ITA No. 4754/Mum/2025

Parties Involved

Facts Summary

The assessee, Lodha Developers Limited, is a company engaged in real estate construction and development. For the assessment year 2016-17, the assessee filed its return of income electronically declaring a total income of Rs. 83,28,22,820/-. The case was selected for scrutiny under CASS, and the assessment was completed determining the total income at Rs. 85,13,75,670/- under the normal provisions and computing book profit under section 115JB at Rs. 54,05,47,601/-. The Assessing Officer made several additions including ERP/Software Expenses, disallowance under Section 14A read with Rule 8D, and Debenture Redemption Reserve under Section 115JB. Aggrieved by the assessment order, the assessee appealed before the CIT(A), which allowed certain grounds raised by the assessee. The Revenue then appealed before the Income Tax Appellate Tribunal raising several grounds of appeal.…

Legal Issues

• 1. Deletion of disallowance of ERP / software expenses of Rs. 1,06,60,841/-
• 2. Disallowance under section 14A read with Rule 8D amounting to Rs. 78,91,710/-
• 3. Addition of Debenture Redemption Reserve (DRR) of Rs. 37.50 crores to book profit under section 115JB

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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