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Deputy Commissioner of Income Tax, Central Circle-1, ARTO Complex, 2nd Floor, Sector-33, Noida, Uttar Pradesh-201301 vs Elixir Buildcon Pvt. Ltd., Plot No. 15A, Elixir Business Park, Sector-127, Gautam Buddh Nagar, Noida, Uttar Pradesh-201301

Case No: ITA No.- 2275/Del/2023
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH, B: NEW DELHI
Date: 1/28/2026

Parties Involved

RevenueDeputy Commissioner of Income Tax, Central Circle-1, ARTO Complex, 2nd Floor, Sector-33, Noida, Uttar Pradesh-201301
AssesseeElixir Buildcon Pvt. Ltd., Plot No. 15A, Elixir Business Park, Sector-127, Gautam Buddh Nagar, Noida, Uttar Pradesh-201301

Facts Summary

During the year, the assessee, Elixir Buildcon Pvt. Ltd., carried out activity of running a guest house and restaurant under the name & style of M/s Hide away suites at Elixir business park, 15A, Sector-127, Noida. The Assessing Officer made two additions: (i) Addition of Rs. 47,50,000/- under section 68 of the Act in respect of unsecured loans received from M/s Cosmic Solution Pvt. Ltd.; and (ii) Addition of ₹3,42,47,147/- on account of disallowance of “finance costs”. The assessee had received an unsecured loan of Rs. 47,50,000/- from M/s Cosmic Solution Pvt. Ltd. and claimed finance costs of Rs. 3,42,47,147/- as assured return to Anand Kumar. The Assessing Officer disallowed these claims, which were subsequently deleted by the Commissioner of Income Tax (Appeals). The Revenue then filed an appeal against the order of the Commissioner of Income Tax (Appeals).

Decision in favour of

Revenue

Legal Issues

  • 1. Whether the addition of Rs. 47,50,000/- under section 68 of the Act in respect of unsecured loans received from M/s Cosmic Solution Pvt. Ltd. was correctly deleted by the Ld. CIT(A).
  • 2. Whether the disallowance of Rs. 3,42,47,147/- on account of disallowance of “finance costs” was correctly deleted by the Ld. CIT(A).

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

1 precedent cited in this judgement.

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