INCOME TAX OFFICER WARD 5 3 1 MUMBAI, MUMBAI vs. SAI PALACE HOTELS PVT.LTD, MUMBAI

ITA 472/MUM/2026Status: DisposedITAT Mumbai15 July 2026AY 2011-128 pages
AI SummaryDismissed

What were the facts?

The Assessing Officer (AO) estimated the annual letting value of the assessee's property based on stamp duty valuation of tenancy rights transfer, considering it outside rent control. The Commissioner (Appeals) deleted this addition, holding that rent control legislation applied and limited the annual value to standard rent.

What did the Tribunal hold?

The Tribunal held that the AO's method of estimating annual letting value based on stamp duty valuation of tenancy rights was unsustainable. It affirmed that where rent control legislation applies, the annual value cannot exceed the standard rent, and the AO failed to prove the property was outside such control.

What were the issues?

Whether the annual letting value of a property governed by rent control legislation can be determined based on market value or stamp duty valuation of tenancy rights, disregarding standard rent.

Which sections of the Income-tax Act were involved?

Section 23(1)(a),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI

Before: HON’BLENARENDER KUMAR CHOUDHRY & HON’BLE JAGADISH

For Appellant: Shri Ravi Ganatra, Adv
For Respondent: Shri Amit Gurav,Ld. Sr. D.R
Pronounced: 15.07.2026

PER:NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER : This appeal has been preferred by the REVENUEagainst the order dated 19.11.2025, impugned herein, passed by the /Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) u/s 250 of the Income Tax Act, 1961 (in short „the Act‟) for the A.Y. 2011-12. ITA 472/Mum/2026;

2.

The effective grievance of the Revenue is against the deletion of the addition of ₹3,50,87,298/- made by the Assessing Officer [“Ld. AO”] un

The order continues below.

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