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“fair market value”

Capital GainsSection 55(2)Section 55(2)2,353 judgments

The decision most relied on for fair market value is Sunil Kumar Agarwal v. CIT (372 ITR 83), cited in 159 judgments on BharatTax.

Leading authorities on fair market value

Sunil Kumar Agarwal v. CIT
372 ITR 83 · 2015 · High Court
159
citing judgments

The Assessing Officer is duty-bound to refer the valuation of property to the Departmental Valuation Officer under Section 50C(2) when an assessee disputes the stamp duty valuation or if there is a discrepancy between the actual sale consideration and the guideline value. This reference is mandatory, even if not explicitly requested by the assessee, to ensure a realistic fair market value and avoid injustice.

CIT v. ITC Ltd.
236 Taxmann 612 · 2016 · High Court
108
citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

PCIT v. Chain House International (P) Ltd.
98 Taxmann.com 47 · 2018 · High Court
104
citing judgments

The Assessing Officer cannot arbitrarily reject a share valuation report prepared by an expert using recognized methods like NAV or DCF for the purpose of Section 56(2)(viib) without providing valid reasons to demonstrate its perversity or unreasonableness.

CIT v. Puja Prints
360 ITR 697 · 2014 · High Court
88
citing judgments

The amendment to Section 55A(a) of the Income-tax Act, 1961, which replaced "is less than" with "is at variance" as the condition for referring a valuation to a Departmental Valuation Officer, does not have retrospective effect. Consequently, for periods before July 1, 2012, a DVO reference is invalid if the declared value is not "less than" the fair market value.

Vodafone M-Pesa Ltd. v. PCIT
164 DTR 257 · 2018 · High Court
69
citing judgments

An assessee has the option to choose either the Discounted Cash Flow (DCF) method or the Net Asset Value (NAV) method for share valuation under Section 56(2)(viib) read with Rule 11UA. The Assessing Officer cannot substitute the chosen method or value without identifying a specific error in the assessee's valuation.

Hiaben Jayantilal Shah v. ITO
310 ITR 31 · 2009 · High Court
66
citing judgments

When an assessee presents a registered valuer's report for an asset, the Assessing Officer, if forming an opinion that the value claimed is less than the fair market value, must refer the valuation to the Valuation Officer under Section 55A(a). The AO cannot unilaterally reject the registered valuer's report or resort to Section 55A(b) in such a scenario.

CIT v. Smt. Nilofer I. Singh
309 ITR 233 · 2009 · High Court
55
citing judgments

The full value of consideration for computing capital gains under Section 48 refers to the amount stated in the sale deed and cannot be substituted by the market value or a valuation by the DVO under Section 55A, unless there is evidence that the assessee actually received a consideration in excess of the stated amount.

CIT v. Gillanders Arbuthnot & Co.
87 ITR 407 · 1973 · Supreme Court
51
citing judgments

The "full value of the consideration" for computing capital gains under Section 48 of the Income Tax Act, 1961 (or Section 12B(2) of the 1922 Act), means the price actually bargained for and agreed to by the parties, not the market value of the asset transferred. In a sale transaction involving a price, the market value of the consideration is not relevant.

Judgments citing fair market value

Dy. Commissioner of Income Tax, Circle-7(1)(1), Mumbai vs. M/S Motilal Oswal Financial Services Ltd, Mumbai

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 1794/MUM/2023[2016-2017]Status: DisposedITAT Mumbai13 Sept 2023AY 2016-2017

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2016-17

For Appellant: Shri. Vijay Mehta, A.RFor Respondent: Shri. Jasbir S. Chouhan (CIT DR)
Section 143(3)Section 37(1)Section 45

books of accounts over the grant/vesting period. The assessee claimed the deduction in respect of the aggregate amount of excess of the fair market value of equity shares over the exercise price amounting to Rs. 28,65,26,826, under section 37(1) of the Act. As evident from

Imran Mohamed Ali Kapadia, Mumbai vs. The ITO, Ward-20(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2056/MUM/2023[2018-19]Status: DisposedITAT Mumbai12 Sept 2023AY 2018-19

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.2056/मुं/2023 (िन.व. 2018-19) Imran Mohamed Ali Kapadia, 1702/1703 Sumer Park, Bldg. No.1, Seth Motishah Cross Lane, Byculla, Mumbai 400 008 Pan: Aupk-9074-A ...... अपीलाथ"/Appellant बनाम Vs. Ito, Ward 20(1)(1), Piramal Chamber, G.B.Road, Lalbaug, Parel, Mumbai – 400 012 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Pratik Mehta "ितवादी "ारा/Respondent By : Shri H.M.Bhatt सुनवाई की ितिथ/ Date Of Hearing : 12/09/2023 घोषणा की ितिथ/ Date Of Pronouncement : 12/09/2023 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Center, Delhi [Hereinafter Referred To As ‘The Cit(A)’] Dated 06.04.2023, For Assessment Year 2018-19. 2. Shri. Pratik Mehta Appearing On Behalf Of The Assessee Submitted That The Solitary Issue In Present Appeal Is Against The Addition Of ₹30,47,000/- U/S 56(2)(X) Of The Income Tax Act, 1961

