(i) ACIT v. Tata Housing Development Company Ltd.

45 SOT 9Income Tax Appellate Tribunal2011#8475 most cited

What is (i) ACIT v. Tata Housing Development Company Ltd. authority for?

Interest paid on borrowed funds used for construction is deductible as a revenue expenditure, even if the assessee follows the projection completion method. Such interest can be allowed as a deduction under section 36(1)(iii).

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2016 to 2026.

Also referred to as

ACIT vs Tata Housing Development Company Ltd · 45 SOT 9 · section 36(1)(iii) · interest on borrowed funds · construction · revenue expenditure · projection completion method · deduction of interest

Sections most often in play

Section 143(3)Section 250Section 37Section 37(1)Section 68

Judgments citing (i) ACIT v. Tata Housing Development Company Ltd.

Deputy Commissioner of Income Tax, Mumbai vs. Mahindra and Mahindra Financial Services Limited, Mumbai

In the result, the appeal is dismissed

ITA 6005/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethdeputy Commissioner Of Vs. Mahindra & Mahindra Financial Income Tax R. No. 126, Services Limited Mahindra Towers, 4Th Floor, 570 P.B. Marg, Aayakar Bhawan, Maharhi Karve Marg, Worli, Mumbai-400020. Mumbai-400018. Pan/Gir No: Aaacm2931R (Appellant) (Respondent)

Section 143(3)Section 250Section 37Section 37(1)Section 68

…n for which the amount was borrowed. The case of the assessee is even otherwise ITA No.6005/MUM/2025/AY 2017-18 Mahindra and Mahindra Financial Services Limited covered by the dedcision of the Tribunal in ACIT vs Tata Housing Developing Company Ltd. (2011) 45 SOT 9. The gist of which has been reproduced at page 15 of the impugned order. The details filed by the assessee clearly shows that the expenditure was incurred during the year and this fact has not been disputed by the Assessing Officer. In the past, identical claim was allowed as revenue expenditure by the Department, thus, without bringing any contrary…

Pr. CIT -3 vs. Dlf Ltd.(Fomerly Known As Dlf Universal Ltd

ITA/926/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…0 Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon‟ble Karnataka High Court vide it…

Pr. CIT -3 vs. Dlf Ltd. (Formerly Known As Dlf Universal Ltd.)

ITA/928/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…0 Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon‟ble Karnataka High Court vide it…

DCIT, New Delhi vs. M/S. Dlf Ltd., New Delhi

ITA 4793/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Sept 2020AY 2010-11

Bench: Sh. Prashant Maharishi & Sh. K. N. Chary(Through Video Conferencing) Assessment Year: 2010-11 Dlf Limited Jcit Dlf Centre, (9Th Floor) Vs Range-10 Sansad Marg, 404, C. R. Building New Delhi-110001 New Delhi Pan No.Aaacd3494N (Appellant) (Respondent) Assessment Year: 2010-11 Dcit Vs. Dlf Ltd. Circle –7 (1) Sansad Marg New Delhi New Delhi Pan No. Aaacd3494N (Appellant) (Respondent)

Section 14ASection 80I

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble Karnataka High Court vide its order d…

Dlf Ltd., New Delhi vs. JCIT, New Delhi

ITA 4187/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Sept 2020AY 2010-11

Bench: Sh. Prashant Maharishi & Sh. K. N. Chary(Through Video Conferencing) Assessment Year: 2010-11 Dlf Limited Jcit Dlf Centre, (9Th Floor) Vs Range-10 Sansad Marg, 404, C. R. Building New Delhi-110001 New Delhi Pan No.Aaacd3494N (Appellant) (Respondent) Assessment Year: 2010-11 Dcit Vs. Dlf Ltd. Circle –7 (1) Sansad Marg New Delhi New Delhi Pan No. Aaacd3494N (Appellant) (Respondent)

Section 14ASection 80I

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble Karnataka High Court vide its order d…

DCIT, New Delhi vs. M/S. Dlf Ltd., New Delhi

ITA 4436/DEL/2013[2009-10]Status: DisposedITAT Delhi10 Sept 2020AY 2009-10

Bench: Sh. Prashant Maharishi & Sh. K. Narashimha Chary(Through Video Conferencing) Assessment Year: 2009-10 Dlf Limited Addl. Cit Dlf Centre, (9Th Floor) Vs Range-10 Sansad Marg, 404, C. R. Building New Delhi-110001 New Delhi Pan No.Aaacd3494N (Appellant) (Respondent) Dcit Vs. Dlf Ltd. Circle –7 (1) Sansad Marg New Delhi New Delhi Pan No. Aaacd3494N (Appellant) (Respondent)

Section 14ASection 23(1)

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon‟ble Karnataka High Court vide its order…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 4061/DEL/2013[2009-10]Status: DisposedITAT Delhi10 Sept 2020AY 2009-10

