आदेश / O R D E R

PER AMIT SHUKLA (J.M):

The aforesaid batch of appeals has been preferred by the Revenue against separate impugned orders passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, dated 21.10.2025 and 22.10.2025 for Assessment Years 2013-14, 2014-15, 2015-16 and 2017-18 respectively. Since common issues are involved in all these appeals arising out of an identical factual matrix and involving substantially similar additions/disallowances, all these appeals were heard together and are being disposed of by way of this consolidated order for the sake of convenience, consistency and brevity. Assessment Year 2013-14 has been taken as the lead year and the findings rendered therein shall apply mutatis mutandis to the remaining assessment years also.

The Revenue in the present batch of appeals has challenged the action of the learned CIT(A) in deleting the additions/disallowances made by the Assessing Officer on three common issues, namely, firstly, determination of enhanced Annual Letting Value under section 23(1)(a); secondly, disallowance of interest expenditure relatable to borrowed funds utilized for acquisition of commercial properties; and thirdly, disallowance made under section 14A read with Rule 8D despite the admitted position that no exempt income had been earned by the assessee during the relevant years. The issue-wise additions involved in the respective years are reproduced herein below:

(i) Assessment Year 2013-14 – Addition on account of ALV of Rs.1,08,92,616/-, disallowance of interest expenditure of Rs.1,23,60,853/- and disallowance under section 14A of Rs.16,79,804/-;

(ii) Assessment Year 2014-15 – Addition on account of ALV of Rs.1,08,92,616/-, disallowance of interest expenditure of Rs.1,80,95,099/- and disallowance under section 14A of Rs.13,97,249/-;

(iii) Assessment Year 2015-16 – Addition on account of ALV of Rs.1,43,19,062/-, disallowance of interest expenditure of Rs.1,39,25,014/- and disallowance under section 14A of Rs.62,11,813/-; and

(iv) Assessment Year 2017-18 – Addition on account of ALV of Rs.1,27,72,301/-, disallowance of interest expenditure of Rs.69,77,361/- and disallowance under section 14A of Rs.10,00,000/-.

Briefly stated, the facts borne out from the records are that the assessee company is primarily engaged in the business of leasing and exploitation of commercial premises and deriving income from letting out commercial properties on leave and license basis along with provision of allied commercial facilities and amenities to tenants occupying such premises.

The assessee had entered into separate agreements with tenants, namely, one agreement towards lease/license fees for the bare-shell commercial premises and another agreement for provision of amenities and commercial facilities such as centralized HVAC systems, common area maintenance, power backup infrastructure, security services, escalators and other related facilities.

For Assessment Year 2013-14, the assessee filed its return of income declaring loss of Rs.71,15,701/-. The case was selected for scrutiny and assessment under section 143(3) was completed wherein the Assessing Officer assessed the total income at Rs.1,86,48,325/- after making three major additions/disallowances. Firstly, the Assessing Officer rejected the actual rent declared by the assessee and proceeded to determine the Annual Letting Value on the basis of estimated market rent by holding that bifurcation of receipts between rent and amenities charges constituted a device to suppress taxable ALV. Secondly, the Assessing Officer disallowed the interest expenditure incurred on borrowed funds utilized for acquisition of commercial properties by alleging that the assessee had failed to establish that the borrowings were utilized wholly and exclusively for business purposes and also failed to establish direct nexus between borrowed funds and acquisition of property. Thirdly, the Assessing Officer invoked section 14A read