DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, DELHI vs. REKANTAA DEVELOPERS PVT. LTD., DELHI

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ITA 7693/DEL/2025Status: DisposedITAT Delhi29 April 2026AY 2016-174 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal found no merit in the Revenue's grounds. It noted that the CIT(A) had confirmed additions in the searched party's hands, thus rejecting the Revenue's attempt to revive predictive additions. The Section 14A disallowance was also rejected as there was no exempt income, following established precedent.

What were the facts?

The Revenue filed appeals against the CIT(A)'s orders which deleted additions made in the hands of two assessees, Rekantaa Developers Pvt. Ltd. and Prayas Infosolutions Pvt Ltd. The Revenue also sought to uphold a disallowance under Section 14A for Rekantaa Developers.

What were the issues?

Whether the CIT(A) erred in deleting additions made in the assessees' hands and whether the Section 14A disallowance was justified in the absence of exempt income.

Which sections of the Income-tax Act were involved?

Section 14A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘E’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Respondent: Ms. Ankush Kalra, Adv
Hearing: 15.04.2026Pronounced: 15.04.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 7693/Del/2025 Assessment Year: 2016-17 Deputy Commissioner of Vs. Rekantaa Developers Pvt. Ltd Income Tax 1037, First Floor, Room No. 2, Central Circle-3 Tilak Bazaar Chowk, Delhi- 06 Room No. 333 ARA Centre, E-2, Jhandewalan Extension New Delhi-55 PAN/TAN: AAICM3804H (Appellant) (Respondent) ITA No. 7694/Del/2025 Assessment Year: 2012-13 Vs. Prayas Infosolutions Pvt Ltd. Deputy Commissioner of Income Tax 1037, First Floor, Room No. 2, Central Circle-3 Tilak Bazaar Chowk, Delhi- 06 Room No. 333 ARA Centre, E-2, Jhandewalan Extension New Delhi-55 PAN/TAN: AADCP9503H (Appellant) (Respondent)

Assessee by Sh. Prateek Mittal, CA Department by Ms. Ankush Kalra, Adv. Date of hearing 15.04.2026 Date of pronouncement 15.04.2026 ORDER PER SATBEER SINGH GODARA, JM These Revenue’s twin appeals involving as many assesses M/s Rekantaa Developers Pvt. Ltd. & M/s Prayas

ITA No.7693 & 7694/Del/2025 Infosolutions Pvt. Ltd; ITA 7693 & 7694/Del/2025, arise against Commissioner of Income Tax (Appeal)-23 [in short, “CIT(A)”], New Delhi’s orders dated 30.08.2025, passed in DINs & Order Nos. ITBA/APL/S/250/2025-26/1080193173(1) & ITBA/APL/S/250/2025-26/1080186695(1), involving proceedings u/s 143(3) & 143 r.w.s 147 of the Income Tax Act, 1961; hereinafter referred to as ‘the Act’, respectively.

Heard both the parties at length. Case files perused.

2.

Delay of 25 days in filing of the Revenue’s former appeal ITA No. 7693/Del/2025 stands condoned in the larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3.

It next transpires that the Revenue’s identical substantive grounds in both these appeals seek to reverse the learned CIT(A) detailed lower appellate discussion inter alia deleting the corresponding predictive additions made in these twin assessee’s hands. The Revenue could hardly dispute that the learned CIT(A) has made it clear that he had confirmed the corresponding substantive

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ITA No.7693 & 7694/Del/2025 additions in the searched party’s hands. We thus see no merit in the revenue’s endeavour herein seeking to revive impugned predictive addition instances of double addition.

4.

So far as the Revenue’s latter substantive ground in case of M/s Rekanta Developers Private Limited seeking to uphold section 14A read with Rule 8D disallowance of Rs. 9,08,253/- is concerned, it is noticed that the learned CIT(A) detailed discussion, has followed this tribunal’s order in the preceding assessment year 2014-15 that the same does not get attracted in an instance of absence of any exempt income in light of Cheminvest Ltd. v. CIT (2009) 317 ITR 86 (Delhi). We thus find no merit in the Revenue’s instant substantive grounds; be it on the issue of undisclosed income as well as disallowance relating to exempt income, as the case may be, which are hereby rejected in foregoing terms.

No other ground or argument has been pressed before us.

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ITA No.7693 & 7694/Del/2025

5.

These Revenue’s twin appeals 7693 & 7694/Del/2025 are dismissed. A copy of this common order be placed in the respective case files.

Order pronounced in the open court on 15th April, 2026.

Sd/- Sd/- (MANISH AGARWAL) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 29.04.2026 Pooja Mittal/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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