Bench: Sh. Prashant Maharishi & Sh. K. Narashimha Chary(Through Video Conferencing) Assessment Year: 2009-10 Dlf Limited Addl. Cit Dlf Centre, (9Th Floor) Vs Range-10 Sansad Marg, 404, C. R. Building New Delhi-110001 New Delhi Pan No.Aaacd3494N (Appellant) (Respondent) Dcit Vs. Dlf Ltd. Circle –7 (1) Sansad Marg New Delhi New Delhi Pan No. Aaacd3494N (Appellant) (Respondent)

Section 14ASection 23(1)

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon‟ble Karnataka High Court vide its order…

Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore vs. M/S. Cornerstone Property Investments Private Limited, Bangalore

In the result, both the appeals of the revenue are dismissed

ITA 1083/BANG/2019[2014-15]Status: DisposedITAT Bangalore14 Aug 2020AY 2014-15

Bench: Shri A. K. Garodia & Smt. Beena Pillai

For Appellant: Shri. V. Sreenivasan, AdvocateFor Respondent: Ms. Neera Malhotra. CIT DR
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI A. K. GARODIA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No. 1082 & 1083/Bang/2019 Assessment years : 2013 – 14 & 2014 – 15 DCIT Central Circle 2 (2), M/s Cornerstone Property Investment (P) Ltd., No. 583, 9th Main Road, Bengaluru Vs. Off CMH Road, Indiranagar Road, Bengaluru - 560038 PAN : AACCC8744Q APPELLANT RESPONDENT Assessee by : Shri. V. Sreenivasan, Advocate Revenue by : Ms. Neera Malhotra. CIT DR Date of hearing : 30.07.2020 Date of Pronouncement : 14.08.2020 O R D E R PER ARUN KUMAR GARODIA, A. M.: Both these appea…

Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore vs. M/S. Cornerstone Property Investments Private Limited, Bangalore

In the result, both the appeals of the revenue are dismissed

ITA 1082/BANG/2019[2013-14]Status: DisposedITAT Bangalore14 Aug 2020AY 2013-14

Bench: Shri A. K. Garodia & Smt. Beena Pillai

For Appellant: Shri. V. Sreenivasan, AdvocateFor Respondent: Ms. Neera Malhotra. CIT DR
Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI A. K. GARODIA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No. 1082 & 1083/Bang/2019 Assessment years : 2013 – 14 & 2014 – 15 DCIT Central Circle 2 (2), M/s Cornerstone Property Investment (P) Ltd., No. 583, 9th Main Road, Bengaluru Vs. Off CMH Road, Indiranagar Road, Bengaluru - 560038 PAN : AACCC8744Q APPELLANT RESPONDENT Assessee by : Shri. V. Sreenivasan, Advocate Revenue by : Ms. Neera Malhotra. CIT DR Date of hearing : 30.07.2020 Date of Pronouncement : 14.08.2020 O R D E R PER ARUN KUMAR GARODIA, A. M.: Both these appea…

DCIT, New Delhi vs. M/S. Dlf Ltd., New Delhi

ITA 2749/DEL/2013[2008-09]Status: DisposedITAT Delhi27 May 2019AY 2008-09

Bench: Shri Amit Shukla & Shri L.P. Sahu

For Appellant: Shri R.S. Singhvi & Shri SatyajeetFor Respondent: Shri Puneet Rai, Adv. Special counsel
Section 10Section 142ASection 143(3)Section 14ASection 40Section 43B

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assessee has followed the projection completion method:- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; I.T.A. No.2126 & 2749/DEL/2013 110 (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 2126/DEL/2013[2008-09]Status: DisposedITAT Delhi27 May 2019AY 2008-09

Bench: Shri Amit Shukla & Shri L.P. Sahu

For Appellant: Shri R.S. Singhvi & Shri SatyajeetFor Respondent: Shri Puneet Rai, Adv. Special counsel
Section 10Section 142ASection 143(3)Section 14ASection 40Section 43B

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assessee has followed the projection completion method:- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; I.T.A. No.2126 & 2749/DEL/2013 110 (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble…

ACIT, New Delhi vs. M/S Dlf Ltd., New Delhi

ITA 3061/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble Karnataka High Court vide its order d…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 2677/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…is case.” Further, in the following decisions of various coordinate Benches, the deduction of interest has been allowed u/s 36(1)(iii) even where the assesse has followed the projection completion method :- (i) ACIT vs. Tata Housing Development Company Ltd. – 45 SOT 9 (Bom.); (ii) DCIT vs. Thakar Developers – 115 TTJ 841 (Pune); (iii) DCIT vs. K. Raheja Pvt. Ltd. – (2006) TIOL 220 ITAT-MUM.; (iv) K. Raheja Development Corporation vs. DCIT in ITA No.240/Bang./97 dated 22.09.1997 - In this case, reference application filed by the Department has also been rejected by the Hon’ble Karnataka High Court vide its order d…

(i) ACIT v. Tata Housing Development Company Ltd. (45 SOT 9) — Cited in 13 Judgments | BharatTax