Shree Bal Properties & Finance P. Ltd Vs PCIT

This order consolidates two appeals filed by Shree Bal Properties & Finance P. Ltd concerning assessment year 2014-15. The appeals challenge orders from the Principal Commissioner of Income-tax under Section 263 and the CIT(Appeals) under Section 80P. Both orders stem from an assessment originally framed by the Assessing Officer under Section 143(3). The issues in both appeals are closely related and are being addressed together.

IN THE INCOME TAX APPELLATE TRIBUNAL
“G” Bench, Mumbai

Before Shri G. Manjunatha, Accountant Member
and Shri Ravish Sood, Judicial Member

ITA No. 2848/Mum/2019
(Assessment Year: 2014-15)

M/s Shree Bal Properties & Finance P. Ltd
4, Buona Case, Sir P.M Road,
Opp. Kashmir Arts Emporium,
Fort, Mumbai - 400 001.

Vs.

Pr. Commissioner of Income-tax -2,
Room No. 344, 3rd Floor, Aaykar Bhavan
M.K Road, Mumbai – 400 020.
PAN –AACCS1776N

ITA No. 345/Mum/2018
(Assessment Year: 2014-15)

M/s Shree Bal Properties & Finance P. Ltd
4, Buona Case, Sir P.M Road,
Opp. Kashmir Arts Emporium,
Fort, Mumbai - 400 001.

Vs.

Dy. Commissioner of Income-tax 2(3)(2),
Room No. 552, Aaykar Bhavan
M.K Road, Mumbai – 400 020.
PAN – AACCS1776N

Appellant by: S/shri Mihir Naniwadekar & Kalpesh Turalkar, A.Rs
Respondent by: S/shri Salil Mishra, CIT D.R & V.Vinod Kumar, D.R
Date of Hearing: 04.03.2020
Date of Pronouncement: 09.06.2020

O R D E R

PER RAVISH SOOD, JM

The present appeals filed by the assessee are directed against the respective orders passed by the Pr. Commissioner of Income-tax-2, Mumbai [Pr.CIT] under Sec. 263 of the Income-tax Act, 1961 [for short ‘Act’], dated 26.03.2019 AND the order passed by the CIT(Appeals)-6, Mumbai, dated 08.11.2017, both of which arises from the assessment framed by the A.O u/s 143(3) of the Act, dated 28.12.2016. As the issues involved in the captioned appeals are inextricably interlinked or in fact interwoven, therefore, the same are being taken up and disposed off together by way a common order. We shall first advert to the appeal filed by the asssessee against the order passed by the Pr. CIT u/s 263 of the Act, wherein the impugned order has been assailed on the following grounds of appeal before us :

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