BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT, 1(2)1, MUMBAI

ITA 5319/MUM/2025Status: DisposedITAT Mumbai13 February 2026AY 2018-19Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL ( (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal restored the issue related to Section 43CA additions to the Assessing Officer for adjudication, considering additional evidence. Grounds related to disallowance under Section 14A and adjustment for book profit under Section 115JB were allowed.

What were the facts?

The assessee, Bajaj International Reality Private Limited, filed appeals against orders upholding additions made under Section 43CA of the Income Tax Act. The dispute involved the applicability of Section 43CA to property bookings made prior to its insertion and the method of revenue recognition.

What were the issues?

Whether Section 43CA is applicable to transactions prior to its insertion and whether revenue recognition under POCM affects its applicability. Also, the applicability of Section 14A disallowance and adjustments to book profit under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 43CA,Section 14A,Section 115JB

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “B” MUMBAI

Before: SHRI OM PRAKASH KANT & MS. KAVITHA RAJAGOPAL

For Appellant: Shri Leyaqat Ali Aafaqui, Sr. AR
Pronounced: 13/02/2026

PER OM PRAKASH KANT, AM

These two appeals by the assessee are directed against two separate orders, both dated 16.06.2025, passed by the Learned Commissioner of Income Tax (Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for Assessment Year (in short A.Y) 2016 -17 and 2018 -19 respectively. As common issue in dispute

Bajaj International Reality Bajaj International Reality 2 Private Limited ITA Nos. 5321 and 5319 5321 and 5319/MUM/2025

is involved in these appeals and therefore sa n these appeals and therefore same w

The order continues below.

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