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AMBIENCE PRIVATE LIMITED Vs. INCOME TAX OFFICER, WARD-2(1), DELHI

Case No: ITA 2638/DEL/2026
Court: INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCHES, NEW DELHI
Date: 9/9/2026

Parties Involved

appellantAMBIENCE PRIVATE LIMITED
respondentINCOME TAX OFFICER, WARD-2(1), DELHI

Facts Summary

The assessee company, AMBIENCE PRIVATE LIMITED, is engaged in the business of real estate and infrastructure development. The return of income was filed on 31.10.2023, declaring a total loss of INR 14,05,48,926/-. The case was selected for scrutiny under CASS due to large payments made under section 194C to persons who had not filed their ITRs. Notices under section 133(6) were issued to three payees, but no reply was received. Consequently, the Assessing Officer (AO) disallowed 30% of the total payment amounting to INR 48,25,069/-, assessing the total loss at INR 13,51,98,542/-. The assessee appealed against this order to the Commissioner of Income Tax (Appeals), which was dismissed. The assessee then appealed to the Tribunal.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the disallowance of 30% of the total expenditure claimed by the AO was justified?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

1 precedent cited in this judgement.

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