For Appellant: Shri Pratik MehtaFor Respondent: Shri H.M.Bhatt
Section 56(2)(x)

admitted by the builder in allotment letter, hence the date of allotment letter should be considered for the purpose of 3 determination of Fair Market Value (FMA) of immovable property. He referred to the proviso to section 56(2)(x)(b) of the Act. 2.2. Without prejudice to his primary ... There cannot be two FMV for the same property on a given date. Therefore, we direct the Assessing Officer to 6 adopt the Fair Market Value of the property` determined by the DVO as in the case of assessee’s brother. 7. In the result, appeal of the assessee

ACIT, Circle-8(1), New Delhi vs. Etawah Chakeri (Kanpur) Highway P.Ltd, New Delhi

In the result the appeal of the Revenue in ITA No

ITA 5906/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Sept 2023AY 2013-14

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri KVSR Krishna, CAFor Respondent: Shri T. James Singson, CIT- DR
Section 144ASection 56(2)(viib)

premium of Rs.90 per share. 6. On the issue of consideration received by the assessee for issuing of shares being more than the fair market value of such shares in terms of section u/s 56(2)(viib) r.w.s 2(24)(xvi) of the Act, directions under section 144A ... support from the relevant provisions of the Act, the Assessing Officer was of the opinion that the relevant provisions provides for determination of fair market value of shares in accordance with sections 11U and 11UA of the Act and as per Rule 11UA of the Act prevailing

M/S. K Lalchand Pvt Ltd., Mumbai vs. CIT (A), NFAC, Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 1023/MUM/2023[2014-15]Status: DisposedITAT Mumbai08 Sept 2023AY 2014-15

Bench: Shri Amit Shukla, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. K Lalchand Private Ltd V. Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre 1017/18, Dalamal Tower 10Th Floor, Nariman Point Mumbai - 400021

Section 143(1)Section 143(2)

have made adjustment of rental of Furniture for which the LLP paid concessional rent of Rs, 13,000/- per month per flat. The fair market value would have been Rs. 20,000/- A discount for long term rental and short term arrangement

DCIT Circle - 16(1), New Delhi vs. Aruna Chandhok, New Delhi

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 387/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Sept 2023AY 2015-16

Bench: Shri M. Balaganesh & Shri Anubhav Sharmadcit, Vs. Smt Aruna Chandhok, Circle-16(1), H-30, Sainik Farms, New Delhi Delhi-110062 (Appellant) (Respondent) Pan: Aaepc7861R

For Appellant: Sh. Pradeep Dinodia, CAFor Respondent: Shri P. Praveen Sidharth, CIT DR
Section 143(3)Section 55(2)(aa)Section 56(2)(vii)

circumstances of the case, the Tribunal was right in law in holding that the assessing authority is not correct in determining the fair market value as per Rule 11UA of the IT Rules at Rs 12,49,00,000/-on 1,00,00,000 bonus shares received by assessee ... counsel for the parties and have perused the record. The issue which arises for consideration in this appeal is 'as to whether the fair market value of bonus shares computed as per Rule 11U and Rule 11UA of the Income Tax Rules can be considered as income from other sources

Kartar Singh, Rohtak vs. ACIT, Circle- 42(1), New Delhi

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 3268/DEL/2019[2010-11]Status: DisposedITAT Delhi05 Sept 2023AY 2010-11

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 3268/Del/2019 : Asstt. Year : 2010-11 Kartar Singh, Vs Acit, C/O S.K. Bansal, Ca, Circle-42(1), 101, First Floor, Kochar Market, New Delhi-11 Jhajjar Road, Opp. Khanu Mandi, Rohtak, Haryana-12001 (Appellant) (Respondent) Pan No. Cskps5940K Assessee By : None Revenue By : Sh. Amit Katoch, Sr. Dr Date Of Hearing: 19.07.2023 Date Of Pronouncement: 05.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: NoneFor Respondent: Sh. Amit Katoch, Sr. DR
Section 49(1)Section 54B

based on surmises, suspicion and conjectures is wholly unjustified, arbitrary, haphazard, and without any jurisdiction to estimate such valuation as against the Fair Market Value of the land taken at Rs. 2.48 crore as on calculated by the Ld. A.O. at Rs. 12,69,03,930/- on the basis ... taxable u/s 45 of LT. Act. Provisions of section 45, 48, 55. 55A, 142(2A), etc. are not applicable in such cases because fair market value is not applicable under such circumstances without the option of the assessee. 6. That the ld. A.O. has erred in law as well

