IFCI Infrastructure Development Ltd. vs Addl/Jt. CIT Range-4, New Delhi
Case No: ITA Nos. 3653, 3654, 3655 & 3656/Del/2023
Court: Income Tax Appellate Tribunal (Delhi Bench ‘C’, New Delhi)
Date: 3/12/2025
Parties Involved
appellantIFCI Infrastructure Development Ltd.
respondentAddl/Jt. CIT Range-4, New Delhi
Facts Summary
The assessee, IFCI Infrastructure Development Limited, is a company engaged in property development and running service apartments under the name 'Frazer Suites' in New Delhi. For the assessment year 2012-13, the assessee filed its return of income declaring income at Rs. 9,46,04,630/-. During the scrutiny assessment of AY 2016-17, it was noticed that the assessee could not substantiate the claim of Rs. 90,73,672/- as pre-operative expenses under section 35D of the Act. Consequently, the case wa…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the order of the Ld. CIT(A) is bad in law and wrong on facts.
- 2. Whether the Ld. CIT(A) erred in upholding the assessment under section 147 where the notice was issued after more than 4 years from the end of the assessment year.
1 more legal issue analysed in this judgement.