maintenance of the hospital. Accordingly, assessee initially entered in to a Memorandum of Understanding dated 30.03.2005 for proposing to grant lease of 29 years lease to Aditya Birla Health Services Ltd. (ABHSL) of the said property, subject to approval of Charity Commissioner as mandatorily required under section 36(1) of the Maharashtra Public Trust Act, 1950. As per clause (5) of the MOU, the proposed lessee was required to pay the lease rental at Rs. 4.10/- per sq. ft. per month for the built-up area of the hospital building and Rs.3.00 per sq. ft. per month for the built- up area of staff housing building. It further provided that the lease rent shall be increased by at least 5% after every block of 5 years or by such further amount as may be mutually agreed between the parties.

4. Broadly, there are only two issues which needs to be adjudicated upon in the three appeals by the Revenue, one relating to claim of exemption u/s.11 which has been denied on account of violation of provisions of section 13(1)(c) r.w.s. 13(2)(a) and (b) and section 13(1)(3) of the Act along with its consequential effects and second relating to taxing interest income on accrual basis as against stance of the assessee to be taxed on receipt basis.

4.1. Ld. Counsel for the assessee at the outset put forth that both these issues are squarely covered by the decisions of Coordinate Benches in assessee’s own case for Assessment Year 2011-12, 2012-13, 2016-17 and 2017-18, there being no change in material facts and relevant law. The decisions of Coordinate Benches for the aforesaid four Assessment Years in assessee’s own case which covers both the issues contested by the Revenue before us are listed as under:

i. DCIT(E)-1(1) v. Aditya Birla Foundation (A.Y. 2011-12) in ITA 4065/Mum/2019, dated 16