M/S. Neelkanth Mansions and Infrastructure Pvt Ltd., Mumbai vs. DCIT, Circle-14(1)(1), Mumbai

ITA 1638/MUM/2023[2018-19]Status: DisposedITAT Mumbai31 Aug 2023AY 2018-19

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2018-19

For Appellant: Shri. Gyaneshwar Kataram, A.RFor Respondent: Shri. Ashok Kumar Ambastha (SR. AR.)
Section 143(3)Section 250Section 55(2)(b)

have perused the impugned order passed by the Ld. CIT(A) which is with regard to the issue as to assessing the fair market value of the property which has not been considered by the AO under section 55(2)(b)(ii), whereas the issue raised by the assessee

Mondelez India Foods P.Ltd, Mumbai vs. Asst CIT RG 5(1)(2), Mumbai

ITA 1518/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Aug 2023AY 2012-13

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

related parties is not deductible where the AO is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods." In such event, so much of the expenditure as is so considered by him to be excessive or unreasonable shall

Mondelez India Foods P. Ltd, Mumbai vs. DCIT RG 5(1)(2), Mumbai

ITA 1240/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Aug 2023AY 2011-12

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

related parties is not deductible where the AO is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods." In such event, so much of the expenditure as is so considered by him to be excessive or unreasonable shall

Aman Growth Fund Pvt Ltd, New Delhi vs. Pr.CIT, Delhi

In the result, the appeal of the assessee is allowed

ITA 659/DEL/2021[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Sh. G.S.Pannu, Hon’Ble & Sh.Anubhav Sharmaita No. 659/Del/2021, A.Y. 2015-16 M/S. Aman Growth Fund Vs. Pr. Cit(Central), Private Limited Delhi-2 L-4, Green Park Extension New Delhi Pan : Aaaca0525B Appellant Respondent

Section 142(1)Section 143Section 143(3)Section 263Section 56Section 56(2)(viib)

received shares of various companies in which the public are not substantially interested, for a consideration which was less than the aggregate fair market value (hereinafter referred to as FMV). In all, assessee had acquired 26 companies and in 20 instances the consideration paid was below

M/S Sulaikha Clay Mines, Trivandrum vs. DCIT, Circle 1(2), Trivandrum

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 937/COCH/2022[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Sulaikha Clay Mines, Thiruvananthapuram vs. ACIT, Circle 1(2), Thiruvananthapuram

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 627/COCH/2022[2009-2010]Status: DisposedITAT Cochin31 Aug 2023AY 2009-2010

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Sulaikha Clay Mines, Thiruvananthapuram vs. ACIT, Circle 1(2), Thiruvananthapuram

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 626/COCH/2022[2007-2008]Status: DisposedITAT Cochin31 Aug 2023AY 2007-2008

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Sulaikha Clay Mines, Thiruvananthapuram vs. ACIT, Circle 1(2), Thiruvananthapuram

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 625/COCH/2022[2006-2007]Status: DisposedITAT Cochin31 Aug 2023AY 2006-2007

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Sulaikha Clay Mines, Thiruvananthapuram vs. ACIT, Circle 1(2), Thiruvananthapuram

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 624/COCH/2022[2005-2006]Status: DisposedITAT Cochin31 Aug 2023AY 2005-2006

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Sulaikha Clay Mines, Thiruvananthapuram vs. ACIT, Circle 1(2), Thiruvananthapuram

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 623/COCH/2022[2004-2005]Status: DisposedITAT Cochin31 Aug 2023AY 2004-2005

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

this sub-section, and the Assessing Officer is of opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or profession of the assessee ... thus only on a specific finding that the rate of the relevant goods or services is excessive or unreasonable having regard to the fair market value thereof, or the legitimate needs of the assessee’s business, or the benefit derived by or accruing to it therefrom, that the same could

Nearbuy Pte.. Ltd, Singapore vs. ACIT (Intl Tax) Circle 3(3) (1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 1607/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Aug 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(3)

value of shares was reduced by 50% within short span. Accordingly, he proposed to re-compute the capital gain by adopting Fair Market Value of shares at Rs.14,361/- per share. The assessee submitted that the sale value of shares has been determined on the basis of valuation report obtained ... shares under Discounted Cash Flow (DCF) method and arrived at the value of Rs.7,094/- per share. It was further submitted that the Fair market value of shares is required to be determined as per Rule 11UAA of Income tax Rules, only when the sale consideration 3 M/s. Nearbuy

