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Pawan Edifice Pvt. Ltd. v. The Deputy Commissioner of Income Tax

Case No: ITA Nos. 477-478/Ahd/2023 and ITA No. 529/Ahd/2023
Court: Income Tax Appellate Tribunal, Ahmedabad
Date: 8/20/2025

Parties Involved

appellantPawan Edifice Pvt. Ltd.
respondentThe Deputy Commissioner of Income Tax, Circle-2(1)(2), Vadodara

Facts Summary

The assessee, Pawan Edifice Pvt. Ltd., a company engaged in the construction and development of residential premises, filed its income returns for the assessment years 2013-14 and 2014-15. The Assessing Officer issued notices under section 143(2) and made various disallowances and additions, determining the assessed income. The assessee and the Revenue appealed against the orders passed by the Commissioner of Income Tax (Appeals). The key issues involved disallowances under section 14A, addition of interest on advances, disallowance of site development expenses, and addition on account of cancelled bookings, among others.

Decision in favour of

Partly Assessee

Legal Issues

  • 1. Disallowance u/s 14A r.w. Rule 8D
  • 2. Charging of Notional interest on advances given to related parties / disallowance under section 36(1)(iii)
  • 3. Addition on account of Notional interest on advances/rent
  • 4. Cost of land / purchase of land Rs. 15,16,966/- A.Y. 2013-14
  • 5. Disallowance of Site development expenses / soil filling expenses
  • 6. Deduction of Rs.1,71,000/- under section 80GGB for the A.Y. 2013-14

5 further legal issues analysed in the full judgement.

Judgment Outcome

Decided in favour of Partly Assessee.

Precedents Relied Upon

15 precedents cited in this judgement.

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