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Judgment
PER SATBEER SINGH GODARA, JM
These Revenue’s twin appeals involving as many assesses M/s Rekantaa Developers Pvt. Ltd. & M/s Prayas Infosolutions Pvt. Ltd; ITA 7693 & 7694/Del/2025, arise against Commissioner of Income Tax (Appeal)-23 [in short, “CIT(A)”], New Delhi’s orders dated 30.08.2025, passed in DINs & Order Nos. ITBA/APL/S/250/2025-26/1080193173(1) & ITBA/APL/S/250/2025-26/1080186695(1), involving proceedings u/s 143(3) & 143 r.w.s 147 of the Income Tax Act, 1961; hereinafter referred to as ‘the Act’, respectively.
Heard both the parties at length. Case files perused.
Delay of 25 days in filing of the Revenue’s former appeal ITA No. 7693/Del/2025 stands condoned in the larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
It next transpires that the Revenue’s identical substantive grounds in both these appeals seek to reverse the learned CIT(A) detailed lower appellate discussion inter alia deleting the corresponding predictive additions made in these twin assessee’s hands. The Revenue could hardly dispute that the learned CIT(A) has made it clear that he had confirmed the corresponding substantive additions in the searched party’s hands. We thus see no merit in the revenue’s endeavour herein seeking to revive impugned predictive addition instances of double addition.
So far as the Revenue’s latter substantive ground in case of M/s Rekanta Developers Private Limited seeking to uphold section 14A read with Rule 8D disallowance of Rs. 9,08,253/- is concerned, it is noticed that the learned CIT(A) detailed discussion, has followed this tribunal’s order in the preceding assessment year 2014-15 that the same does not get attracted in an instance of absence of any exempt income in light of Cheminvest Ltd. v. CIT (2009) 317 ITR 86 (Delhi). We thus find no merit in the Revenue’s instant substantive grounds; be it on the issue of undisclosed income as well as disallowance relating to exempt income, as the case may be, which are hereby rejected in foregoing terms.
No other ground or argument has been pressed before us.
These Revenue’s twin appeals 7693 & 7694/Del/2025 are dismissed. A copy of this common order be placed in the respective case files.