ACIT- CC -4(2), Mumbai vs. Chalet Hotels Ltd. (As A Successor to M/S. Magna Distribution & Warehousing Pvt. Ltd.), Mumbai

ITA 2513/MUM/2021[2014-15]Status: DisposedITAT Mumbai30 Aug 2023AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकर अपील सं/ I.T.A. No.2505/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) & आयकर अपील सं/ I.T.A. No.2507/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.2510/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2013-14) & आयकर अपील सं/ I.T.A. No.2511/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T.A. No.2513/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) Acit, Central Circle-4(2) बिधम/ M/S. Chalet Hotels Ltd Room No. 1918, 19Th Floor, (As A M/S. Magna Vs. Air India Building, Nariman Distribution & Point, Mumbai-400021. Warehousing Pvt. Ltd.) Plot No. C-30 Raheja Tower, Bandra Kurla Complex, Bandra (E), Mumbai-400051. Pan No.Aaack0411E आयकर अपील सं/ I.T.A. No.1754/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.1755/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2015-16) & आयकर अपील सं/ I.T.A. No.1756/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2014-15) Genext Hardware & Parks बिधम/ Dcit, Central Circle-4(2) Pvt. Ltd. Room No. 1918, Air India Vs. Raheja Tower, Plot No. C- Building, Nariman Point, 30, Oppo. Sidbi, Bandra Mumbai-400021. Kurla Complex, Bandra (E), Mumbai-400051. Pan No. Aaccg5567F

Section 132Section 14ASection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI OM PRAKASH KANT

ACIT- CC -4(2), Mumbai vs. Chalet Hotels Ltd. (As A Successor to M/S. Magna Distribution & Warehousing Pvt. Ltd.), Mumbai

ITA 2511/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 Aug 2023AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकर अपील सं/ I.T.A. No.2505/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) & आयकर अपील सं/ I.T.A. No.2507/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.2510/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2013-14) & आयकर अपील सं/ I.T.A. No.2511/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T.A. No.2513/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) Acit, Central Circle-4(2) बिधम/ M/S. Chalet Hotels Ltd Room No. 1918, 19Th Floor, (As A M/S. Magna Vs. Air India Building, Nariman Distribution & Point, Mumbai-400021. Warehousing Pvt. Ltd.) Plot No. C-30 Raheja Tower, Bandra Kurla Complex, Bandra (E), Mumbai-400051. Pan No.Aaack0411E आयकर अपील सं/ I.T.A. No.1754/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.1755/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2015-16) & आयकर अपील सं/ I.T.A. No.1756/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2014-15) Genext Hardware & Parks बिधम/ Dcit, Central Circle-4(2) Pvt. Ltd. Room No. 1918, Air India Vs. Raheja Tower, Plot No. C- Building, Nariman Point, 30, Oppo. Sidbi, Bandra Mumbai-400021. Kurla Complex, Bandra (E), Mumbai-400051. Pan No. Aaccg5567F

Section 132Section 14ASection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI OM PRAKASH KANT

ACIT -CC -4(2), Mumbai vs. Chalet Hotels Ltd. (As A Successor to M/S. Magna Distribution Pvt. Ltd.), Mumbai

ITA 2510/MUM/2021[2013-14]Status: DisposedITAT Mumbai30 Aug 2023AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकर अपील सं/ I.T.A. No.2505/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) & आयकर अपील सं/ I.T.A. No.2507/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.2510/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2013-14) & आयकर अपील सं/ I.T.A. No.2511/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T.A. No.2513/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) Acit, Central Circle-4(2) बिधम/ M/S. Chalet Hotels Ltd Room No. 1918, 19Th Floor, (As A M/S. Magna Vs. Air India Building, Nariman Distribution & Point, Mumbai-400021. Warehousing Pvt. Ltd.) Plot No. C-30 Raheja Tower, Bandra Kurla Complex, Bandra (E), Mumbai-400051. Pan No.Aaack0411E आयकर अपील सं/ I.T.A. No.1754/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2016-17) & आयकर अपील सं/ I.T.A. No.1755/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2015-16) & आयकर अपील सं/ I.T.A. No.1756/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2014-15) Genext Hardware & Parks बिधम/ Dcit, Central Circle-4(2) Pvt. Ltd. Room No. 1918, Air India Vs. Raheja Tower, Plot No. C- Building, Nariman Point, 30, Oppo. Sidbi, Bandra Mumbai-400021. Kurla Complex, Bandra (E), Mumbai-400051. Pan No. Aaccg5567F

Section 132Section 14ASection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI OM PRAKASH KANT