Intime Properties Limited Vs DCIT (ITAT Hyderabad)
The appeal before the Income Tax Appellate Tribunal, Hyderabad Bench arose from the order of the Commissioner of Income Tax (Appeals)-52, Mumbai, dated 30 May 2025, for Assessment Year (AY) 2014–15. The assessee, a company engaged in developing and maintaining industrial and non-industrial parks, derived income mainly from leasing or licensing space, maintenance services, and sale of developed areas in non-industrial parks.
For AY 2014–15, the assessee filed its return declaring total income of ₹4,68,76,570 after claiming deduction under Section 80-IA of the Income Tax Act, 1961, amounting to ₹26,73,12,820 under normal provisions. It also declared book profit of ₹28,05,74,172 under the Minimum Alternate Tax (MAT) provisions. The case was selected for scrutiny, and notice under Section 143(2) was issued. After assessment, the Assessing Officer (AO) computed total income at ₹5,07,75,345 and allowed deduction under Section 80-IA at a reduced figure of ₹26,62,22,377, thereby disallowing a portion of the claim.
The assessee appealed before the Commissioner (Appeals), who dismissed the appeal. The assessee then approached the Tribunal. At the outset, the sole issue identified was the denial of deduction under Section 80-IA in respect of interest of ₹38,98,773 received on an income-tax refund.
