MICHELLE YOHAN POONAWALLA,PUNE vs. DCIT CIRCLE-7, PUNE

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ITA 539/PUN/2025Status: DisposedITAT Pune28 August 2025AY 2016-17Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)1 pages

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

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that the issue was already decided against the assessee in their own case by a Coordinate Bench. Consequently, the appeals were dismissed.

What were the facts?

The appeals were filed against orders relating to assessment years 2015-16, 2016-17 and 2018-19 concerning the allowability of interest paid on borrowed capital for relinquishing tenancy rights.

What were the issues?

Whether interest paid on borrowed capital for the purpose of payment to tenants for relinquishment of tenancy rights is allowable as a deduction.

Which sections of the Income-tax Act were involved?

Section 24(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & SHRI VINAY BHAMORE

For Appellant: Shri Nikhil S Pathak
For Respondent: Shri Ramnath P Murkunde

filed by the assessee is directed against the order dated 10.01.2025 of the Ld. Addl / JCIT(A)-5, Kolkata relating to assessment year 2015-16.

23.01.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2016-17. filed by the assessee is directed against the order dated 25.02.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2018-19. Since common issues are involved in all these appeals, therefore, these wesre heard together and are being disposed of by this common order for the sake of convenience.

2.

The only issue raised by the assessee in the above 3 appeals is regarding the allowability of interest u/s 24(b) of the Income Tax Act, 1961 paid on borrowed capital utilized for payment to the tenants for relinquishment of tenancy rights.

3.

The Ld. Counsel for the assessee at the outset fairly conceded that the issue stands decided against the assessee by the decision of the Coordinate Bench of the Tribunal in assessee’s own case for assessment years 2013-14 and 2017-18 vide & 665/PUN/2024 order dated 18.09.2024.

4.

In view of the above submission of the Ld. Counsel for the assessee and in absence of any objection from the side of the Ld. DR, the above 3 appeals filed by the assessee are dismissed.

5.

In the result, all the three appeals filed by the assessee are dismissed.

Order pronounced in the open Court at the conclusion of hearing itself i.e. on 28th August, 2025.

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