MYRA MALL MANAGEMENT COMPANY PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 7(2)(2), MUMBAI

ITA 3360/MUM/2026Status: DisposedITAT Mumbai27 August 202611 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, engaged in leasing commercial premises, filed its return declaring a loss. During scrutiny, the AO added a difference between Form 26AS rental receipts and reported income, and disallowed a portion of interest expenditure claimed. The CIT(A) upheld these additions.

What did the Tribunal hold?

The Tribunal held that the assessment order was not barred by limitation. However, it restored the issues of addition on account of rental income difference and disallowance of interest expenditure to the AO for de novo verification.

What were the issues?

The key issues were the validity of the assessment order due to alleged limitation, the addition of rental income based on Form 26AS, and the disallowance of interest expenditure on inter-corporate deposits.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 24(a),Section 24(b),Section 36(1)(iii),Section 234B,Section 244A,Section 234D,Section 271(1)(c),Section 115JAA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SMT. BEENA PILLAI, HON’BLE & SMT. RATNA DASGUPTA, HON’BLE

For Respondent: Shri Sree Kumar C., Sr. DR

PER SMT. BEENA PILLAI, JUDICIAL MEMBER:

Present appeal filed by the assessee arises out of the order dated 17/02/2026 passed by the National Faceless Appeal Centre, Delhi [hereinafter referred to as “Ld.CIT(A)”], for A.Y. 2012-13, on the following grounds of appeal:-

“1. Re.: Validity of Assessment Order:

ITA 3360/M

The order continues below.

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